WASHINGTON — The National Cattlemen’s Beef Association and a coalition of companies and trade associations representing U.S. energy and mining sectors submitted written comments opposing a recent Environmental Protection Agency proposal to regulate greenhouse gas emissions under the Clean Air Act. The proposed regulations were based on agency findings that concluded greenhouse gas emissions pose a threat to public health and welfare. The coalition said the regulations would be devastating to the agriculture sector, and the U.S. economy as a whole.

"With so much scientific uncertainty surrounding the question of whether human activity is responsible for climate change, it is inappropriate for the E.P.A. to only consider one side of the debate — especially considering the devastating consequences that their actions could have on an already struggling U.S. economy, " said Tamara Thies, N.C.B.A. chief environmental counsel. "Additionally, the Clean Air Act is ill-equipped to regulate greenhouse gases. Should E.P.A. move forward, we could find ourselves in a mire of bureaucracy and red tape."

Manure management facilities associated with livestock production account for less than 1% of total U.S. G.H.G. emissions, the E.P.A. previously said. Regulation of these emissions would be inconsequential to the climate change equation, the group stated. Rather than being unnecessarily regulated, agriculture should be considered an important solution to climate change.

Comments submitted to the E.P.A. are based upon a number of extensive climate studies conducted by leading environmental scientists from across the world. Here is an excerpt from the comments:

"…We submit there is neither a sound nor adequate basis to make a Finding of Endangerment to public health or welfare from anthropogenic greenhouse gases under Section 202[a] of the Clean Air Act. E.P.A.’s Proposed Finding fails to acknowledge the profound uncertainty that pervades the current state of scientific knowledge related to human-caused climate change. Instead, the Administrator has touted a supposed ‘scientific consensus’ while unduly relying on speculative and uncertain data and models, resulting in a Proposed Finding that is nothing more than a tissue of assumptions, presumptions, and unsubstantiated science."

E.P.A. is being urged by the groups to postpone regulation until climate science can address the profound uncertainty that currently exists in climate data and modeling.

"Before mandating drastic regulation on U.S. industry, E.P.A. has a responsibility to conclusively demonstrate that altering human activities could mitigate climate change issues," Ms. Thies said.