Docket 7373 Exhibit DPS-VDH-2 73 Pages POSITION PAPER ON ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS AND THE VELCO SOUTHERN LOOP PROJECT PREPARED BY VERMONT DEPARTMENT OF HEALTH OFFICE OF PUBLIC HEALTH PREPAREDNESS JUNE 9, 2008 1 TABLE OF CONTENTS I. SUMMARY……………………………………………………………………………....……5 II. CURRENT SCIENTIFIC VIEW OF HUMAN HEALTH EFFECTS RELATED TO ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS……………….….…..…12 A. Transmission Power Lines………………………………………………….…..….12 B. Underground Transmission Power Lines………………………………….…..….14 C. Substations……………………………………………………………………...…...14 D. Side-By-Side Transmission Power Lines………………………………..……..….15 E. EMF Guidelines……………………………………………………………………..15 F. EMF in the Home………………………………………………………………...…16 G. EMF and Research on Health Effects……………………………………………..16 H. National Organizations...………………………………………………..……..…..20 I. International Organizations...…………………………………………………...…25 J. State Agencies…………………………………………………………………...…..31 III. GUIDELINES FROM SAFETY ORGANIZATIONS…………………………….……35 IV. STATE GUIDELINES……………………………………………………………….……37 V. WILL THE PROJECTED ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS INCREASE, DECREASE OR STAY THE SAME WITH THE SOUTHERN LOOP PROJECT?…………………..………………………………………………..…....…..39 A. Electric and Magnetic Power Frequency Fields at Annual Peak Loading At The Edge Of The Right Of Way.………………………………………….……………….………..40 B. Electric and Magnetic Power Frequency Fields at Annual Peak Loading Directly Under The Power Lines ………………………………………………...……….…………….41 C. Magnetic Power Frequency Fields at Average Loading At The Edge Of The Right Of Way.………………………………….…………………………………………….....43 2 D. Magnetic Power Frequency Fields at Average Loading Directly Under The Power Lines ………………………………………………...……………………………….….44 E. Magnetic Power Frequency Fields at Continuous Line Ampacity At The Edge Of The Right Of Way.………………………………………….…………………………………..45 F. Magnetic Power Frequency Fields at Continuous Line Ampacity Directly Under The Power Lines ………………………………………………...………………………….….46 G. Magnetic Power Frequency Fields at Identified Buildings Near the Right of Way at Annual Peak Loading……………………………………………………………………..…47 H. Summary……………………………………………………………………..……..48 VI. THE PROJECTED ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS AT THE EXISTING BUILDING IN THE RIGHT OF WAY NEAR POLE 142…..……..49 VII. ELECTROMAGNETIC INTERFERENCE AND MEDICAL DEVICES…………..50 VIII. DOES THE VELCO TESTIMONY OF PETER A. VALBERG, PH.D. CORRESPOND WITH THE CURRENT SCIENTIFIC VIEW OF HUMAN EXPOSURE TO ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS?…………………..55 IX. POLICY OF PRUDENT AVOIDANCE………………………………………….……..55 X. CONCLUSIONS FOR THE SOUTHERN LOOP PROJECT………..…………..…….57 REFERENCES……………………………………………………………………..………….59 WEBSITES…………………………………………………………………………………….63 APPENDIX A: DATA FROM VELCO……………………………………………………..65 Table 1. Proposed Electric and Magnetic Field Input Data……………………...…65 APPENDIX B…………………………………………………………………………………..67 Table 1. Magnetic Power Frequency Field Strength At Annual Peak Loading On The Edge Of The Right Of Way………………………………………………………….…...67 3 Table 2. Magnetic Power Frequency Field Strength At Annual Peak Loading Directly Under The Power Line……………………………………………………………....67 Table 3. Magnetic Power Frequency Field Strength At Average Loading On The Edge Of The Right Of Way………………………………………………………….……..…68 Table 4. Magnetic Power Frequency Field Strength At Average Loading Directly Under The Power Line………………………………………………………………………..68 Table 5. Electric Power Frequency Field Strength Directly Under The Power Line And At The Edge Of The Right Of Way………………………………………………….…69 Table 6. Magnetic Power Frequency Field Strength At Continuous Line Ampacity On The Edge Of The Right Of Way…………………………………………………….……69 Table 7. Magnetic Power Frequency Field Strength At Continuous Line Ampacity Directly Under The Power Line……………………………………………………………...70 Table 8. Distance From Edge Of Right Of Way At Which Magnetic Power Frequency Field Has Dropped To 4 MilliGauss At Annual Peak Loading….……..……...70 Table 9. Magnetic Power Frequency Field Strength At Identified Buildings Near The Right Of Way At Annual Peak Loading…………………..…….……….……………...71 Table 10. Distance From Edge Of Right Of Way At Which Magnetic Power Frequency Field Has Dropped To Less Than 2 MilliGauss At Annual Peak Loading…....73 4 I. SUMMARY The purpose of this position paper is to 1) describe the current scientific view of human health effects related to electric and magnetic power frequency fields (“EMF”); 2) analyze whether the projected EMF for the Southern Loop Project will be less, the same, or greater than the existing power lines are projected to produce; 3) analyze whether the Vermont Electric Power Company (“VELCO”) testimony corresponds with the current scientific view of human exposure to EMF; 4) provide the Vermont Department of Health’s (“VDH”) policy on prudent avoidance; 5) describe and discuss public comments posed at public hearings on the Southern Loop Project; and 6) analyze whether the Southern Loop Project specifically poses any EMF concerns from VDH’s perspective. The Southern Loop Project consists of 1) a new approximately 51 mile, 345 kilovoltage (kV) transmission line between Vernon and Cavendish to be built parallel to and within the same right of way as VELCO’s existing Vernon to Cavendish 345 kV line; 2) a new VELCO 345/115 kV Vernon substation, to be located just north of the Vermont Yankee Nuclear power Station; 3) a new 345/115/46 kV Newfane substation; 4) a new, approximately 1 mile, 345 kV transmission line loop between the new Newfane substation and the new Vernon to Cavendish 345 kV line; 5) expansion of VELCO’s Coolidge substation in Cavendish; and 6) the implementing of incremental energy efficiency to defer transmission upgrades in Southern Vermont. There are no federal standards for occupational and residential chronic exposures to EMF nor are there standards or guidelines limiting EMF fields for appliance manufacturers at this time. However, there is a significant contribution to the literature about the effects of EMF on human health which is reviewed in Sections II and VII. In this paper electric and magnetic power frequency fields refer to those fields produced by 60 or 50 Hertz power lines. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) established guidelines for acute exposure of the public to magnetic and electric power frequency fields of 833 milligauss (mG) and 4.2 kilovolts per meter (kV/m), respectively [1].1 Acute exposures refer to short term immediate effects, such as shocks caused by touching conducting objects. Chronic exposures refer to long term exposures, such as one might receive from living continuously on the edge of a power line right of way. 5 The Institute of Electrical and Electronics Engineers’ (“IEEE”) magnetic power frequency field guideline for acute exposure to the public is 9,040 mG and 5 kV for the electric power frequency field [2]. Florida has established guidelines for power lines less than 230 kV of 150 mG and 2.0 kV/m at the edge of the right-of-way, and 8.0 kV/m in the right-of-way when the power line is operating at its highest continuous current rating [3]. The Florida guidelines are designed so that the maximum electric and magnetic power frequency fields will not exceed those fields produced by power lines now in operation and are not based on health effects. New York guidelines for electric power frequency fields are limited to11.8 kV/m in the right-of-way and 1.6 kV/m at the edge of the right-of-way. The maximum magnetic power frequency field allowed by New York is 200 mG at the edge of the right-of-way. Germany (1997) adopted a national rule on EMF exposure for the general public limiting the electric power frequency field to 5 kV/m and the magnetic power frequency field to 1000 mG [4]. These fields are unlikely to be encountered in daily life. Typical magnetic power frequency fields in the home average 0.9 mG [5] and range from 0.1 to 4 mG [6] over a period of a day. Average electric power frequency fields in the home range from 0 to 0.01 kV/m [7]. For the purpose of the VDH’s review of the VELCO Southern Loop Project, the Florida and New York guidelines were chosen for comparison because they provide the strictest guidelines presently available, even though they are not health-based. When the Florida or New York guidelines were exceeded, the ICNIRP guidelines for acute exposure, which are healthbased, were compared with the projected magnetic or electric power frequency fields. In instances where the ICNIRP guidelines for electric fields are exceeded the projected electric fields are compared with the existing fields. Data was provided by VELCO for the years 2010 and 2017 for both existing and proposed power line configurations. The year 2010 is used as an estimate of the year that the Southern Loop Project will be completed. Data required for the calculations include: 1) distance of the power line from the center of the ROW, 2) maximum sag height of the power line, 3) number of conductors, 4) diameter of the conductor, 5) bundle diameter, 6) maximum line to All bracketed numbers throughout this Paper refer to the corresponding report in the References section. 1 6 ground voltage, 7) phase angle, 8) existing and projected average loading, 9) existing and projected annual peak loading, 10) existing and projected continuous line ampacity. Using these parameters and assumptions the estimated existing and projected results are maximum possible values for the electric and magnetic power frequency fields. The results of these calculations are very conservative estimates and are not “real” or measured fields. Projected annual peak loading at the edge of the right of way for the Southern Loop Project is expected to result in an increase in the magnetic power frequency field for the Vermont Yankee corridor from 11.8 mG in 2010 to 28.6 mG in 2017; the Vernon-Newfane corridor decreases from 42.5 mG in 2010 to 27.9 mG in 2017; the Newfane Divergence corridor increases from 0.8 mG in 2010 to 12.2 mG in 2017; the Newfane-Coolidge corridor decreases from 42.5 mG in 2010 to 27 mG in 2017. The average projected magnetic power frequency field along the entire Southern Loop Project corridor is approximately 23.9 mG in 2017, and ranges from 12.2 to 28.6 mG (refer to Appendix B Table 1 Columns “Existing Power Line-2010”, “Proposed Power Line-2010”, and “Proposed Power Line-2017HG”.) All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the Florida, New York and ICNIRP guidelines. Projected annual peak loading directly under the power line for the Southern Loop Project is expected to result in a decrease in the magnetic power frequency field for the Vermont Yankee corridor from 113 mG in 2010 to 84 mG in 2017; the Vernon-Newfane corridor decreases from 185 mG in 2010 to 139 mG in 2017; the Newfane Divergence corridor increases from 6.3 mG in 2010 to 91 mG in 2017; and the Newfane-Coolidge corridor decreases from 185 mG in 2010 to 134 mG in 2017. The average projected magnetic power frequency field directly under the power line for the entire Southern Loop Project corridor is approximately 112 mG in 2017, and ranges from 84 to 139 mG (Refer to Appendix B Table 2 Columns “Existing Power Line-2010”, “Proposed Power Line-2010”, and “Proposed Power Line-2017HG”.) All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the ICNIRP guidelines. Projected average loading at the edge of the right of way for the proposed Southern Loop Project is expected to result in an increase in the magnetic power frequency field for the Vermont Yankee corridor from 7.1 mG in 2010 to 17.2 mG in 2017; the Vernon-Newfane corridor decreases from 25.5 mG in 2010 to 16.7 mG in 2017; the Newfane Divergence corridor 7 increases from 0.5 mG in 2010 to 7.3 mG in 2017; the Newfane-Coolidge corridor decreases from 25.5 mG in 2010 to 16.2 mG in 2017. The average projected magnetic power frequency field along the entire Southern Loop Project corridor is approximately 14.4 mG in 2017, and ranges from 7.3 to 17.2 mG (refer to Appendix B Table 3, Columns “Existing Power Line2010”, “Proposed Power Line-2010”, and “Proposed Power Line-2017HG”.) All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the Florida, New York and ICNIRP guidelines. Projected average loading directly under the power line for the Southern Loop Project is expected to result in a decrease in the magnetic power frequency field for the Vermont Yankee corridor from 68 mG in 2010 to 50 mG in 2017; the Vernon –Newfane corridor decreases from 111 mG in 2010 to 83 mG in 2017; the Newfane Divergence corridor increases from 3.8 mG in 2010 to 55 mG in 2017; and the Newfane-Coolidge corridor decreases from 111 mG in 2010 to 80 mG in 2017. The average projected magnetic power frequency field directly under the power line for the entire Southern Loop Project corridor is approximately 67 mG in 2017, and ranges from 50 to 83 mG (refer to Appendix B Table 4, “Existing Power Line-2010”, “Proposed Power Line-2010”, and “Proposed Power Line-2017HG”.) All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the ICNIRP guidelines. Projected continuous line ampacity at the edge of the right of way for the Southern Loop Project is expected to result in an increase in the magnetic power frequency field for the Vermont Yankee corridor from 58 mG in 2010 to 122 mG in 2017; the Vernon-Newfane corridor decreases from 124 mG in 2010 to 119 mG in 2017; the Newfane Divergence corridor increases from 21 mG in 2010 to 61 mG in 2017; the Newfane-Coolidge corridor decreases from 121 mG in 2010 to 119 mG in 2017. The average projected magnetic power frequency field along the entire Southern Loop Project corridor is approximately 105 mG in 2017, and ranges from 61 to 122 mG (refer to Appendix B Table 6). All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the Florida, New York and ICNIRP guidelines. Projected continuous line ampacity directly under the power line for the Southern Loop Project is expected to result in a decrease in the magnetic power frequency field for the Vermont Yankee corridor from 331 mG in 2010 to 359 mG in 2017; the Vernon –Newfane 8 corridor increases from 542 mG in 2010 to 581 mG in 2017; the Newfane Divergence corridor increases from 92 mG in 2010 to 395 mG in 2017; and the Newfane-Coolidge corridor increases from 542 mG in 2010 to 581 mG in 2017. The average projected magnetic power frequency field directly under the power line for the entire Southern Loop Project corridor is approximately 479 mG in 2017, and ranges from 359 to 581 mG (refer to Appendix B Table 7). All of the projected magnetic power frequency fields along the entire proposed Southern Loop Project corridor, as indicated above, are well below the health based ICNIRP guidelines. In summary, the projected magnetic power frequency fields at the edge of the right of way and in the right of way are less than the Florida (150 mG), New York (200 mG), and the ICNIRP (833 mG) guidelines for public exposure. The existing and projected electric power frequency fields directly under the power lines (0.34 to 6.7 kV/m in 2010 and 6.8 to 8.5 kV/m in 2017, respectively) are approximately the same as or less than the Florida guideline of 8 kV/m and the New York guideline of 11.8 kV/m. The projected electric power frequency field directly under the power lines is approximately the same as the existing electric power frequency field along the Vermont Yankee, Vernon to Newfane and Newfane to Coolidge corridors. There is only one residence that extends into the right of way along the Newfane to Coolidge corridor (section VI). The electric power frequency field at the residence is projected to be 3.4 kV/m which is less than the ICNIRP guideline of 4.2 kV/m. In addition, shielding from the residence walls and roof will eliminate the electric power frequency field from the power lines to the inhabitants. The projected electric power frequency field for the Newfane Divergence directly under the power lines will increase from 0.34 to 8.5 kV/m, due to the addition of two 345 kV power lines and is approximately the same as the Vermont Yankee to Newfane and Newfane to Coolidge corridors. There are no residences within 300 feet of the edge of the right of way (0.02 kV/m). All existing and projected electric power frequency fields directly under the power lines are above the ICNIRP guideline of 4.2 kV/m. The ICNIRP guidelines for power frequency electric fields are based on “short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects” [1](see section II.A.). Due to conservatism in the EMF calculations, the lack of evidence of chronic adverse health effects in the scientific literature from power frequency electric fields, the lack of 9 chronic adverse health effects for use of the existing power line as of this date, the existence of only one residence in the right of way, and the ease of reducing the power frequency electric field by shielding (trees, clothing, etc.), the VDH believes that the existing and proposed power frequency electric fields will not cause chronic adverse health effects. Intermittent recreational use in the proposed power line right of way is also not expected to cause chronic adverse health effects. The existing and projected electric power frequency field at the ROW edge (0.05 to 1.6 kV/m and 0.33 to 1.6 kV/m, respectively) for the Southern Loop Project are less than the Florida, New York and ICNIRP guidelines (refer to Appendix B Table 3 Columns “Existing Power Line”, “Proposed Power Line”). This demonstrates that the existing and projected maximum electric power frequency fields at the edge of the right of way for the Southern Loop Project are well below the health based ICNIRP guideline. The Vermont Department of Health: 1) Concludes that the data in the current body of literature is insufficient to establish a direct cause and effect relationship between EMF exposure and adverse health effects; 2) Concludes that the annual peak load, average load and continuous line ampacity contributing to the electric and magnetic power frequency field strength for the proposed Southern Loop Project does not appear to be a public health hazard based on a review of the literature and on calculations with existing and proposed electric and magnetic fields; and 3) Concludes that Vermont should continue to follow the policy of prudent avoidance outlined in the Vermont Twenty Year Electric Plan (1994) [8] in order to mitigate EMF exposures. The Vermont Department of Health concludes that there are no compelling health concerns or reasons requiring modification to the Southern Loop Project. 10 II. CURRENT SCIENTIFIC VIEW OF HUMAN HEALTH EFFECTS RELATED TO ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS In this paper, electric and magnetic power frequency fields (“EMF”) refer to those fields produced by 60 hertz power lines (50 hertz power lines in Europe). The terms transmission line, transmission power line, and power line are used interchangeably. EMFs are produced by the earth, static electricity, lightning, and man-made devices. The static magnetic field around the earth is around 500 mG and is produced by electric currents flowing in the earth’s core. These static magnetic fields do not induce currents in stationary objects. However, currents may be induced in moving and rotating objects from a static magnetic field. EMFs are also produced by high voltage transmission lines, distribution lines, wiring in buildings, and many commonly used appliances. A. TRANSMISSION POWER LINES Electric power frequency fields from transmission power lines exist whenever voltage is present and whether a current is flowing or not. Electric power frequency fields have very little ability to penetrate through the skin into the human body and are not strong enough to heat tissue or stimulate nerves. At very high field strengths, electric power frequency fields can induce currents in the body. Strong electric power frequency fields can also result in perceptual effects due to the alternating electric charge induced on the surface of the body causing, for example, body hair to vibrate. A person standing directly under a transmission line may feel a slight shock when touching something that conducts electricity. These sensations only occur at close range to the transmission line because electric power frequency fields decrease quickly with distance and are easily shielded or weakened by building, trees and other objects that conduct electricity. 11 There are no permanent health effects known to exist from prompt, acute or chronic exposure to electric power frequency fields. [36] Corona discharge occurs when the electric power frequency field strength of a conductor reaches values where the surrounding air can no longer act as an insulator and is sufficient to cause air ionization. Transmission lines are designed not to go into corona under normal operating conditions. However, nicks, scrapes, insects, raindrops, etc., on the conductor surface can increase local field strength sufficiently to produce corona discharges. Phenomena associated with corona discharge includes audible noise, radio, television and telephone interference, and production of ozone, nitrous oxides and air ions which decrease with increasing distance away from the power line. These phenomena are intermittent and for a well-constructed line they occur only during and immediately after periods of rain, snow, or fog. There are no permanent health effects known to exist from corona discharge. Ionization of particles from corona discharges tends to make the particles more likely to adhere to any nearby surface. This process can cause changes in the concentration and deposition of particles (radon decay products and other environmental pollutants) in the vicinity of power lines. The U.K. Advisory Group on Non-Ionizing Radiation concluded that whether any such enhanced deposition will increase human exposure in a way that will result in adverse health effects to the general public has not been demonstrated. There are no permanent health effects known to exist from ionization of particles from corona discharges. In nature, the ratio of positive and negative ions is approximately equal. Negative ions predominate in areas that are traditionally regarded as therapeutic in nature – spas, springs, waterfalls, mountaintops and the seashore. Human activity rarely creates negative ions. Negative ions are used to control pain with burn patients, favorably alter circadian rhythms, improve psychomotor performance, and give a general sense of well being and energy. Some reasons for this are thought to be that negative ions limit serotonin levels in the brain and increase activity in the endocrine system, circulation and metabolism. There are no adverse health effects from negative ions. Positive ions have adverse effects on humans, ranging from respiratory difficulties to migraines, irritability, depression and reduced psychomotor performance. Positive ions produce increased serotonin levels. Most authorities agree that ions affect our capacity to absorb and utilize oxygen. Positive ions can produce symptoms similar to anoxia. The production of 12 positive ions is negligible for power frequency transmission lines and their concentration decreases with increasing distance away from the power line. This phenomenon is intermittent and for a well constructed power line they occur only during and immediately after periods of rain, snow or fog. There are no permanent health effects known to exist from positive ions. Ozone, singlet oxygen, nitric oxide, nitrogen dioxide, nitrous acid and peroxyacycle nitrates are among the electrochemical oxidants formed from oxygen and nitrogen in the vicinity of a high voltage power line. Electrochemical oxidants are unstable and highly reactive. Their destructive capabilities range from decreasing plant growth and combining with water to form acid rain, to causing respiratory problems and having carcinogenic properties. Their concentrations decrease with increasing distance away from the power line and for a wellconstructed power line they occur only during and immediately after periods of rain, snow or fog. Studies to date indicate that contributions to environmental ozone levels are negligible. There are no permanent health effects known to exist from these electrochemical oxidants. B. UNDERGROUND TRANSMISSION POWER LINES Generally, the electric and magnetic fields from a buried power line are less than those from an overhead power line. However, directly over the buried power line the magnetic power frequency field is higher than that from the overhead power, because it is so much closer to the measurement point (one meter above the ground). The electric and magnetic fields from a buried power line decrease more rapidly away from it than from an overhead power line. One study indicates the magnetic power frequency field directly over a buried 400 kV power line is 1000 mG. At 60 feet away the magnetic power frequency field decreases to 10 to 20 mG. C. SUBSTATIONS Electric and magnetic fields around the outside of a substation come from the power lines that enter and leave the substation, and decreases rapidly with distance away from the substation. Usually beyond the substation fence the electric and magnetic fields produced by the substation are not distinguishable from background levels [21, 29]. Transformers in the substation have high, localized magnetic fields that are not detectable beyond the substation fence [29]. 13 Overhead or pole mounted transformers also have localized electric and magnetic fields which are dominated by the overhead power lines coming in and going out of the transformer [29]. Electric fields are typically shielded by metallic casings and enclosure walls [27]. D. SIDE-BY-SIDE TRANSMISSION POWER LINES Magnetic fields may decrease when there are two side-by-side power lines because the conductor phases are oriented so that the magnetic power frequency fields will cancel each other out. The width of the magnetic field will increase, but as one moves away from the power lines the magnetic field will decrease rapidly to background. E. EMF GUIDELINES At this time there are no federal standards for occupational and residential chronic exposures to EMF, nor are there standards or guidelines limiting EMF fields for appliance manufacturers. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) established guidelines for acute exposure of the public to magnetic and electric power frequency fields of 833 milligauss (mG) and 4.2 kilovolts per meter (kV/m), respectively [1]. Acute exposures refer to short term immediate effects, such as shocks caused by touching conducting objects. Chronic exposures refer to long term exposures, such as one might receive from living continuously on the edge of a power line right of way. The Institute of Electrical and Electronics Engineers’ (“IEEE”) magnetic power frequency field guideline for acute exposure to the public is 9,040 mG and 5 kV/m for the electric power frequency field [2]. Florida has established guidelines for power lines less than 230 kV of 150 mG and 2.0 kV/m at the edge of the right-of-way, and 8.0 kV/m in the right-of-way when the power line is operating at its highest continuous current rating [3]. The Florida guidelines are designed so that 14 the maximum electric and magnetic power frequency fields will not exceed those fields produced by power lines now in operation and are not based on health effects. New York guidelines for electric power frequency fields are limited to11.8 kV/m in the right-of-way and 1.6 kV/m at the edge of the right-of-way. The maximum magnetic power frequency field allowed by New York is 200 mG at the edge of the right-of-way when the power line is operating at its highest continuous current rating. Germany (1997) adopted a national rule on EMF exposure for the general public limiting the electric power frequency field to 5 kV/m and the magnetic power frequency field to 1000 mG [4]. These fields are unlikely to be encountered in daily life. F. EMF IN THE HOME EMFs are also produced by distribution lines, wiring in buildings, and many commonly used appliances. Magnetic power frequency fields close to electrical appliances are often much stronger than those from other sources, including power lines. Exposures vary widely from refrigerators (up to 10 mG at 6 inches) to can openers (up to 1500 mG at 6 inches) [5]. Typical magnetic power frequency fields in the home average 0.9 mG [5] and range from 0.1 to 4 mG [6] over a period of a day. Average electric power frequency fields in the home range from 0 to 0.01 kV/m [7]. G. EMF AND RESEARCH ON HEALTH EFFECTS The relationship between EMF and health effects has been studied extensively since the late 1970’s when there appeared to be a weak association between increased rates of childhood leukemia and proximity to transmission lines [9]. Current research is qualitatively superior to those early studies, though a uniform exposure metric has not been determined because there is no biological data that can be attributed to a specific measure of the magnetic power frequency field (e.g., time-averaged mG, cumulative mG, peak mG, time spent in a field above a certain strength). The criteria scientists use to evaluate laboratory and epidemiologic studies of EMF and health effects are [5, 9]: 15 1) How strong is the association between EMF and a health effect? A strong association is defined as one with a relative risk (RR) of equal to or greater than 5 (e.g. smoking RR = 10 to 30). A relative risk of less than 3 is a weak association. An RR of less than 1.5 is essentially meaningless unless it is supported by other data. The RR for most electric and magnetic power frequency fields is less than 2, and is therefore classified as a weak association (the RR’s have not increased as the quality of the studies has increased). 2) How consistent are the studies of associations between exposure to EMF and a health effect? Studies show decreases, no increases and some increases in the incidence of some types of cancers and some types of exposure metrics. Many studies are internally inconsistent (e.g. there is a positive association with calculated retrospective fields and negative association with measured EMFs). 3) Is there a dose response relationship between EMF and health effects? There are no published studies indicating a dose response relationship (i.e. as dose increases there is a greater risk of an adverse health effect) between measured EMFs and cancer rates. The lack of a clear relationship between an exposure metric and increased health effect incidence is a major reason scientists are skeptical about the significance of much of the EMF epidemiology. Meta-analyses (combination of many epidemiological studies to attempt to calculate a summary risk estimate) have shown that there is a lack of adequate exposure information and clear dose response patterns to conclusively state that EMF causes cancer. 4) Is there laboratory evidence of an association between EMF and health effects? There is little evidence of the effect of EMF on cells, tissues or animals that point toward their being a cause of cancer. Existing laboratory studies have not yet been able to establish a biological mechanism for how EMF may cause cancer. There is evidence that normal daily exposure to EMF is not carcinogenic. 5) Are there plausible biological mechanisms suggesting an association between exposure to EMF and health effects? Laboratory studies do not suggest an association between EMF and cancer. However, biological effects have been observed and reproduced in experiments using very high magnetic power frequency 16 fields above 5,000 mG. Convincing evidence for EMF causing health effects is only available for magnetic field densities greater than approximately 1,000 mG [10]. Validation of studies of positive associations between EMF and health effects suffer from: 1) no attempt to replicate single positive studies; 2) lack of publication of studies; 3) replication of a positive study failed; 4) variation in exposure metrics and the lack of adequate detail in an original study to make an attempt at replication impossible; and 5) the use of a wide variety of biological systems, endpoints, and exposure conditions [9]. The energy of the electric and magnetic power frequency fields from high voltage power lines (60 Hz) is insufficient to damage DNA (genetic material) in cells directly and to cause thermal effects in biological systems [4, 9]. Electrical currents generated in the human body by changes in a electric and magnetic power frequency field of less than 1 kV/m or 500 mG (AC current in the power lines) are much smaller than those produced naturally by the brain, nerves and heart [5, 9]. Electric power frequency fields may produce biological effects without damaging DNA by exerting forces on charged and uncharged molecules or cellular structures, however, the field strength applied to the biological system in order to produce these effects generally far exceeds those in typical environmental exposure conditions [9]. Magnetic power frequency fields can exert forces on cellular structures, but since biological materials are mostly nonmagnetic these forces are usually very weak [9]. Most evidence suggests that there is no consistent evidence that EMFs are genotoxins (agents capable of initiating damage to DNA), or epigenetic agents (agents contributing to development of cancer or promoters) [9]. There are several factors that result in false associations between EMF and health effects in some studies: 1) inappropriate controls (e.g. laboratory studies were not performed under controlled conditions, or there was difficulty of obtaining a control group identical to the exposed group); 2) inadequate dose assessment (e.g. reliability of the exposure information and what exposure metric of the EMF is involved); 3) confounders (e.g. traffic density and socioeconomic class); 4) publication bias (e.g. unrepresentative subsets of the actual study are reported, or the likelihood that positive studies are more likely to be published); and 5) multiple comparison artifacts (e.g. studies using multiple exposure metrics and/or multiple health effect endpoints) [9]. Studies that have initially shown a positive association between EMF and health effects have not been successfully replicated in many cases. 17 Electric power frequency fields may be sensed as mild shocks when touching a conducting material while standing directly under a high voltage power line. Electric power frequency fields, from high voltage power lines, are easily shielded by conducting objects (houses, trees, and human skin) [9]. Electric power frequency fields do not change with increasing current through the power lines. Many studies show that the electric power frequency fields around power lines do not affect human health [9]. The easiest method of reducing exposure to either the magnetic or electric power frequency field is by increasing your distance away from the power lines. The magnetic and electric power frequency field strength decreases as the inverse of the square of the distance. In other words, if a person moves from 2 feet to 4 feet away from a source then the field strength decreases to ¼ of the original field strength. Spending less time near the source also will decrease the cumulative exposure. However, exposure to EMFs has not been proven to be absolutely safe due to the small proportion of studies that have shown a small increase in health effects. This increase in health effects may be restricted to very small subgroups and for those occupationally exposed to high EMF fields. Some laboratory studies suggest that there may be “windows” for health effects, which may be observed at some frequencies and intensities but not at others. Also, it is not known if continuous exposure to or repeated entrance and exiting of a given field intensity causes a biological effect. Many laboratory studies (in vivo and in vitro) test at magnetic power frequency field strengths far above those which are normally encountered in the daily environment (e.g. up to 20,000 mG [9]). Because of all this uncertainty, it is difficult to determine a “safe” distance from any magnetic power frequency field source or a “safe” exposure. At this point in time, only comparisons can be made from one set of field conditions to another. For example, the average magnetic power frequency field common in households and offices (primarily from the wiring and outside power lines) is 0.9 mG [5] varying from 0.1 to 4 mG [6]. Average electric power frequency fields in the home range from 0 to 0.01 kV/m [7]. There are no known definitive studies indicating that EMFs cause adverse health effects. However, with advances in science and technology, it could be possible that EMFs may in the future be shown to cause health concerns. Related issues that are brought up are: 1) identifying the type of scientific studies should be done, and 2) prioritizing these studies. 18 Based on the current level of science and technology, adverse health effects are not an issue for electric and magnetic power frequency fields projected for the Southern Loop Project. A new project with higher voltage power lines, the addition of power lines in the same corridor, new technologies or future findings on health effects from EMF would require the reanalysis of the exposure to these power lines. H. NATIONAL ORGANIZATIONS Excerpts from a number of scientific reviews of the literature and research on electrical and magnetic power frequency fields from the national organizations, upon which we relied in the development of this position paper regarding electrical and magnetic power frequency fields and the Southern Loop Project, are listed below in reverse chronological order. Most scientific reviews conclude that there is insufficient evidence to prove that EMFs from high voltage power lines cause human health effects, though some show a very weak association. Electric Power Research Institute (EPRI) (2005)[47]: “Although epidemiologic studies show that magnetic field exposure at or above 3 to 4 milligauss may increase the risk of childhood leukemia, it cannot be concluded that a cause-and-effect relationship exists. The reported association between magnetic fields and childhood leukemia is weak (children with exposure above 3 milligauss might have roughly double the risk of unexposed children). For such weak epidemiologic associations, supporting data from laboratory studies are usually critical for establishing a causal link. For example, exposures or agents that are known to cause cancers in humans (such as ionizing radiation and benzene) also cause cancers in laboratory rodents. Such laboratory evidence should also be supported by an understanding of the mechanisms by which the exposures or agents interact with biological tissue. For magnetic fields, lifetime studies of rodents almost all report no adverse effects, and scientists have not identified a mechanism by which the low-level fields found in homes can possibly interact with tissue. In the absence of supporting laboratory and mechanistic evidence, scientists are investigating the possibility that the epidemiologic results have been generated by inadvertent errors in study design or that magnetic fields occur along with another exposure that could plausibly cause leukemia. 19 American Cancer Society (ACS), What are the Risk Factors for Acute Myeloid Leukemia (AML)? (2005)[45]: “There is some question about electromagnetic field (EMF) exposure (such as that occurring near very high-voltage power lines) as a potential risk factor for developing leukemia. Most studies published so far suggest either no increased risk or a very slightly increased risk. Clearly, most cases of leukemia are not related to EMF exposure.” American Cancer Society (ACS), Unproven Risks (2002)[46]: “Non-ionizing radiation. Electromagnetic radiation at frequencies below ionizing and ultraviolet levels has not been proven to cause cancer. Some studies suggest an association with cancer, but most of the now-extensive research in this area does not.” American Cancer Society (ACS) (2002) [11]: “There is conflicting evidence about electromagnetic field (EMF) exposure (such as that occurring near very high-voltage power lines) as a potential risk factor for developing leukemia. The NCI [National Cancer Institute] has several large studies going on now to look into this question. Most studies published so far suggest either no increased risk or a very slightly increase risk. Clearly, most cases of leukemia are not related to EMF exposure.” Institute of Electrical and Electronics Engineers (IEEE), Committee on Man and Radiation (COMAR) (2002) [2]: “Protection is to be afforded to individuals in the general population by limiting maximum permissible exposure (MPE) to magnetic field levels of 9,040 mG at 60-Hz power-line frequencies.” Institute of Electrical and Electronics Engineers (IEEE), Committee on Man and Radiation (COMAR) (2000) [13]: “After examination of relevant research reports published during the last ten years, COMAR [Committee on Man and Radiation] concludes that it is highly unlikely that health problems can be associated with average 24-hour field exposure to power frequency magnetic fields of less than 1 microT (10 mG).” National Institute of Environmental Health Sciences (NIEHS) (1999)[10] : 20 “The scientific evidence suggesting that ELF-EMF [Extremely Low Frequency Electric and Magnetic Fields] exposures pose any health risk is weak. The strongest evidence for health effects comes from associations observed in human populations with two forms of cancer: childhood leukemia and chronic lymphocytic leukemia in occupationally exposed adults. While the support from individual studies is weak, the epidemiological studies demonstrate, for some methods of measuring exposure, a fairly consistent pattern of a small, increased risk with increasing exposure that is somewhat weaker for chronic lymphocytic leukemia than for childhood leukemia. In contrast, the mechanistic studies and the animal toxicology literature fail to demonstrate any consistent pattern across studies although sporadic findings of biological effects (including increased cancers in animals) have been reported. No indication of increased leukemias in experimental animals has been observed…. The NIEHS concludes that ELF-EMF exposure cannot be recognized as entirely safe because of weak scientific evidence that exposure may pose a leukemia hazard. In our opinion, this finding is insufficient to warrant aggressive regulatory concern. However, because virtually everyone in the United States uses electricity and therefore is routinely exposed to ELF-EMF, passive regulatory action is warranted such as a continued emphasis on educating both the public and the regulated community on means aimed at reducing exposure. The NIEHS does not believe that other cancers or non-cancer health outcomes provide sufficient evidence of a risk to currently warrant concern.” “The association between exposure to magnetic fields and a variety of other cancers has also been considered in occupational settings. Included are brain cancers, breast cancers (in both males and females), testicular cancers, cancers in offspring of workers, lymphoma, multiple myeloma, melanoma, non-Hodgkin’s lymphoma, thyroid cancers and many other. Some evidence exists for an association between brain cancers and exposure to ELF-EMF and between female breast cancers and ELF-EMF exposure; however, the studies evaluating these associations are inconsistent and have limits to their interpretation making them inadequate for supporting or refuting an effect. In the remaining cases, the evidence supporting an association is negative or too weak to warrant concern…. Limited data are available on risks of male and female breast cancer associated with residential exposure to ELF-EMF. A small, non-significant association between use of electric blankets and the risk for breast cancer was observed in one, large U.S. study but not in another. Both found no evidence for an association with duration of exposure. Three studies, using exposure measured by calculated fields, identified an association between exposure to magnetic fields and the risk of breast cancer. These same scientists also looked at exposure to ELF-EMF and cancers of the central nervous system (such as brain cancers); no associations were found.” “The association between occupational exposure to ELF-EMF (Extremely Low Frequency – Electromagnetic Fields) and Alzheimer’s disease was considered in five studies. All five studies showed 21 increases in one or more exposure groups with four studies showing statistically significant increase and one showing non-statistically significant increases. All of these studies suffer from design limitations that make it inappropriate to use them for addressing a causal association between ELF-EMF exposure and Alzheimer’s disease. Two of these are based on diagnoses from death certificates (Alzheimer’s disease is not consistently noted on death certificates). Two studies used different groups of cases and controls; some of the control groups included persons with other types of dementia, and proxy information was used to define the exposure of cases. The one remaining study was evaluated using data for twins and also suffered many limitations. These data are inadequate for interpreting the possibility of an association. The association between exposure to magnetic fields and amyotrophic lateral sclerosis was assessed in three studies. One study showed an increase risk in the highest exposure group and the other two studies were negative. Adequate adjustment could not be made for known risk factors (electric shocks or a family history of amyotrophic lateral sclerosis) making these studies difficult to interpret…” “Two occupational studies assessed possible adverse cardiovascular outcomes that may result from exposure to magnetic fields. In the first study, a significant decrease in risk using a broadly defined cardiovascular grouping was observed. In the second, data from five utilities were examined. This study was motivated a priori by a biological hypothesis based on the results of human clinical studies on heart rate variability for increased numbers of deaths due to arrhythmia and acute myocardial infarct. Significant exposure-dependent associations were reported. Lacking additional epidemiological studies to collaborate these results, these data are inconclusive regarding an association between cardiovascular disease and exposure to ELF-EMF.” “The NIEHS suggests that the level and strength of evidence supporting ELF-EMF exposure as a human health hazard are insufficient to warrant aggressive regulatory actions; thus, we do not recommend actions such as stringent standards on electric appliances and a national program to bury all transmission and distribution lines. Instead, the evidence suggests passive measures such as a continued emphasis on educating both the public and the regulated community on means aimed at reducing exposures. NIEHS suggests that the power industry continue its current practice of siting power lines to reduce exposure and continue to explore ways to reduce the creation of magnetic fields around transmission and distribution lines without creating new hazards. We also encourage technologies that lower exposure from neighborhood distribution lines provided that they do not increase other risks, such as those from accidental electrocution or fire…. In summary, the NIEHS believes that there is weak evidence for possible health effects from ELF-EMF exposures, and until stronger evidence changes this opinion, inexpensive and safe reduction in exposure should be encouraged.” 22 U. S. National Academy of Science (NAS) (1996) [14]: “Based on a comprehensive evaluation of published studies relating to the effects of powerfrequency electric and magnetic fields on cells, tissues, and organisms (including humans), the conclusion of the committee is that the current body of evidence does not show that exposure to these fields presents a human-health hazard. Specifically, no conclusive and consistent evidence shows that exposure to residential electric and magnetic fields produce cancer, adverse neurobehavioral effects, or reproductive and developmental effects. Oak Ridge Associated Universities (ORAU) Panel for the Committee on Interagency Radiation Research and Policy Coordination (CIRRPC) Health Effects of Low-Frequency Electric and Magnetic Fields (1992) [15]: “This review indicates that there is no convincing evidence in the published literature to support the contention that exposures to extremely low-frequency electric and magnetic fields (ELF-EMF) generated by sources such as household appliances, video display terminals, and local power lines are demonstrable health hazards. Epidemiologic findings of an association between electric and magnetic fields and childhood leukemia or other childhood or adult cancers are inconsistent and inconclusive. No plausible biological mechanism is presented that would explain causality. Neither is there conclusive evidence that these fields initiate cancer, promote cancer or influence tumor progression. Likewise, there is no convincing evidence to support suggestions that electric and magnetic fields result in birth defects or other reproductive problems. Furthermore, any neurobehavioral effects are likely to be temporary and do not appear to have health consequences.” U.S. Environmental Protection Agency (EPA) Evaluation of the Potential Carcinogenicity of Electromagnetic Fields, External Review Draft, October 1990 [16]: “In evaluating the potential for carcinogenicity of chemical agents, the U.S. EPA has developed an approach that attempts to integrate all of the available information into a summary classification of the weight of evidence that the agent is carcinogenic in humans. At this time, such a characterization regarding the link between cancer and exposure to EMF fields is not appropriate because the basic nature of the interaction between EM fields and biological processes leading to cancer is not understood. … With our current understanding, we can identify 60 Hz magnetic fields from power lines and perhaps other sources in the home as a possible, but not proven, cause of cancer in humans.” 23 I. INTERNATIONAL ORGANIZATIONS Excerpts from a number of scientific reviews of the literature and research on electrical and magnetic power frequency fields from international organizations, upon which we relied in the development of this position paper regarding electrical and magnetic power frequency fields and the Southern Loop Project, are listed below in reverse chronological order. World Health Organization Environmental Health Criteria 238, Extremely Low Frequency Fields (2007) [50]: “Scientific evidence suggesting that everyday, chronic low-intensity (above 0.3-0.4 µT [3-4 mG]) power-frequency magnetic field exposure poses a health risk is based on epidemiological studies demonstrating a consistent pattern of increased risk for childhood leukaemia. Uncertainties in the hazard assessment include the role that control selection bias and exposure misclassification might have on the observed relationship between magnetic fields and childhood leukaemia. In addition, virtually all of the laboratory evidence and the mechanistic evidence fail to support a relationship between low-level ELF magnetic fields and changes in biological function or disease status. Thus, on balance, the evidence is not strong enough to be considered causal, but sufficiently strong to remain a concern. “Although a causal relationship between magnetic field exposure and childhood leukaemia has not been established, the possible public health impact has been calculated assuming causality in order to provide a potentially useful input into policy. However, these calculations are highly dependent on the exposure distributions and other assumptions, and are therefore very imprecise. Assuming that the association is causal, the number of cases of childhood leukaemia worldwide that might be attributable to exposure can be estimated to range from 100 to 2400 cases per year. However, this represents 0.2 to 4.9% of the total annual incidence of leukaemia cases, estimated to be 49000 worldwide in 2000. Thus, in a global context, the impact on public health, if any, would be limited and uncertain. “A number of other diseases have been investigated for possible association with ELF magnetic field exposure. These include cancers in both children and adults, depression, suicide, reproductive 24 dysfunction, developmental disorder, immunological modifications and neurological disease. The scientific evidence supporting a linkage between ELF magnetic fields and any of these diseases is much weaker than for childhood leukaemia and in some cases (for example, cardiovascular disease or breast cancer) the evidence is sufficient to give confidence that magnetic fields do not cause the disease… Implementing … suitable precautionary procedures to reduce exposure is reasonable and warranted. However, electric power brings obvious health, social and economic benefits, and precautionary approaches should not compromise these benefits. Furthermore, given both the weakness of the evidence for a link between exposure to ELF magnetic fields and childhood leukaemia, and the limited impact on public health if there is a link, the benefits of exposure reduction on health are unclear. Thus the costs of precautionary measure should be very low.” World Health Organization Fact Sheet No 322 (WHO) (June 2007)[51] “Much of the scientific research examining long-term risks from ELF magnetic field exposure has focused on childhood leukaemia. In 2002, IARC published a monograph classifying ELF magnetic fields as “possibly carcinogenic to humans”….This classification was based on pooled analyses of epidemiological studies demonstrating a consistent pattern of a two-fold increase in childhood leukaemia associated with average exposure to residential power-frequency magnetic filed above 0.3 to 0.4 µT [3 to 4 mG]. The Task Group concluded that additional studies since then do not alter the status of this classification. However, the epidemiological evidence is weakened by methodological problems, such as potential selection bias. In addition, there are no accepted biophysical mechanisms that would suggest that low-level exposures are involved in cancer development. Thus, if there were any effects from exposure to these low-level fields, it would have to be through a biological mechanism that is as yet unknown. Additionally, animal studies have been largely negative. Thus, on balance, the evidence related to childhood leukaemia is not strong enough to be considered causal.” International Commission on Non-Ionizing Radiation Protection (ICNIRP) (2005) [52] “In the development of its protection system and in particular in the definition of exposure guidelines, ICNIRP has adopted a general approach, taking into consideration different population groups and different exposure conditions. Assuming a worst-case scenario for each of the known physical, biological and physiological factors that influence health effects, ICNIRP aims at developing conservative guidelines, introducing de facto substantial reduction factors that add to those explicitly defined, to account for scientific uncertainties. Therefore, in the opinion of ICNIRP, there is neither need nor any justification for a specific approach to the protection of children or other special groups of the population. 25 Consideration of the peculiar characteristics of different groups enters spontaneously into each step of the process of development of the guidelines. U.K. National Radiation Protection Board (NRPB) (2004) [48]: “Power frequency fields – In the context of possible adverse health effects from EMFs, the conclusions of published expert scientific reviews have identified only one reasonably consistent epidemiological finding of an adverse health outcome associated with exposure to EMFs at levels lower than exposure guidelines: that is an apparent increased risk of childhood leukaemia with time-weighted exposure to power frequency magnetic fields above 0.4 µT (4 mG). It is the view of NRPB that the epidemiological evidence is currently not strong enough to justify a firm conclusion that such fields cause leukaemia in children…The view of NRPB is that it is important to consider the possible need for further precautionary measures in respect of exposure of children to power frequency magnetic fields.” U.K. National Radiation Protection Board (NRPB) (2004) [49]: “In the view of NRPB, the epidemiological evidence that time-weighted average exposure to power frequency magnetic fields above 0.4 µT (4 mG) is associated with a small absolute raised risk of leukaemia in children is, at present, an observation for which there is no sound scientific explanation. There is no clear evidence of a carcinogenic effect of ELF EMFs in adults and no plausible biological explanation of the association can be obtained from experiments with animals or from cellular and molecular studies. Alternative explanations for this epidemiological association are possible: for example, potential bias in the selection of control children with whom leukaemia cases were compared in some studies and chance variations resulting from small numbers of individuals affected. Thus any judgements developed on the assumption that the association is causal would be subject to a very high level of uncertainty… NRPB concludes that the results of epidemiological studies, taken individually or as collectively reviewed by expert groups, cannot currently be used as a basis for restrictions on exposure to EMFs… In addition, a number of studies suggest that ELF EMFs, particularly magnetic fields in excess of about 100 µT (1,000 mG), may induce a variety of subtle responses in biological systems, as well as those attributable to the effects of either surface charge or the induced electric field. However, the pattern of reported responses is diffuse and inconsistent. Furthermore, many tend to be small in magnitude and often fail to be replicated. Overall, none is considered sufficient to provide a coherent framework on which to base restrictions for human exposures… It is concluded that currently the results of these studies on EMFs and health, taken individually or as collectively reviewed by expert groups, are insufficient either to make a conclusive judgment on 26 causality or to quantify appropriate exposure restriction. This conclusion is in accord with the manner in which other expert bodies – for example, ICNIRP (1998) – have developed EMF exposure guidelines. However, such studies taken together with people’s concerns provide a basis of considering the possible need for further precautionary measures in addition to the application of quantitative restrictions on exposure to EMFs… There remain concerns about possible effects of exposure of children to power frequency magnetic fields. The view of NRPB is that it is important to consider the possible need for further precautionary measures in respect of exposure of children to power frequency magnetic fields… The government should consider the need for further precautionary measures in respect of exposure of people to EMFs. In doing so, it should note that the overall evidence for adverse effects of EMFs on health at levels of exposure normally experienced by the general public is weak. The least weak evidence is for the exposure of children to power frequency magnetic fields and childhood leukaemia.” International Agency for Research on Cancer (IARC) (2002) [17]: “The association between childhood leukaemia and high levels of magnetic fields is unlikely to be due to chance, but it may be affected by bias. In particular, selection bias may account for part of the association.” “…there is limited evidence in humans for the carcinogenicity of extremely low-frequency magnetic fields in relation to childhood leukaemia. There is inadequate evidence in humans for the carcinogenicity of extremely low-frequency magnetic fields in relation to all other cancers.” International Agency for Research on Cancer (IARC) (2001) [18]: “In June 2001, an expert scientific working group of IARC reviewed studies related to the carcinogenicity of static and ELF electric and magnetic fields. Using the standard IARC classification that weighs human, animal and laboratory evidence, ELF magnetic fields were classified as possibly carcinogenic to humans based on epidemiological studies of childhood leukaemia. Evidence for all other cancers in children and adults, as well as other types of exposures (i.e. static fields and ELF electric fields) was considered not classifiable either due to insufficient or inconsistent scientific information. ‘Possibly carcinogenic to humans’ is a classification used to denote an agent for which there is limited evidence of carcinogenicity in humans and less than sufficient evidence for carcinogenicity in experimental animals. This classification is the weakest of three categories (‘is carcinogenic to humans’, ‘probably carcinogenic to humans’ and ‘possibly carcinogenic to humans’) used by IARC to classify potential carcinogens based on published scientific evidence.” 27 “Group 2B: The agent (mixture) is possibly carcinogenic to humans. The exposure circumstance entails exposures that are possibly carcinogenic to humans. This category is used for agents, mixtures and exposure circumstances for which there is limited evidence of carcinogenicity in humans and less than sufficient evidence of carcinogenicity in experimental animals. It may also be used when there is inadequate evidence of carcinogenicity in humans but there is sufficient evidence of carcinogenicity in experimental animals. In some instances, an agent, mixture or exposure circumstance for which there is inadequate evidence of carcinogenicity in humans but limited evidence of carcinogenicity in experimental animals together with supporting evidence from other relevant data may be placed in this group.” [Note the IARC lists 236 different materials classified as “possible carcinogens”. Also included as possible carcinogens are coffee, pickled vegetables, gasoline engine exhaust, welding fumes, and chloroform.] World Health Organization (WHO Fact Sheet 263, 2001) [19]: “It is especially difficult to suggest protective measures for ELF fields because we do not know what field characteristic might be involved in the development of childhood leukaemia and therefore need to be reduced, or even if it is the ELF magnetic fields that are responsible for this effect. One approach is to have voluntary policies that aim to cost-effectively reduce exposure to ELF fields.” International Commission on Non-Ionizing Radiation Protection (ICNIRP) (2001) [20]: “In the absence of evidence from cellular or animal studies, and given the methodological uncertainties and in many cases inconsistencies of the existing epidemiologic literature, there is no chronic disease outcome for which an etiological relation to EMF exposure can be regarded as established.” U.K. National Radiation Protection Board (NRPB) (2001) [21]: “Laboratory experiments have provided no good evidence that extremely low frequency electromagnetic fields are capable of producing cancer, nor do human epidemiological studies suggest that they cause cancer in general. There is, however, some epidemiologic evidence that prolonged exposure to higher levels of power frequency magnetic fields is associated with a small risk of leukaemia in children. … In the absence of clear evidence of a carcinogenic effect in adults, or of plausible 28 explanation from experiments on animals or isolated cells, the epidemiological evidence is currently not strong enough to justify a firm conclusion that such fields cause leukaemia in children. Unless however, further research indicates that the finding is due to chance or some currently unrecognized artifact, the possibility remains that intense and prolonged exposures to magnetic fields can increase the risk of leukaemia in children.” Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) (2001) [53]: “With regard to extremely low frequency electromagnetic fields, the CSTEE reached the following conclusions: Combined analyses of the epidemiological studies on the association between exposure to ELF and childhood leukaemia have strengthened the evidence of an association. However, given some inconsistencies in exposure measurements and the absence of other criteria commonly used in assessing causality (particularly a plausible explanation of underlying biological mechanisms, …), the association does not meet adequate criteria for being considered causal. Thus the overall evidence for 50/60 Hz magnetic fields to produce childhood leukaemia must be regarded as being limited. The effect, if any seems to be limited to exposures above 0.4 µT [4 mG]. In European countries, the proportion of children exposed to such levels is less than 1%. Assuming that the risk is doubled among the exposed, in the general population this would roughly correspond to an excess incidence of less than 1% of childhood leukemia. To put this in context, in European countries, the incidence of leukaemia is around 45 per million children (age 0-14) per year… There is no convincing suggestion of any other carcinogenic effect of ELF on either children or adults. Current information on this respect does not provide clues for reconsidering exposure limits. Reports on possibly hypersensitive individuals require confirmation and do not provide a basis for proposing changes in the exposure limits.” Committee of the Health Council of the Netherlands (2000) [54]: “The committee arrives at the conclusion that it has not been demonstrated that exposure to electric or magnetic fields originating from the electricity transmission and distribution system at field strengths below the limits of exposure that have been established for short-term effects, induces any kind of disease or abnormality. It feels that, on the basis of the current scientific understanding described in 29 this report, there is no reason to recommend measures to limit living near overhead power lines or working under conditions involving ELF EM field exposure that is increased, but not exceeding the exposure limits. The committee does recommend to continue following the scientific developments in this field.” World Health Organization (WHO Fact Sheet 205, 1998) [22]: “Consultation with local authorities and the public in siting new power lines: Obviously power lines must be sited to provide power to consumers. Despite the fact that ELF field levels around transmission and distribution lines are not considered a health risk, siting decisions are often required to take into account aesthetics and public sensibilities. Open communication and discussion between the electric power utility and the public during the planning stages can help create public understanding and greater acceptance of a new facility.” J. STATE AGENCIES Excerpts from a number of scientific reviews of the literature and research on electrical and magnetic power frequency fields from state agencies, upon which we relied in the development of this position paper regarding electrical and magnetic power frequency fields and the Southern Loop Project, are listed below in reverse chronological order Vermont Public Service Board (Docket No. 6860, January 28, 2005)[33] A Certificate of Public Good issued by the Vermont PSB for the Northwest Vermont Reliability Project states: “The Board finds that the electric and magnetic fields (“EMF”) that will result from the proposed Project are very unlikely to have an undue adverse effect on public health. It is not possible to state unequivocally that there will be no adverse health effects. Some epidemiological studies have found a weak correlation between EMF and childhood leukemia, despite the fact that no mechanism of causation has been found….Based upon the recommendations of the NIEHS, the Board finds that the policy of prudent avoidance, which we adopt, does not require a generic policy of placing transmission lines underground to avoid EMF exposure….We will not require VELCO to place underground any portion of the project based upon the health effects of EMF….In addition, we note that the conclusions of VELCO’s EMF witness and the Vermont Department of Health appear to be consistent with the conclusions of the major health agencies who have rigorously studied this issue.” 30 Minnesota Department of Health (2002) [4]: “The Minnesota Department of Health concludes that the current body of evidence is insufficient to establish a cause and effect relationship between EMF and adverse health effects. However, as with many other environmental health issues, the possibility of a health risk from EMF cannot be dismissed. Construction of new generation and transmission facilities to meet increasing electrical needs in the State is likely to increase public exposure to EMF. Based on these considerations, the Work Group considers it prudent public health policy to take a prudent avoidance approach to mitigating EMF exposures.” Florida Department of Environmental Protection (2001) [23]: “We seem to be approaching a time when some aspects of EMF exposure may be deemed a slight risk, but we are still lacking knowledge of EMF impact mechanisms and adequate scientific proof to allow a valid estimate of risk to the public and the knowledge to set a regulatory standard to manage the risk.” California Department of Health Services (draft 2001) [24]: “To one degree or another all three of the DHS scientists are inclined to believe that EMFs can cause some degree of increased risk of childhood leukemia, adult brain cancer, Lou Gehrig’s Disease, and miscarriage. They strongly believe that EMFs do not increase the risk of birth defects, or low birth weight. They strongly believe that EMFs are not universal carcinogens, since there are a number of cancer types that are not associated with EMF exposure. To one degree or another they are inclined to believe that EMFs do not cause an increased risk of breast cancer heart disease, Alzheimer’s Disease, depression, or symptoms attributed by some to a sensitivity to EMFs. However, all three scientists had judgments that were close to the dividing line between believing and not believing that EMFs cause some degree of increased risk of suicide, or for adult leukemia, two of the scientists are close to the dividing line between believing or not believing and one was prone to believe that EMFs cause some degree of increased risk.” Virginia Department of Health (2000) [25]: “Based on the review and analysis of the exhaustive literature review and other research projects completed under the EMF-RAPID program, the Virginia Department of Health is of the opinion that there is no conclusive and convincing evidence that exposure to extremely low frequency EMF emanated from nearby high voltage transmission lines is causally associated with an increased incidence of cancer or other detrimental health effects in humans.” 31 Connecticut Department of Environmental Protection and Department of Health Services (1994) [26]: “No definitive cause and effect relationship between exposure to EMF and an increase in health risk has been established.” Maryland Department of Natural Resources (1994) [27]: “It is impossible to predict effects (or lack of effects) with any certainty, and it is not clear which biological effects observed in cellular or animal studies (if any) could have significant human health implications. … There is no definitive indication that EMF exposure does or does not cause adverse health effects.” Oregon Department of Energy (1993) [28]: “Some early epidemiological studies have suggested an association between EMF exposure and increased risk for diseases such as leukemia in children, brain cancer, male breast cancer, lymphoma, miscarriages and birth defects. However, research to date has not shown that EMF exposure causes these diseases.” Texas Public Utility Commission Health Effects of Exposure to Power-Frequency Electric and Magnetic Fields (1992) [29]: “The Committee believes that, based on its evaluation of the existing EMF research, the evidence at this time is insufficient to conclude that exposure to EMF from electric power transmission lines poses an imminent or significant public health risk. … The Committee concludes that at present there is insufficient evidence regarding human health effects of EMF to provide the basis for a health-based standard.” Illinois Department of Public Health and Environmental Protection Agency Possible Health Effects of Extremely Low Frequency Electric and Magnetic Field Exposure: A Review (1992) [30]: “Whether these observed ELF bioeffects cause adverse health effects in humans and animals is not yet clear. No scientific consensus has been reached on this issue. Without sufficient information, health risks from exposure to these fields cannot be properly determined. … Because some studies have 32 identified positive associations between ELF field exposure and certain adverse health effects, while other studies have not, the data obtained to date are far from conclusive.” 33 III. GUIDELINES FROM SAFETY ORGANIZATIONS International Commission on Non-Ionizing Radiation Protection (ICNIRP) (1998) [1]: General Public (60 Hz) Magnetic Power Frequency Field: 833 mG Electric Power Frequency Field: 4.2 kV/m Occupational Exposure (60 Hz) Magnetic Power Frequency Field: 4,200 mG Electric Power Frequency Field: 8.3 kV/m “Induction of cancer from long-term EMF exposure was not considered to be established, and so these guidelines are based on short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects, and elevated tissue temperatures resulting from absorption of energy during exposure to EMF.” Institute of Electrical and Electronics Engineers (IEEE) (Standard C95.6 General Public) (2002) [2]: Magnetic Power Frequency Field: 9,040 mG Electric Power Frequency Field: 5.0 kV/m American Conference of Governmental Industrial Hygienists (ACGIH) (2007)(60 Hz Occupational Exposure) [12]: Magnetic Power Frequency Field: 10,000 mG Electric Power Frequency Field: 25 kV/m “Prudence dictates the use of protective devices (e.g., suits, gloves, and insulation) in all fields exceeding 15 kV/m.” “For workers wearing cardiac pacemakers,…It is recommended that, lacking specific information on electromagnetic interference from the manufacturer, the exposure of persons wearing cardiac pacemakers or similar medical electronic devices be maintained at or below 0.1 mT (1,000 mG) at power frequencies.” 34 “For workers with cardiac pacemakers,…It is recommended that, lacking specific information on electromagnetic interference from the manufacturer, the exposure of pacemaker and medical electronic device wearers should be maintained at or below 1 kV/m.” World Health Organization (WHO Fact Sheet N182, 1998) [31]: “Safety Standards: In order to ensure that human exposure to EMF should not have adverse health effects, that man-made EMF generating devices are safe and their use does not electrically interfere with other devices, various international guidelines and standards are adopted. Such standards are developed following reviews of all the scientific literature by groups of scientists who look for evidence of consistently reproduced effects with adverse health consequences. These groups then recommend guidelines for standards for action by the appropriate national and international bodies. A nongovernmental organization, formally recognised by WHO in the field of NIR [non-ionizing radiation] protection, is the International Commission on Non-Ionizing Radiation Protection (ICNIRP). ICNIRP has established international guidelines on human exposure limits for all electromagnetic fields, including ultraviolet (UV) radiation, visible light and infrared radiation, as well as RF fields and microwaves… Even high intensity NIR cannot cause ionization in the biological system. NIR, however, have been shown to produce other biological effects, for instance, by heating, altering normal chemical reactions or inducing electrical currents in tissues.” 35 IV. STATE GUIDELINES The bolded text in this section was added for ease of reference. The following chart is a summary of state guidelines for EMF from Electric and Magnetic Fields Associated with the Use of Electric Power Question & Answers, June 2002 [7]: State Transmission Line Standards and Guidelines Magnetic Electric Field Field On R.O.W.* Edge R.O.W. On R.O.W. Edge R.O.W. State Florida Minnesota Montana New Jersey New York Oregon 8 kV/m(a) 10 kV/m(b) 8 kV/m 7 kV/m(d) -----11.8 11 7 9 kV/m kV/m(f) kV/m(d) kV/m 2 kV/m ------ ------ 150 mG(a) 200 mG(b) 250 mG(c) (max load) (max load) (max load) 200 mG (max load) -----1 3 1.6 kV/m(e) kV/m kV/m ------ ------ ------ ------ *R.O.W. = right-of-way (or in the Florida standard, certain additional areas adjoining the right-of way). kV/m = kilovolt per meter. One kilovolt = 1,000 volts. (a) For lines of 69-230 kV. (b) For 500 kV lines. (c) For 500 kV lines on certain existing R.O.W. (d) Maximum for highway crossings. (e) May be waived by the landowner. (f) Maximum for private road crossings. Florida 62-814.450 (2001) [23]: “(3) New transmission lines and substations. (a) The maximum electric field at the edge of the transmission line ROW or at the property boundary of a new substation shall not exceed 2.00 kV/m. (b) The maximum electric field on the ROW of a 230 kV or smaller transmission line shall not exceed 8 kV/m. (c) The maximum electric field on the ROW of a 500 kV transmission line shall not exceed 10 kV/m. 36 (d) The maximum magnetic field at the edge of a 230 kV or smaller transmission line ROW or at the property boundary of a new substation serving such lines shall not exceed 150 milliGauss. (e) The maximum magnetic field at the edge of the transmission line ROW for a 500 kV line or at the property boundary of a new substation serving a 500 kV line shall not exceed 200 milliGauss, except for double circuit 500 kV lines to be constructed on ROWs existing on March 21, 1989, as identified below where the limit will be 250 milliGauss. California (1999) [32]: “The California Department of Education enacted regulations that require minimum distances between a new school and the edge of a transmission “right-of-way,” or the area immediately surrounding lines that utility companies need to access the lines for maintenance and repairs. The setback distances are 100 feet for 50-133 kV lines, 150 feet for 220-230 kV lines, and 350 feet for 500-550 kV lines. These distances were not based on specific biological evidence, but on the known fact that the strength of electric fields from powerlines drops to near background levels at the specified distances, given that no major sources are present.” 37 V. WILL THE PROJECTED ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS INCREASE, DECREASE OR STAY THE SAME WITH THE PROPOSED SOUTHERN LOOP PROJECT? The VDH relied on data and EMF modeling provided by VELCO as listed in Appendix A. Data required for the calculations include: 1) distance of the power line from the center of the right of way (ROW), 2) sag height of the power line, 3) number of conductors, 4) diameter of the conductor, 5) bundle diameter, 6) line to ground voltage, 7) phase angle, 8) existing and projected average loading, 9) existing and projected annual peak loading, 10) existing and projected continuous line ampacity. The calculations use the maximum power line kV, the maximum sag (minimum allowed height above the ground) and maximum line to ground voltage. The transmission line is modeled as a horizontal line at the estimated sag height. Annual peak loading or peak loading refers to the maximum winter peak demand and represents the highest point in amperage of consumer consumption of electricity in a year Average loading refers to the average amount of amperage used on a daily basis by consumers and is approximately 60% of the annual peak load. Continuous line ampacity refers to the maximum amperage the power line can conduct without breaking down. This is a situation that is unlikely to ever occur, but is used in this report as a worst case scenario. The ROW of the Proposed Southern Loop Project ranges from 200 feet to 250 feet. The distance of the edge of the ROW from the “center line” varies depending on the corridor. The proposed eastern and western edges of the ROW for the Vermont Yankee corridor are both 100 feet from the “center line”. The proposed eastern and western edges of the ROW for the VernonNewfane and Newfane-Coolidge corridors are 75 and 175 feet from the “center line”, respectively. The proposed eastern and western edges of the ROW for the Newfane Divergence are 80 and 130 feet from the “center line”, respectively. Cross-sections for each corridor were provided by Petitioners Exhibit WM-4 and WM-5 (William F. McNamara). Using these parameters and assumptions the estimated existing and projected results are maximum possible values for the electric and magnetic power frequency fields. The results of these calculations are very conservative estimates and are not “real” or measured fields. 38 A. ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS AT ANNUAL PEAK LOADING AT THE EDGE OF THE RIGHT OF WAY (APPENDIX B, TABLES 1 & 5) The magnetic power frequency field along the Vermont Yankee corridor is projected to increase at the edge of the ROW for annual peak loading from 11.8 mG in 2010 to 28.6 mG in 2017. The electric power frequency field is projected to increase from 0.24 kV/m in 2010 to 0.34 kV/m in 2017 and will not change as the current changes or with time The magnetic power frequency field along the Vernon-Newfane corridor is projected to decrease at the edge of the ROW for annual peak loading from 42.5 mG in 2010 to 27.9 mG in 2017. The electric power frequency field is projected to remain the same at 1.6 kV/m and will not change as the current changes or with time. The magnetic power frequency field along the Newfane Divergence corridor is projected to increase at the edge of the ROW for annual peak loading from 0.8 mG in 2010 to 12.2 mG in 2017. The electric power frequency field is projected to increase from 0.04 kV/m in 2010 to 0.33 kV/m in 2017 and will not change as the current changes or with time. The magnetic power frequency field along the Newfane-Coolidge corridor is projected to decrease at the edge of the ROW for annual peak loading from 42.5 mG in 2010 to 27 mG in 2017. The electric power frequency field is projected to remain the same at 1.6 kV/m and will not change as the current changes or with time. CONCLUSION The magnetic power frequency field for annual peak loading at the edge of the ROW is projected to decrease with the Southern Loop Project between 2010 and 2017 for the Vernon-Newfane and Newfane-Coolidge corridors and to increase for the Vermont Yankee and Newfane Divergence corridors. The projected magnetic power frequency field for annual peak loading at the edge of the ROW ranges from 12.2 to 28.6 mG and the average is approximately 23.9 mG in 2017. The magnetic power frequency fields at the edge of the ROW for annual peak loading with the Southern Loop Project are projected to be on the order of 6 times less 39 than the Florida guideline of 150 mG, 8 times less than the New York guideline of 200 mG and 35 times less than the ICNIRP guideline of 833 mG for public exposure. The electric power frequency fields at the edge of the ROW for annual peak loading with the Southern Loop Project are projected to be 1.2 times less than the Florida guideline of 2 kV/m, the same as the New York guideline of 1.6 kV/m and 3 times less than the ICNIRP guideline of 4.2 kV/m. This demonstrates that the projected magnetic and electric power frequency fields for peak loading at the edge of the right of way for the Southern Loop Project are well below the health-based ICNIRP guidelines. B. ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS AT ANNUAL PEAK LOADING DIRECTLY UNDER THE POWER LINES (APPENDIX B, TABLES 2 & 5) The existing power lines for the Vermont Yankee, Vernon-Newfane, and NewfaneCoolidge corridors are presently operating at electric power frequency fields of 6.4, 6.7 and 6.7 kV/m, respectively, which are greater than the ICNIRP guideline of 4.2 kV/m. The magnetic power frequency field along the Vermont Yankee corridor is projected to decrease for annual peak loading directly under the power lines from 113 mG in 2010 to 84 mG in 2017. The electric power frequency field is projected to increase minimally from 6.4 kV/m to 7 kV/m and will not change as the current changes or with time. The magnetic power frequency field along the Vernon-Newfane corridor is projected to decrease for annual peak loading directly under the power lines from 185 mG in 2010 to 139 mG in 2017. The electric power frequency field is projected to increase minimally from 6.7 kV/m to 6.8 kV/m and will not change as the current changes or with time. The magnetic power frequency field along the Newfane Divergence corridor is projected to increase for annual peak loading directly under the power lines from 6.3 mG in 2010 to 91 mG in 2017. The electric power frequency field is projected to increase from 0.34 kV/m to 8.5 kV/m and will not change as the current changes or with time. The large increases in magnetic and electric power frequency fields are due to the addition of two 345 kV power lines in the Newfane Divergence. The projected increases are similar to the rest of the Southern Loop corridor. 40 The magnetic power frequency field along the Newfane-Coolidge corridor is projected to decrease for annual peak loading directly under the power lines from 185 mG in 2010 to 134 mG in 2017. The electric power frequency field is projected to increase minimally from 6.7 kV/m to 6.8 kV/m and will not change as the current changes or with time. CONCLUSION The magnetic power frequency field for annual peak loading directly under the power line is projected to decrease with the Southern Loop Project between 2010 and 2017. The projected magnetic power frequency field for annual peak loading directly under the power line from Vermont Yankee to Coolidge ranges from 84 mG to 139 mG in 2017. The addition of two 345 kV power lines in the Newfane Divergence will allow more current to flow increasing the magnetic power frequency field to 91 mG in 2017, which is similar to the rest of the Southern Loop corridor. The magnetic power frequency fields with the Southern Loop Project for annual peak loading directly under the power lines are projected to be on the order of 7 times less than the ICNIRP guideline of 833 mG for public exposure. Comparison is not made with the Florida and New York guidelines since they are defined only for the edge of the right of way. This demonstrates that the projected magnetic power frequency fields for annual peak loading directly under the power line for the Southern Loop Project is well below the health-based ICNIRP guidelines. The projected electric power frequency fields directly under the power line are approximately the same as the existing electric power frequency fields. The electric power frequency fields directly under the power line for annual peak loading with the Southern Loop Project are projected to be approximately 1.2 times less than the Florida guideline of 8 kV/m and 1.7 times less than the New York guideline of 11.8 kV/m. However, the electric power frequency fields are 1.6 times greater than the ICNIRP guideline of 4.2 kV/m. The ICNIRP guidelines for power frequency electric fields are based on “short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects” [1](see section II.A.). Due to conservatism in the EMF calculations, the lack of evidence of chronic adverse health effects in the scientific 41 literature from power frequency electric fields, the lack of chronic adverse health effects from use of the existing power line as of this date, the existence of only one residence in the right of way, and the ease of reducing the power frequency electric field by shielding (trees, clothing, etc.), the VDH believes that the existing and proposed electric power frequency fields will not cause chronic adverse health effects. C. MAGNETIC POWER FREQUENCY FIELDS AT AVERAGE LOADING AT THE EDGE OF THE RIGHT OF WAY (APPENDIX B, TABLE 3) The magnetic power frequency field along the Vermont Yankee corridor is projected to increase at the edge of the ROW for average loading from 7.1 mG in 2010 to 17.2 mG in 2017. The magnetic power frequency field along the Vernon-Newfane corridor is projected to decrease at the edge of the ROW for average loading from 25.5 mG in 2010 to 16.7 mG in 2017. The magnetic power frequency field along the Newfane Divergence corridor is projected to increase at the edge of the ROW for average loading from 0.5 mG in 2010 to 7.3 mG in 2017. The magnetic power frequency field along the Newfane-Coolidge corridor is projected to decrease at the edge of the ROW for average loading from 25.5 mG in 2010 to 16.2 mG in 2017. CONCLUSION The magnetic power frequency field for average loading at the edge of the ROW is projected to decrease with the Southern Loop Project between 2010 and 2017 for the Vernon-Newfane and Newfane-Coolidge corridors and to increase for the Vermont Yankee and Newfane Divergence corridors. The projected magnetic power frequency field for average loading at the edge of the ROW ranges from 7.3 to 17.2 mG and the average is approximately 14.4 mG in 2017 The magnetic power frequency fields at the edge of the ROW for average loading with the Southern Loop Project are projected to be on the order of 10 times less than the Florida guideline of 150 mG, 14 times less than the New York guideline of 200 mG and 58 times less than the ICNIRP guideline of 833 mG for public exposure. This demonstrates that the projected magnetic power frequency fields for average loading at the edge of the 42 right of way for the Southern Loop Project are well below the health-based ICNIRP guidelines. D. MAGNETIC POWER FREQUENCY FIELDS AT AVERAGE LOADING DIRECTLY UNDER THE POWER LINES (APPENDIX B, TABLE 4) The magnetic power frequency field along the Vermont Yankee corridor is projected to decrease for average loading directly under the power lines from 68 mG in 2010 to 50 mG in 2017. The magnetic power frequency field along the Vernon-Newfane corridor is projected to decrease for average loading directly under the power lines from 111 mG in 2010 to 83 mG in 2017. The magnetic power frequency field along the Newfane Divergence corridor is projected to increase for average loading directly under the power lines from 3.8 mG in 2010 to 55 mG in 2017. The magnetic power frequency field along the Newfane-Coolidge corridor is projected to decrease for average loading directly under the power lines from 111 mG in 2010 to 80 mG in 2017. CONCLUSION The magnetic power frequency field for average loading directly under the power line is projected to decrease with the Southern Loop Project between 2010 and 2017. The projected magnetic power frequency field for average loading directly under the power line from Vermont Yankee to Coolidge ranges from 50 mG to 83 mG in 2017. The addition of two 345 kV power lines in the Newfane Divergence will allow more current to flow increasing the magnetic power frequency field to 55 mG in 2017, which is similar to the rest of the Southern Loop corridor. The projected magnetic power frequency field for average loading directly under the power line ranges from 50 to 83 mG and the average is approximately 67 mG in 2017. 43 The magnetic power frequency fields with the Southern Loop Project for average loading directly under the power lines are projected to be on the order of 12 times less than the ICNIRP guideline of 833 mG for public exposure. Comparison is not made with the Florida and New York guidelines since they are defined only for the edge of the right of way. This demonstrates that the projected magnetic power frequency fields for average loading directly under the power line for the Southern Loop Project is well below the health-based ICNIRP guidelines. E. MAGNETIC POWER FREQUENCY FIELDS AT CONTINUOUS LINE AMPACITY AT THE EDGE OF THE RIGHT OF WAY (APPENDIX B, TABLE 6) The magnetic power frequency field along the Vermont Yankee corridor is projected to increase at the edge of the ROW for continuous line ampacity from 58 mG to 122 mG for the Southern Loop Project. The magnetic power frequency field along the Vernon-Newfane corridor is projected to decrease at the edge of the ROW for continuous line ampacity from 124 mG to 119 mG for the Southern Loop Project . The magnetic power frequency field along the Newfane Divergence corridor is projected to increase at the edge of the ROW for continuous line ampacity from 21 mG to 61 mG for the Southern Loop Project . The magnetic power frequency field along the Newfane-Coolidge corridor is projected to decrease at the edge of the ROW for continuous line ampacity from 124 mG to 119 mG for the Southern Loop Project . CONCLUSION The magnetic power frequency field for continuous line ampacity at the edge of the ROW is projected to decrease with the Southern Loop Project for the Vernon-Newfane and Newfane-Coolidge corridors and to increase for the Vermont Yankee and Newfane Divergence corridors. The addition of two 345 kV power lines in the Newfane Divergence will allow more current to flow increasing the magnetic power frequency field to 61 mG in 44 2017, which is similar to the rest of the Southern Loop corridor. The projected magnetic power frequency field for continuous line ampacity at the edge of the ROW ranges from 61 to 122 mG and the average is approximately 105 mG. The magnetic power frequency fields at the edge of the ROW for continuous line ampacity with the Southern Loop Project are projected to be on the order of 1.4 times less than the Florida guideline of 150 mG, .9 times less than the New York guideline of 200 mG and 8 times less than the ICNIRP guideline of 833 mG for public exposure. This demonstrates that the projected magnetic power frequency fields for continuous line ampacity at the edge of the right of way for the Southern Loop Project are well below the health-based ICNIRP guidelines. F. MAGNETIC POWER FREQUENCY FIELDS AT CONTINUOUS LINE AMPACITY DIRECTLY UNDER THE POWER LINES (APPENDIX B, TABLE 7) The magnetic power frequency field along the Vermont Yankee corridor is projected to increase for continuous line ampacity directly under the power lines from 331 mG to 359 mG for the Southern Loop Project. The magnetic power frequency field along the Vernon-Newfane corridor is projected to increase for continuous line ampacity directly under the power lines from 542 mG to 581 mG for the Southern Loop Project. The magnetic power frequency field along the Newfane Divergence corridor is projected to increase for continuous line ampacity directly under the power lines from 92 mG to 395 mG for the Southern Loop Project. The magnetic power frequency field along the Newfane-Coolidge corridor is projected to increase for continuous line ampacity directly under the power lines from 542 mG to 581 mG for the Southern Loop Project. CONCLUSION The magnetic power frequency field for continuous line ampacity directly under the power line is projected to increase with the Southern Loop Project. The projected 45 magnetic power frequency field for continuous line ampacity directly under the power line from Vermont Yankee to Coolidge ranges from 359 mG to 581 mG . The addition of two 345 kV power lines in the Newfane Divergence will allow more current to flow increasing the magnetic power frequency field to 395 mG, which is similar to the rest of the Southern Loop corridor. The average is approximately 479 mG. The magnetic power frequency fields with the Southern Loop Project for continuous line ampacity directly under the power lines are projected to be on the order of 1.7 times less than the ICNIRP guideline of 833 mG for public exposure. Comparison is not made with the Florida and New York guidelines since they are defined only for the edge of the right of way. This demonstrates that the projected magnetic power frequency fields for continuous line ampacity directly under the power line for the Southern Loop Project is well below the health-based ICNIRP guidelines. G. MAGNETIC POWER FREQUENCY FIELDS AT IDENTIFIED BUILDINGS NEAR THE RIGHT OF WAY AT ANNUAL PEAK LOADING (APPENDIX B, TABLES 9 & 10) Aerial photographs provided in Exhibit WM-7 (William F. McNamara) were used to identify possible locations of buildings near the Southern Loop Project. Some of the locations identified may not represent real buildings due to the lack of resolution of these aerial photographs. It is also possible that there are some buildings that are obscured by the vegetation. A total of 42 buildings were identified with projected magnetic power frequency fields at annual peak loading of greater than 2 mG for the existing power line structures in 2017. The magnetic power frequency fields at annual peak loading for these buildings ranges from 2.1 mG to 27 mG, with an average of 6.4 mG. The projected magnetic power frequency fields at annual peak loading for these buildings are approximately 23, 31 and 130 times less than the Florida, New York and ICNIRP guidelines, respectively, for public exposure. A total of 35 buildings were identified with projected magnetic power frequency fields of greater than 2 mG for the proposed Southern Loop Project in 2017 at annual peak loading. The magnetic power frequency fields at annual peak loading for these buildings ranges from 2.1 mG to 55 mG, with an average of 8.1 mG. The projected magnetic power frequency fields for 46 these buildings at annual peak loading are approximately 18, 25 and 100 times less than the Florida, New York and ICNIRP guidelines, respectively, for public exposure. The projected magnetic power frequency fields for 31 of these buildings will decrease by approximately 50% or stay the same with the Southern Loop Project in 2017. The projected magnetic power frequency fields for the Southern Loop Project for 11 buildings in 2017 will increase from 1.3 to 5 times the existing power line structure in 2010. H. SUMMARY The projected magnetic power frequency fields with the Southern Loop Project at the edge and in the ROW, at peak loading, average loading, and at continuous line ampacity are less than the health-based ICNIRP guideline of 833 mG. The projected electric power frequency fields with the Southern Loop Project at the edge of the right of way are less than the Florida guideline of 2 kV/m, the New York guideline of 1.6 kV/m, and the ICNIRP guideline of 4.2 kV/m. The projected electric power frequency fields in the ROW are approximately the same as the Florida guideline of 8 kV/m, less than the New York guideline of 11.8 kV/m, but greater than the ICNIRP guideline of 4.2 kV/m. The ICNIRP guidelines for power frequency electric fields are based on “short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects” [1](see section II.A.). Due to conservatism in the EMF calculations, the lack of evidence of chronic adverse health effects in the scientific literature from power frequency electric fields, the lack of chronic adverse health effects for use of the existing power line as of this date, the existence of only one residence in the right of way, and the ease of reducing the power frequency electric field by shielding (trees, clothing, etc.), the VDH believes that the existing and proposed power frequency electric fields will not cause chronic adverse health effects. 47 VI. THE PROJECTED ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS AT THE EXISTING BUILDING IN THE RIGHT OF WAY NEAR POLE 142 The existing building near pole 142 lies in the Southern Loop right of way. It extends into the right of way by approximately 30 feet from the west. The magnetic power frequency field for annual peak loading will increase from 11 mG in 2010 to 38 mG in 2010 and the electric power frequency field will increase from 0.30 kV/m in 2010 to 3.41 kV/m in 2010, upon construction of the Southern Loop. These increases are due primarily to the addition of the new 345 kV power line on the western side of the right of way and take into account the closest edge of the porch to the power lines and high winds which may blow the power lines closer to the building. The projected magnetic power frequency field is 4 times less than the Florida guideline at the right of way (150 mG), 5 times less than the New York guideline at the right of way (200 mG) and 22 times less than the ICNIRP guideline (833 mG). The projected electric power frequency field is slightly higher than the Florida guideline at the edge of the right of way (2 kV/m), 3 times less than the New York guideline in the right of way (11.8 kV/m) and 1.2 times less than the ICNIRP guideline (4.2 kV/m). This demonstrates that the projected electric and magnetic power frequency fields at the existing building near pole 142 are well below the healthbased ICNIRP guidelines. The magnetic power frequency field for average loading at the existing structure will increase from 6.6 mG to 23 mG with construction of the Southern Loop in 2010, and is 7 times less than the Florida guideline (150 mG), 8 time less than the New York guideline (200 mG) and 36 times less than the ICNIRP guideline (833 mG). The magnetic power frequency field for continuous line ampacity will increase from 34 mG in to 303 mG in 2010 upon construction of the Southern Loop, and is 2.7 times less than the ICNIRP guideline (833 mG). 48 VII. ELECTROMAGNETIC INTERFERENCE AND MEDICAL DEVICES The American Conference of Governmental Industrial Hygienists (“ACGIH”) is the only organization that has issued guidelines for the exposure to EMF by people wearing medical devices. Specifically, the ACGIH guidelines refer only to “occupational” workers, such as electrical line workers, phone line workers, power station operators, welders, electricians, and electrical engineers. Occupational exposures to workers wearing cardiac pacemakers and medical electronic devices should not be exposed to: 1) magnetic power frequency fields exceeding 1,000 mG, and 2) electric power frequency fields exceeding 1 kV/m. Excerpts from the literature include: “The overall incidence of interaction by a magnetic field was low in patients tested with a wide variety of conventionally programmed pacemaker models. A magnetic field pulsed at power frequency can cause a mode switch and pacing inhibition in patients with devices programmed in the unipolar sensing configuration. The risk of interference appears to be negligible in patients with bipolar sensing programming.” [55] “Numerically estimated electromagnetic interference (EMI) levels under the worst case scenarios are about 40 microT (400 mG) for atrial electrodes, and 140 microT (1400 mG) for ventricular electrodes. These methods could also be applied to studying EMI with other implanted devices such as cardiac defibrillators.” [56] “The interference threshold of cardiac pacemakers depends in a complex way on a number of different factors such as: electromagnetic immunity and adjustment of the pacemaker, the composition of the applied low-frequency fields (only electric or magnetic fields or combinations of both), their frequencies and modulations, the type of pacemaker system (bipolar, unipolar) and its location in the body, as well as the body size and orientation in the field, and last but not least, certain physiological conditions of the patient (e.g. inhalation, exhalation).” [34] “…it is possible under worst-case conditions but unlikely under practice-relevant conditions that an implanted cardiac pacemaker is disturbed by present electric 50 Hz fields beneath high voltage 49 overhead lines.”[35, 50 Hz fields are used in Europe and are essentially the same as 60 Hz fields in the United States.] “Use of bipolar mode confers a high degree of protection from extraneous electrical interference, but in unipolar mode pacemakers may be inhibited by small amounts of corporeal current, potentially encountered in every day life.”[36] “Under certain circumstances, power-frequency electric and magnetic fields can interfere with implanted electronic medical devices… …For the most part, these pacemaker and defibrillator anomalies are reversible, with the devices returning to normal operation upon removal of the electrical interference. Depending on manufacturer and design, the magnetic field threshold for pacemaker interference (including the possibility of inappropriate pacing) is in the range of 2 to 12 G, and the electric field threshold is about1.5 kV/m for some of the newer and more sensitive dual-chamber units, and above 2 kV/m for current or older ventricular units. …The ACGIH guidelines appear to be adequately protective of individuals who wear pacemakers. As well as can be determined, no pacemaker or defibrillator interference has been documented at those levels.”[37] “Medical devices can usually be made much less susceptible to EMI if various considerations are incorporated during the initial design of the device. Shielding the electronics so that they are completely encased in an electrically-conductive enclosure can make medical devices highly immune to EM. Special filters are needed to keep EM voltages from being conducted through the shield from external input or output leads to the device…However, it is difficult to make filters that are effective at low frequencies while not compromising a medical device’s performance and safety requirements (maximum allowable leakage current from the lead to the case). In addition to hardware, well-designed software in these devices can recognize and minimize the effects of EMI. …In perspective, the number of EMI incidents is very small even considering the vast amount of under-reporting that exists…”[38] “A dedicated exposure system generated a 50-Hz frequency and maximum 100 microT (1000 mG) flux density, while the electrical field was kept at values on the order of 0.10 V/m…The overall incidence of interaction by a magnetic field was low in patients tested with a wide variety of 50 conventionally programmed pacemaker models…The risk of interference appears negligible in patients with bipolar sensing programming.”[39] “Many factors influence EMI including those which the patient can regulate (e.g., distance from and duration of exposure) and some the patient cannot control (e.g., intensity of the EMI field, signal frequency).”[40] “Exposure was done to moderate (1.2-1.7 kV/m) and strong (7.0-8.0 kV/m) electric fields, which correspond to the immediate vicinity of 110 and 400 kV power lines, respectively…The results confirm that the programmed sensitivity level and the lead configuration markedly influence pacemakers’ vulnerability to EMI. Bipolar sensing mode is rather safe in the presence of EMI, which is encountered in public environments. The programmable features of today’s pacemakers permit individualized, less stringent safety measure to avoid electromagnetic hazards.”[41] “Recommendation for patients implanted with pacemakers of ICDs Common household equipment – No special precautions for pacemaker and ICD patients in the use of microwaves or other common household equipment such as televisions, radios, toasters, and electric blankets.”[42] [No mention is made of avoiding power lines]. “Avoid high intensity electromagnetic fields. Large TV or radio transmitting towers and transmission power lines carrying more than 100,000 volts are likely to interfere with your defibrillator. Areas for the general public are safe, however, avoid areas that have restricted access: Broadcasting antennas of AM, FM, shortwave radio, and TV stations. Power plants, large generators, transmission lines, and transmission buildings. Sometimes public walkways are underneath transmission lines. Avoid using a public walkway if there are overhead transmission lines. Transmission lines are different from the distribution power lines that bring electricity to your home. Transmission power lines transmit power to local power plants and usually have tall supporting towers with large electrical insulators. Transmission power lines can affect how pacemakers and defibrillators work. 51 Distribution power lines supply power to homes and businesses. Distribution power lines by themselves usually do not affect how a defibrillator or pacemaker works. However, sometimes transmission power lines are next to distribution power lines. When both kinds of power lines are together, they can affect how a pacemaker or defibrillator works.” [43] “Avoid high intensity electromagnetic fields. Large TV or radio transmitting towers and power lines carrying more than 100,000 volts are likely to interfere with your pacemaker. Areas for the general public are safe, however, avoid areas that have restricted access, such as: Broadcasting antennas of AM, FM, shortwave radio, and TV stations Power plants, large generators, transmission lines, transmission buildings Sometimes public walkways are underneath transmission lines. Avoid extended time in using a public walkway if there are overhead transmission lines. Transmission power lines are different from the distribution power lines that bring electricity to your home. Transmission power lines transmit power to local power plants and usually have tall supporting towers with large electrical insulators. Transmission power lines can affect how pacemakers and defibrillators work. Distribution power lines supply power to homes and businesses. Distribution power lines by themselves usually do not affect how a defibrillator or pacemaker works. However, sometimes transmission power lines are next to distribution power lines. When both kinds of power lines are together, they can affect how a pacemaker or defibrillator works.”[44] Examination of the U.S. Food and Drug Administration MedWatch [54] and MAUDE [55] databases and the National Library of Medicine [56], as of March 2008, did not identify any safety alerts, advisories, notices or adverse events identifying power line frequency EMF as a cause of medical device malfunction. The projected maximum magnetic power frequency fields under the power lines for annual peak loading in 2017 with the Southern Loop Project will range from and 84 to 139 mG. These fields are based on calculations using the annual peak load, the maximum power line voltage, and the minimum allowed height above the ground. The magnetic power frequency 52 field directly under the power line, under these conditions, is projected to be approximately 7 to 12 times less than the ACGIH guideline of 1000 mG for occupational workers. The projected maximum electric power frequency fields under the power lines for annual peak loading in 2017 with the Southern Loop Project will range from 6.8 to 8.5 kV/m. These fields are based on calculations using the annual peak load, the maximum power line voltage, and the minimum allowed height above the ground. The electric power frequency field directly under the power line, under these conditions, is projected to be 6 to 8 times higher than the ACGIH guideline of 1 kV/m. The projected maximum electric power frequency field at the edge of the right of way will range from 0.33 to 1.6 kV/m which is approximately the same as the existing structures (0.04 to 1.6 kV/m) and slightly higher than the ACGIH guideline. In summary, the VDH believes the projected electric and magnetic power frequency fields for the Southern Loop Project at the edge and in the ROW are not likely to interfere with medical devices worn by the public because: 1) the conditions used in the calculations are unlikely to occur or are infrequent in real life; 2) new medical devices (e.g. bipolar sensing pacemakers) are EMI (electromagnetic interference) resistant; 3) the lack of evidence of adverse health effects with medical devices in the scientific literature from power frequency electric fields; 4) the lack of adverse health effects with medical devices for use of the existing power line as of this date; and 5) the ease of reducing the power frequency electric field by shielding. 53 VIII. DOES THE VELCO TESTIMONY OF PETER A. VALBERG, PH.D. CORRESPOND WITH THE CURRENT SCIENTIFIC VIEW OF HUMAN EXPOSURE TO ELECTRIC AND MAGNETIC POWER FREQUENCY FIELDS? The testimony provided by VELCO on the Southern Loop Project (Prefiled Testimony of Peter Alexis Valberg, Ph.D. on Behalf of Petitioners, November 8, 2007, Docket No. 7373) and “Update on Scientific Research Regarding Potential Health Effects of Power-Line Electric and Magnetic Fields (EMF), (Gradient Corporation, September 21, 2007) correspond with the current scientific view of human exposure to EMF. [57,58] IX. POLICY OF PRUDENT AVOIDANCE The Vermont Department of Health concludes that we should continue to employ the policy of prudent avoidance as described in the Vermont Department of Public Service’s Vermont Twenty Year Electric Plan (1994). The policy of prudent avoidance is described in that document as follows: “In developing an EMF policy, a number of considerations should be weighed. On one hand, there is no scientific consensus on magnetic fields and human health at this time. Also, the best evidence to date indicates that, at worst, the relative risk of magnetic fields compared to the myriad of other risks faced by society is most likely small. On the other hand, evidence does exist which points toward the possibility of some risk associated with magnetic fields and human health. Given the present uncertainties about EMF and human health, Vermont’s policy should strike a reasonable balance between avoiding potential harm and the attendant costs and risks. To take absolutely no action at this time is not commensurate with the evidence that some risk may exist. Similarly, adopting aggressive measures would most likely be costly and disruptive, and may ultimately turn out to be ineffective. Aggressive measures taken at this time could be ineffective for two key reasons. First, research could ultimately show that the risks to human health from magnetic fields are nonexistent or very small. Second, knowledge gained on the 54 dose-response of magnetic fields could show that the measures that were taken to limit exposure were inappropriate or ineffective.” “If an EMF policy of prudent avoidance is determined to best strike a reasonable balance between avoiding potential harm and the associated costs and risks, Vermont utilities should take steps to lower magnetic field exposure in cases when this can be done at a modest cost. In most cases, this would apply only to new facilities since modifying old facilities would likely be very costly. Actions that could be considered under the prudent avoidance strategy include the use of low EMF design structures when constructing or rebuilding lines, and siting new or rebuilt lines away from populated areas. Utilities should monitor and might consider participating in research on EMF effects and on construction and design alternatives that would reduce EMF exposure. Several Vermont utilities are participating in an ad hoc working group on EMF, an effort that should help them deal with EMF issues. Finally, utilities could provide information on EMF for their customers and the public, including information that would allow concerned individuals to reduce possible risks from EMF exposure on their own. The utility industry in Vermont should rely on the state’s Department of Health to determine if this policy needs modification.” 55 X. CONCLUSIONS FOR THE SOUTHERN LOOP PROJECT The Vermont Department of Health concludes that the electric and magnetic power frequency field strength for the Southern Loop Project does not appear to be a public health hazard based on a review of the literature and on calculations with existing and projected current loads. In the absence of federal and state standards, the Vermont Department of Health applied the Florida (edge of ROW -150 mG, 2 kV/m; in ROW – 8 kV/m), New York (edge of ROW – 200 mG, 1.6 kV/m; in ROW – 11.8 kV/m), and ICNIRP (833 mG, 4.2 kV/m) guidelines for electric and magnetic power frequency fields to its analysis of the Southern Loop Project. The magnetic power frequency field for average and annual peak loading at the edge of the ROW is projected to be less than 29 mG along the Southern Loop Project corridor. This demonstrates that the projected magnetic power frequency fields at the edge of the ROW for the Southern Loop Project are well below the health-based ICNIRP guideline of 833 mG. The magnetic power frequency field for average and annual peak loading directly under the power line is projected to be less than 139 mG along the Southern Loop Project corridor. This demonstrates that the projected magnetic power frequency fields directly under the power line for the Southern Loop Project are well below the health-based ICNIRP guideline of 833 mG. The electric power frequency fields for the Southern Loop Project at the edge of the ROW are projected to be less than 1.6 kV/m. This demonstrates that the projected electric power frequency fields at the edge of the ROW for the Southern Loop Project are well below the health-based ICNIRP guideline of 4.2 kV/m. The projected electric power frequency fields (6.8 to 8.5 kV/m) directly under the power line are approximately the same as the existing electric power frequency fields (6.4 to 6.7 kV/m). All existing and projected electric power frequency fields directly under the power lines are above the ICNIRP guideline of 4.2 kV/m. The ICNIRP guidelines for power frequency electric fields are based on “short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects” [1](see section II.A.). Due to conservatism in the EMF calculations, the lack of evidence of chronic adverse health effects in the scientific literature from power frequency electric fields, the lack of chronic adverse health effects for use of the existing power line as of this date, the existence of 56 only one residence in the right of way whose power frequency electric field is below the healthbased ICNIRP guideline, and the ease of reducing the power frequency electric field by shielding, the VDH believes that the existing and proposed power frequency electric fields will not cause chronic adverse health effects. Intermittent recreational use in the proposed power line right of way is also not expected to cause chronic adverse health effects. The Vermont Department of Health concludes that the data in the current body of literature is insufficient to establish a direct cause and effect relationship between EMF exposure and adverse health effects. Health risks from exposure to EMF cannot be properly determined without sufficient information relating a specific measure of the magnetic power frequency field (e.g., time-averaged mG, cumulative mG, peak mG, time spent above a certain field strength) to a specific health effect. However, the possibility of a health risk from EMF cannot be dismissed entirely because some studies have identified slight but positive associations between EMF exposure and certain adverse health effects, while other studies have not. The VDH concludes that the projected electric and magnetic power frequency fields for the Southern Loop Project at the edge and in the ROW are not likely to interfere with medical devices worn by the public because: 1) the conditions used in the calculations are unlikely to occur or are infrequent in real life; 2) new medical devices (e.g. bipolar sensing pacemakers) are EMI (electromagnetic interference) resistant; 3) the lack of evidence of adverse health effects with medical devices in the scientific literature from power frequency electric fields; 4) the lack of adverse health effects with medical devices for use of the existing power line as of this date; and 5) the ease of reducing the power frequency electric field by shielding. The Vermont Department of Health concludes that modifications to the Southern Loop Project are not required for health reasons, but Vermont’s policy of prudent avoidance to mitigate EMF exposure as identified in the Vermont Twenty Year Electric Plan (1994) should be continued. 57 REFERENCES 1. International Commission on Non-Ionizing Radiation Protection, “Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and Electromagnetic Fields (Up to 300 GHz)”, Health Physics, Vol. 74, No. 4, April 1998. 2. Institute of Electrical and Electronics Engineers, “C95.6-2002 IEEE Standard for Safety Levels with Respect to Human Exposure to Electromagnetic Fields 10 to 3 kHz”, Prepared by Subcommittee 3, Safety Levels with Respect to Human Exposure, 0 3 kHz, of the International Committee on Electromagnetic Safety, Standards Coordinating Committee 28, IEEE, Inc., Three Park Ave, New York, NY, 10016-5997, ISBN 0-7381-3389-2, 2002. 3. 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International Agency for Research on Cancer, “Overall Evaluations of Carcinogenicity to Humans – Group 2B: Possibly carcinogenic to humans”, Website, 2001 http://monographs.iarc.fr/monoeval/crthgr02b.html 19. World Health Organization, “Electromagnetic Fields and Public Health – Extremely Low Frequency Fields and Cancer”, Fact Sheet No. 263, October 2001. 20. International Commission on Non-Ionizing Radiation Protection, “Review of the Epidemiologic Literature on EMF and Health”, Environmental Health Perspectives, Vol. 109, Supp. 6, December 2001. 21. National Radiological Protection Board, “Statement on Childhood Leukemia and Residential Exposure to Magnetic Fields”, Website www.nrpb.org/press/response_statements/response_statement_5_01.htm, 2001. 22. World Health Organization, “Electromagnetic Fields and Public Health – Extremely Low Frequency (ELF)”, Fact Sheet No. 205, October 1998. 23. Florida Department of Environmental Protection, “2001 Annual Report on EMF Research”, Website www.emfs.info/expert_ScienceReviews.asp, 2001. 24. California Department of Health Services, “An Evaluation of the Possible Risks from Electric and Magnetic Fields (EMFs) from Power Lines, Internal Wiring, Electrical Occupations and Appliances (Fourth and Final Draft)”, California EMF Program, Website www.emfs.info/expert_ScienceReviews.asp, 2001. 59 25. Virginia Department of Health, “Monitoring of Ongoing Research on the Health Effects of High Voltage Transmission Lines (Final Report)”, Division of Health Hazards Control, Website www.emfs.info/expert_ScienceReviews.asp, 2000. 26. Connecticut Department of Environmental Protection and Department of Health Services, “Connecticut 1994 Report on Task Force Activities to Evaluate Health Effects From Electric and Magnetic Fields”, Interagency Task Force Studying Electric and Magnetic Fields, Website www.emfs.info/expert_ScienceReviews.asp, 1994. 27. Maryland Department of Natural Resources, “Status Report on Potential Human Health Effects Associated with Power Frequency Electric and Magnetic Fields. Reporting Period: June 1993 - June 1994”, Website www.emfs.info/expert_ScienceReviews.asp, 1994. 28. Oregon Department of Energy, “Report of the EMF Committee to the Energy Facility Siting Council”, Website www.emfs.info/expert_ScienceReviews.asp, 1993. 29. Texas Public Utility Commission, “Health Effects of Exposure to Power-Frequency Electric and Magnetic Fields”, Website www.emfs.info/expert_ScienceReviews.asp, 1992. 30. Illinois Department of Public Health, “Possible Health Effects of Extremely Low Frequency Electric and Magnetic Field Exposure: A Review”, Illinois Environmental Protection Agency, Website www.emfs.info/expert_ScienceReviews.asp, 1992. 31. World Health Organization, “Electromagnetic Fields and Public Health – Physical Properites and Effects on Biological Systems”, Fact Sheet No. N182, May 1998. 32. California Department of Health Services and the Public Health Institute, “Short Factsheet on EMF”, Website www.dhs.ca.gov/ps/deodc/ehib, 1999. 33. Vermont Public Service Board Docket No. 6860, VELCO Northwest Reliability Project, January 28, 2005. 34. Silny, J., The Interference of Electronic Implants in Low Frequency Electromagnetic Fields, Arch. Mal. Coeur Vaiss, 96 Spec No 3:30-4, 2003. 35. Scholten, A., Silny, J. The Interference Threshold of Cardiac Pacemakers in Electric 50 Hz fields, J. Med. Eng. Technol., 25(1):1-11, Jan-Feb 2001. 36. Astridge, P.S., Kaye, G.C., Whitworth, S., Kelly, P., Camm, A.J., Perrins, E.J., The Response of Implanted Dual Chamber Pacemakers to 50 Hz Extraneous Electrical Interference, Pacing Lin. Electrophysiol., 16(10):1966-74, Oct. 1993. 37. EPRI, Susceptibility of Implanted Pacemakers and Defibrillators to Interference by PowerFrequency Electric and Magnetic Fields, Report TR-108893, Aug. 1997. 38. Bassen, Howard, Electromagnetic Interference of Medical Devices and Implications for Patient Safety, International Journal of Bioelectromagnetism, Vol. 4, No. 2, pp. 169-172, 2002. 60 39. Trigano, A., Blandeau, L., Souques, M., Gernez, J.P., Magne, I., Clinical Study of Interference with Cardiac Pacemakers by a Magnetic Field at Power Line Frequencies., J. Am. Coll. Cardiol., 45(6):896-900, Mar. 2005. 40. Sweesy, M.W., Holland, J.L., Smith, K.W., Electromagnetic Interference in Cardiac Rhythm Management Devices, AACN Clin. Issues, 15(3):391-403, Jul-Sep 2004. 41. Toivonen, L, Valjus, J., Hongisto, M., Metso, R., The Influence of Elevated 50 Hz Electric and Magnetic Fields on Implanted Cardiac Pacemakers: The Role of the Lead Configuration and Programming of the Sensitivity, Pacing Clin. Electrophysiol., 14(12):2114-22, Dec. 1991. 42. Heart Online Editorial, Electromagnetic Interference in Patients with Implanted Pacemakers or Cardioverter-Defibrillators, Heart 86:246-248, Sept. 2001. 43. 2008 www.medtronic.com/servlet/ContentServer?pagename=Medtronic/Website/StageArticle&Condit ionName=Tachyarrhythmia&Stage=Treatment&Article=tachy_art_home_work#likely4 44. 2008 www.medtronic.com/servlet/ContentServer?pagename=Medtronic/Website/StageArticle&Condit ionName=Bradycardia&Stage=Management&Article=brady_art_home_work#likely4 45. American Cancer Society, “What are the Risk Factors for Adult Myeloid Leukaemia (AML)?”, Website www.cancer.org, 2005. 46. American Cancer Society, “Unproven Risks”, Website www.cancer.org, 2002. 47. Electric Power Research Institute, Electric and Magnetic Fields (EMF), www.epri.com, January 2005. 48. National Radiological Protection Board, “Review of the Scientific Evidence for Limiting Exposure to Electromagnetic Fields (1-300 GHz)”, Documents of the NRPB, Vol 15, No 3, 2004. 49. National Radiological Protection Board, “Advice on Limiting Exposure to Electromagnetic Fields (1-300 GHz)”, Documents of the NRPB, Vol 15, No 2, 2004. 50. World Health Organization, “Environmental Health Criteria 238 - Extremely Low Frequency Fields”, WHO Press, 2007. 51. World Health Organization, Electromagnetic Fields and Public Health Exposure to Extremely Low Frequency Fields, Fact Sheet No. 322, June, 2007 52. International Commission on Non-Ionizing Radiation Protection, “The Approach of ICNIRP to Protection of Children”, Bioelectromagnetics Supplement 7:S157-S160, 2005. 61 53. Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE), “Opinion on Possible Effects of Electromagnetic Fields (EMF), Radio Frequency Fields (RF) and Microwave Radiation on Human Health”, European Commission Directorate-General, Health and Consumer Protection, 27th CSTEE Plenary Meeting, Brussels, 30 October 2001. 54. Health Council of the Netherlands: ELF Electromagnetic Fields Committee, “Exposure to Electromagnetic Fields (0 Hz – 10 MHz)”, The Hague: Health Council of the Netherlands, 2000. 55. Trigano, A, Blandeau, O, Souques, M, Gernez, JP, Magne, I, “Clinical Study of Interference with Cardiac Pacemakers by a Magnetic Field at Power Line Frequencies”, J Am Coll Cardiol, 45(6), 896-900, March 15, 2005. 56. Dawson, TW, Caputa, K, Stuchly, MA, Shepard, RB, Kavet, R, “Pacemaker Interference by Magnetic Fields at Power Line Frequencies”, IEEE Trans Biomed Eng, 49(3), 254-262, March 2002. 57. Prefiled Testimony of Peter Alexis Valberg, Ph.D. on Behalf of Petitioners, November 8, 2007, Docket No. 7373 58. “Update on Scientific Research Regarding Potential Health Effects of Power-Line Electric and Magnetic Fields (EMF), Gradient Corporation, September 21, 2007 WEBSITES International Commission on Non-Ionizing Radiation Protection Website, www.icnirp.de/pubEMF. National Institute of Environmental Health Sciences Website, www.niehs.nih.gov/emfrapid National Institute of Occupational Safety and Health, “EMFs In The Workplace”, NIOSH Fact Sheet, Website www.cdc.gov/niosh/emf2.html World Health Organization Website, www.who.int/peh-emf/en U.S. Food and Drug Administration MedWatch , www.fda.gov/medwatch/SAFETY.htm U.S. Food and Drug Administration MAUDE, www.fda.gov/cdrh/maude.html and www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfMAUDE/search.CFM National Library of Medicine, www.ncbi.nlm.nih.gov/entrez/ Electric Power Research Institute, www.epri.com 62 THIS PAGE INTENTIONALLY LEFT BLANK 63 APPENDIX A DATA FROM VELCO Table 1. Proposed Electric & Magnetic Field Input Data Vermont Yankee This is the field input data for proposed double 345 kV lines from Vermont Yankee to Fort Bridgeman Road crossing. Bundle x-feet y-feet n Cond Bund l-n phase cond D D volt 1 15.61 94 2 1.165 18 209.15 0 2 18.72 74 2 1.165 18 209.15 240 3 15.72 54 2 1.165 18 209.15 120 4 -34.39 101 2 1.345 18 209.15 0 5 -31.28 80 2 1.345 18 209.15 240 6 -34.28 59 2 1.345 18 209.15 120 Vernon to Newfane This is the field input data for proposed double 345kV lines from the Fort Bridgeman Road crossing (Pole 1) to Newfane (Pole 122). Bundle x-feet y-feet n Cond Bund l-n Phase cond D D volt 1 -26 55.83 2 1.165 18 209.15 240 2 0 55.83 2 1.165 18 209.15 120 3 -26 55.83 2 1.165 18 209.15 0 4 -126 55.83 2 1.345 18 209.15 0 5 -100 55.83 2 1.345 18 209.15 240 6 -74 55.83 2 1.345 18 209.15 120 Existing Structure Proposed Structure Continuous Peak Current (Amps) Peak Current (Amps) Line 2010 2017 2010 2017 2017HG Ampacity Ratings 816 926 466 507 565 2390 816 926 466 507 565 2390 816 926 466 507 565 2390 NA NA 488 531 584 2490 NA NA 488 531 584 2490 NA NA 488 531 584 2490 Existing Structure Proposed Structure Peak Current (Amps) Peak Current (Amps) 2010 2017 2010 2017 816 816 816 NA NA NA 926 926 926 NA NA NA 466 466 466 488 488 488 507 507 507 531 531 531 64 Continuous Line Ampacitiy 2017HG Ratings 565 565 565 584 584 584 2390 2390 2390 2490 2490 2490 Newfane Divergence This is the field input data for proposed 46 kV and double 345 kV lines from Newfane (Pole 122) to the proposed Newfane Existing Structure Proposed Structure Substation. Peak Current (Amps) Peak Current (Amps) Bundle x-feet y-feet 1 2 3 4 5 6 7 8 9 7 38.85 0 48.99 -7 38.85 -42.39 101 -39.28 80 -42.28 59 -73.61 101 -76.72 80 -73.72 59 n cond 1 1 1 2 2 2 2 2 2 Cond Bund l-n Phase D D volt 0.814 na 27.89 0 0.814 na 27.89 240 0.814 na 27.89 120 1.165 18 209.15 0 1.165 18 209.15 240 1.165 18 209.15 120 1.165 18 209.15 0 1.165 18 209.15 120 1.165 18 209.15 240 2010 2017 2010 2017 56 56 56 NA NA NA NA NA NA 260 260 260 NA NA NA NA NA NA 80 80 80 488 488 488 442 442 442 63 63 63 531 531 531 481 481 481 Continuous Line 2017HG Ampacity Ratings 101 814 101 814 101 814 584 2390 584 2390 584 2390 539 2490 539 2490 539 2490 Newfane to Coolidge Existing Structure Proposed Structure Continuous This is the field input data for proposed double 345kV line Peak Current (Amps) Peak Current (Amps) Line Newfane (Pole 122) to the Coolidge Substation (Pole 403). Bundle x-feet y-feet n Cond Bund l-n Phase 2010 2017 2010 2017 2017HG Ampacity cond D D volt Raltings 1 -26 55.83 2 1.165 18 209.15 240 816 926 466 507 565 2390 2 0 55.83 2 1.165 18 209.15 120 816 926 466 507 565 2390 3 26 55.83 2 1.165 18 209.15 0 816 926 466 507 565 2390 4 -126 55.83 2 1.345 18 209.15 0 NA NA 442 481 539 2490 5 -100 55.83 2 1.345 18 209.15 240 NA NA 442 481 539 2490 6 -74 55.83 2 1.345 18 209.15 120 NA NA 442 481 539 2490 Notes: *X-feet, Y-feet, N-cond, Cond-D, Bund D, L-n voltage, phase (voltage and current), peak currents from e-mail of Jeff Carrara, January 17,2008. *Continuous Line Ampacity Ratings per telephone conversation with Jeff Carrara, March 7, 2008. *Note that current phase for the Newfane Divergence are not the same as the voltage phase and are not shown in this table (e-mail of Jeff Carrara, January 17, 2008). *Average currents (amps) are approximately 60% of the peak current per telephone conversation with Jeff Carrara, March 7, 2008. 65 APPENDIX B Table 1. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT ANNUAL PEAK LOADING ON THE EDGE OF THE RIGHT OF WAY1 (milliGauss) Existing Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 1200 2010 11.8 42.5 0.8 42.5 2017 13.4 48.2 3.8 48.2 Proposed Power Line 2010 22.8 23.3 9.8 22.3 2017 25.9 25.4 10.6 24.2 2017HG2 28.6 27.9 12.2 27.0 foot ROW for all corridors Converter 2Highgate Table 2. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT ANNUAL PEAK LOADING DIRECTLY UNDER THE POWER LINE (milliGauss) Existing Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 2010 113 185 6.3 185 2017 128 210 29 210 Proposed Power Line 2010 66 116 75 111 2017 76 126 82 121 1 Highgate Converter 66 2017HG1 84 139 91 134 Table 3. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT AVERAGE LOADING1 ON THE EDGE OF THE RIGHT OF WAY2 (milliGauss) Existing Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 1Average loading is approximately 60% of the annual peak load 2200 foot ROW for all corridors 3Highgate Converter 2010 7.1 25.5 0.5 25.5 2017 8.0 28.9 2.3 28.9 Proposed Power Line 2010 13.7 14.0 5.9 13.4 2017 15.5 15.2 6.4 14.5 2017HG3 17.2 16.7 7.3 16.2 Table 4. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT AVERAGE LOADING1 DIRECTLY UNDER THE POWER LINE (milliGauss) Existing Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 1Average loading is approximately 60% of the annual peak load 2 Highgate Converter 2010 68 111 3.8 111 2017 77 126 17 126 Proposed Power Line 2010 40 70 45 67 2017 46 76 49 73 67 2017HG2 50 83 55 80 Table 5. ELECTRIC POWER FREQUENCY FIELD STRENGTH DIRECTLY UNDER THE POWER LINE AND AT THE EDGE OF THE RIGHT OF WAY (kilovolt/meter) Existing Power Line Corridor Vermont Yankee Vernon to Newfane Newfane Divergence Newfane to Coolidge 1200 Directly Under 6.4 6.7 0.34 6.7 Proposed Power Line ROW Edge 0.24 1.6 0.04 1.6 1 Directly Under 7.0 6.8 8.5 6.8 ROW Edge1 0.34 1.6 0.33 1.6 foot ROW for all corridors Table 6. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT CONTINUOUS LINE AMPACITY ON THE EDGE OF THE RIGHT OF WAY (milliGauss) Existing Power Line Proposed Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 58 124 21 124 122 119 61 119 68 Table 7. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT CONTINUOUS LINE AMPACITY DIRECTLY UNDER THE POWER LINE (milliGauss) Existing Power Line Proposed Power Line Corridor Vermont Yankee Vernon-Newfane Newfane Divergence Newfane-Coolidge 331 542 92 542 359 581 395 581 Table 8. DISTANCE FROM EDGE OF RIGHT OF WAY AT WHICH MAGNETIC POWER FREQUENCY FIELD HAS DROPPED TO 4 MILLIGAUSS AT ANNUAL PEAK LOADING (feet) Existing Power Line 2010 Corridor Vermont Yankee Vernon to Newfane Newfane Divergence Newfane to Coolidge West 95 170 -302 170 Proposed Power Line 2017 East 125 170 -302 170 West 110 185 15 185 2017 HG1 2010 East 140 185 15 185 West 140 175 30 90 1 Highgate Converter A negative number indicates the magnetic field has dropped to 4 mG within the right of way by the indicated number of feet 2 69 East 120 95 -202 95 West 170 120 40 110 East 145 115 -102 115 Table 9. MAGNETIC POWER FREQUENCY FIELD STRENGTH AT IDENTIFIED BUILDINGS NEAR THE RIGHT OF WAY AT ANNUAL PEAK LOADING (milliGauss) Corridor Road Pole Distance1 (feet) Governor Hunt Road 6-SW 6-SW Franklin Road 8 8-9 8-9 8-9 8-9 17-18 18-19 45-46 50-51 51 57-58 77-78 81-82 89-90 Existing Power Line Proposed Power Line 2010 2017 2010 2017 2017HG2 75 W 100 W 4.8 3.8 5.4 4.3 7.6 5.8 8.6 6.6 9.5 7.3 50 W 50 E 50 E 150 E 225 E 175 E 225 E 250 E 125 E 150 W 75 E 175 E 25 E 150 W 4.8 15.5 15.5 4.8 2.6 3.9 <2 2.3 6.0 2.3 11 3.9 24 2.3 5.4 17.6 17.6 5.4 3.0 4.4 2.1 2.6 6.9 2.6 12 4.4 27 2.6 8.1 7.7 7.7 2.3 <2 <2 <2 <2 3.0 2.4 5.3 <2 12 2.4 8.9 8.4 8.4 2.5 <2 2.0 2.1 <2 3.2 2.7 5.8 2.0 13 2.7 9.7 9.4 9.4 2.8 <2 2.3 2.4 <2 3.6 2.9 6.4 2.3 15 2.9 Vermont Yankee VernonNewfane Melendy Hill Road Bonny Vale Road Goodenough Road Covey Road Halladay Brook Road Sunset Lake Road Unknown road 70 Corridor Road Pole Distance1 (feet) 137-138 142-143 142-143 151 151-152 151-152 151-152 164 164-165 167-168 168-169 169-170 169-170 188-189 192-193 192-193 195-196 197-198 222-223 Existing Power Line Proposed Power Line 2010 2017 2010 2017 2017HG2 175 W -25 W -25 W 50 E 175 E 250 E 125 W 200 E 125 E 75 W 125 W 25 W 75 W 275 E 250 E 75 W 180 W 150 W 175 E <2 11 11 15 3.9 2.3 2.7 3.2 6.0 3.9 2.7 6.0 3.9 <2 2.3 3.9 <2 2.3 3.9 2.2 12 12 18 4.4 2.6 3.0 3.6 6.9 4.4 3.0 6.9 4.4 2.2 2.6 4.4 2.2 2.6 4.4 <2 45 45 7.8 <2 <2 2.8 <2 3.0 5.0 2.8 12 5.0 <2 <2 5.0 <2 2.2 <2 <2 49 49 8.5 2.1 <2 3.0 <2 3.2 5.5 3.0 13 5.5 <2 <2 5.5 <2 2.4 2.1 2.2 55 55 9.4 2.3 <2 3.4 <2 3.6 6.1 3.4 14 6.1 <2 <2 6.1 2.1 2.7 2.3 283-284 307-308 307-308 200 E 175 W 125 E 3.2 <2 6.0 3.6 2.2 6.9 <2 <2 3.0 <2 <2 3.2 <2 2.2 3.6 314-315 324-325 380-381 381-382 150 W 150 E 50 E 125 W 2.3 4.8 15 2.7 2.6 5.4 18 3.0 2.2 2.3 7.8 2.8 2.4 2.5 8.5 3.0 2.7 2.8 9.4 3.4 NewfaneCoolidge Putney Mountain Road Merrill Drive Hill Road Taft Road Crane Road Hazel Hill Road Deer Valley Road Route 35 Simpson Brook Road Popple Dungeon Road Route 11 Weston-Andover Road Farrar Road Route 103 1Distance is from proposed edge of ROW, W = west edge, E = east edge Converter NOTE: Not all identified locations in this table may be actual residences due to the lack of detail on the aerial photographs. 2Highgate 71 Table 10. DISTANCE FROM EDGE OF RIGHT OF WAY AT WHICH MAGNETIC POWER FREQUENCY FIELD HAS DROPPED TO LESS THAN 2 MILLIGAUSS AT ANNUAL PEAK LOADING (feet) Existing Power Line 2010 Corridor Vermont Yankee Vernon to Newfane Newfane Divergence Newfane to Coolidge West 180 270 -302 270 Proposed Power Line 2017 East 210 265 -102 270 West 200 295 30 295 2010 East 230 295 50 295 West 225 170 65 160 1 Highgate Converter A negative number indicates the magnetic field has dropped to 4 mG within the right of way by the indicated number of feet 2 72 2017 HG1 2017 East 215 165 15 165 West 250 180 65 170 East 235 175 20 175 West 275 195 75 185 East 250 190 30 190