September 13,
1999
Commissioner
Gene Hugoson, EQS Chairman
Minnesota
Department of Agriculture
90 West Plato
Boulevard
St. Paul,
Minnesota 55155
Dear
Commissioner Hugoson
I am sorry that
I will be unable to staid the September 16, 1999 meeting of the Environmental
Quality Board (EQB) due to a prior commitment
I have a
particular interest in the agenda item remaining from the August meeting, the
EAW adequacy decision on the proposed SE Metro 125 k V Transmission Line. This project proposes to replace an existing
single circuit 115 k V line with a double circuit line, utilizing new, higher
poles along the existing right of way. According to Northern States Power
(NSP), the resulting lines should emit lower magnetic fields than the existing
line. However, many residents who live along the line’s right-of-way would like
NSP to complete an EIS on the project, in part because of their concerns regarding
the potential health effects of the magnetic fields associated with the line.
The EQB staff recommendation is to issue a negative decimation on the EAW, which means that the
Board would find that this project has no potential for significant
environmental effects
At the August
EQB meeting we talked at some length about the meaning of a negative
declaration. While clearly there are differences of opinion about the
significance or intended meaning of a negative declaration, I be1ieve that a
negative determination in this case would be misunderstood. From a public
health standpoint, I am concerned about the levels of magnetic field exposure
to which certain residents are now and will continue to be subject. The most
recent report by the National Institute of Environmental Health Sciences states
that “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 lymphocyte leukemia
than for childhood leukemia.” While this evidence is weak, it cannot be
entirely discounted.
If our basis for not ordering an EIS is that there is conclusively no evidence of harm, I cannot agree. While there is no definite linkage of EMF exposure to health risks, it is equally true that such a linkage cannot be ruled out based on existing knowledge. My primary concern is a section of the transmission line on which the right-of-way is only 40 feet wide, meaning that numerous homes arc only 20-25 feet away from the line. According to NSP modeling, these people may be subject to magnetic fields averaging 48 milliGauss (mG) at 25 feet from the line by the year 2020, when the line is utilized at full capacity. This appears to be well outside the range of what is considered “normal” exposure. For example, 1993 survey of residential homes by the Electric Power Research Institute showed that less than one percent of homes had a whole-house median field exceeding 5.8 mG or a single room field exceeding 12-2 mG. In addition, the Canadian epidemiological study cited by EQB staff as showing little relationship between magnetic fields and leukemia was based on far lower EMF levels. That study classified children whose bedrooms had mean magnetic fields of 2.6 mG as having very high exposure to EMF. Given that this same study showed an elevated (but statistically nonsignificant) risk of leukemia for the group whose exposure was in the upper 10 percent, it seems premature to conclude that EMF poses no risk whatsoever. The SE Metro line project is projected to generate exposure levels 4-24 times as high as those in the studies on which EQB staff is basing its recommendation.
My concerns
should not be interpreted to mean that EMF is a public health issue which
requires drastic action. However, the evidence suggests to me that regulatory
bodies should examine precautionary measures that will minimize exposure to
EMF, especially in those situations where exposure would otherwise be
particularly high. An exploration of this issue suggests several questions that
should be answered:
·
How
typical is this power line and right-of-way configuration in Minnesota? In
other words, how many Minnesota residents are potetial1y subject to high (above
10 mG) magnetic fields? What are average residential exposures to magnetic
fields, and to what extent do power lines contribute to those fields?
·
What
arc the alternative routes or line configurations that might reduce exposure?
Can they be used specifically through the most affected communities. or would
they require a complete change in the project? What is the cost of these
alternatives?
·
How
many similar power line upgrades are anticipated by NSP over the next 10-20
years?
I feel that
these questions can only be answered adequately through the preparation of an
EIS. I was prepared to vote for an EIS at the August EQB meeting, and would
vote for one now if I were able to attend the September meeting. My Assistant
Commissioner, Aggie Leitheiser will be at the EQB meeting if you have questions
about these concerns. Thanks for your thoughtful consideration.
Sincerely,
Jan K. Malcolm
Commissioner
cc: EQB members
Michael Sullivan