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BEFORE THE PUBLIC SERVICE COMMISSION OF WISCONSIN
Joint Application of Minnesota Power
Company
PREFILED DIRECT TESTIMONY OF DR. JOHN E. MOULDER
Q. What is your name and business address? A. My name is John E. Moulder, Ph.D. My business address is Radiation Oncology, Medical College of Wisconsin, 8701 Watertown Plank Road, Milwaukee, Wisconsin 53226 Q. Where do you work? A. I am a professor in the departments of Radiation Oncology, Radiology, and Pharmacology at the Medical College of Wisconsin. Q. What is your educational background? Q. Where have you worked in addition to the Medical College of Wisconsin? A. I was appointed to the faculty of the Yale Medical School in the Department of Therapeutic Radiology in 1976. In 1978, I joined the Department of Radiology at the Medical College of Wisconsin. Except for a six month period as a visiting professor in the Department of Radiation Oncology at the University of Washington-Seattle, I have been teaching and conducting research at the Medical College of Wisconsin since 1976. Q. What are your responsibilities at the Medical College of Wisconsin? A. My responsibilities are three-fold. First, I teach radiation and cancer biology to medical residents and physicians. Second, I conduct basic and clinical research in the areas of cancer biology and radiation biology. Third, I serve on a variety of advisory bodies, principally in the area of public health risks from exposure to various forms of ionizing and non-ionizing radiation. Q. Would you describe in more detail the courses that you teach at the Medical College of Wisconsin? A. The major course that I teach is Biological Effects of Ionizing and Non-Ionizing Radiation. This course is principally directed toward uses of ionizing and non-ionizing radiation in medical diagnosis and in the treatment of cancer. In this course I cover epidemiological studies, clinical studies, animal studies, cell culture studies and biochemical studies, since all are necessary for a complete understanding of radiation biology. Q. Are you involved in any research? A. About three-quarters of my time is devoted to research, principally in the areas of cancer biology and radiation biology. I have published extensively in those areas. Q. Do you have a summary of your educational credentials, professional experiences, publications and other activities? A. Yes. A copy of my CV is attached as Exhibit (JEM-1). Q. Your CV mentions that you served on the Wisconsin Radiation Protection Counsel (WRPC). Would you explain your involvement with that agency? A. The WRPC was a state agency attached to the Department of Health and Social Services. I served on the WRPC for a number of years beginning in the 1980s. One of my responsibilities was to advise the State of Wisconsin concerning the status of knowledge regarding alleged health risks from electro-magnetic fields, such as those associated with utility power facilities and electrical appliances. Q. Are electro-magnetic fields popularly called “EMF”? A. Yes. However, I prefer to refer to them as “power-frequency fields.” The term “power-frequency fields” refers to the sinusoidal electric and magnetic fields produced by the alternating current (AC) frequencies used in electric power systems in the United States and elsewhere. Most electric transmission lines, and virtually all common electrical devices, use alternating current and generate such power-frequency fields. On the other hand, “EMF” is an imprecise term that could apply to many different types of fields, and “EMF” also has. a long-standing use in physics to refer to an entirely different concept: electromotive force. Q. Have you lectured or published about the biological effects of power-frequency fields? A. Yes, as set out in my CV, I have published a number of peer-reviewed papers on the issue of whether power-frequency fields cause or contribute to cancer. Over the past decade I have been an invited lecturer at many institutes and scientific societies on the subject of the biological effects of power-frequency fields. Q. Do you provide information about the biological effects of power-frequency fields in a way that is accessible to people who do not subscribe to peer-reviewed journals? A. Yes. In addition to publishing in conventional peer-reviewed journals, I maintain an internet (worldwide web) site at the Medical College of Wisconsin that provides public information on the biological effects of power-frequency fields. This web site is referenced on a number of other internet sites, including: The World Health Organization (WHO), the US National Institute of Environmental Health Sciences (NEIHS), the US National Aeronautics and Space Administration (NASA), the Australian Radiation Protection Agency, the Canadian Center for Occupational Health and Safety, the Leukemia Research Fund (UK), the Radiation Research Society (US), the Bioelectromagnetic Society, the US Health Physics Society, Harvard University, Princeton University, Stanford University, and the University of Pennsylvania Cancer Center. Q. Have you acted as a consultant regarding the alleged health hazards or risks of power-frequency fields? A. Yes. I have consulted on the alleged health hazards of power lines for a number of companies, public utilities and governmental bodies. As part of the work I did for the US National Institute of Health, I participated in the review of many of the grant proposals that were submitted for funding on the EMF-RAPID Program. This program was authorized by the US Congress in 1993 “to determine whether or not exposure to EMF produced by the generation, transmission and use of electric energy affects human health.” Q. Has the EMF-RAPID Program been completed? A. The research part of the program has been completed, but some of the work has yet to be published. Q. What conclusions can be drawn from the EMF-RAPID program regarding whether power-frequency fields from the generation, transmission and use of electric energy affect human health? A. The U.S. Academy of Science has reviewed the results of the EMF-RAPID Program [National Research Council, Research on Power Frequency Fields Completed under the Energy Policy Act of 1992. National Academy Press, Washington D.C., 1999] and concluded that: “the results of the EMF-RAPID Program do not support the contention that the use of electricity poses a major unrecognized public-health danger.” Q. Did you have any role in preparing the National Academy of Sciences report? A. Yes. I served as a formal external reviewer of the draft report. Q. Do you agree or disagree with this conclusion? A. I agree with it. Q. What are the major types of fields encompassed by the term “power-frequency fields”? A. The two primary components are the electric field and the magnetic field. Q. Would you explain the difference between those types of fields? A. Electric fields exist whenever electric charges are present, regardless of whether current is flowing. Electric fields are measured in volts per meter (V/rn). Magnetic fields are produced by moving charges (e.g., an electric current flowing through a wire), and are commonly measured in tesla (T). An older unit for measuring magnetic fields is the gauss (G). Ten thousand gauss equals one tesla. This means that one milligauss (mG) equals 0.1 microtesla (j.iT). The magnetic fields associated with power lines easily penetrate buildings and are difficult to shield. In contrast, power-frequency electric fields are easily shielded and have little ability to penetrate buildings (or human tissue). Because power-frequency electric fields have little ability to penetrate, it is generally thought that any biologic effect from residential exposure to power-frequency fields from power lines must be due to the magnetic component of the field. Q. Do you agree that the electric field component of power-frequency fields is unlikely to cause any human health hazards? Q. Would you briefly summarize the state of research on power-frequency fields and human health? A. By 1995 the scientific community generally had concluded that there was no consistent evidence that exposure to power-frequency fields could cause cancer or produce other adverse effects on humans. Extensive epidemiological studies, laboratory studies and exposure assessments published since 1995 have reinforced this view. I have prepared a paper which discusses, summarizes and addresses the importance of the research on power-frequency fields and human health conducted in the last five years. A copy of that paper is attached as Exhibit __ (JEM-2). Q. Have you reviewed the estimates of the magnetic field component of the power-frequency fields associated with the Arrowhead-Weston 345 kV Transmission Line? A. Yes. Q. Do you believe that those fields pose a risk to human health? A. In my opinion, there is no consistent scientific evidence that power-frequency electric and magnetic fields of this magnitude produce any adverse effects on human health. While it is not possible in science to absolutely prove a negative, it is possible to say that this issue has been studied extensively by researchers and that no one has found consistent, reproducible evidence that power-frequency fields of this magnitude cause an adverse effect on human health. Consequently, based on what we know today, it cannot be demonstrated that the power-frequency fields calculated to be produced by this line create a risk to human health. Q. Is that opinion consistent with some of the research you cite in Ex. _____ (JEM-2) which claims to show an association between power-frequency fields and human health? A. Yes. When you are talking about whether there is a relationship between an environmental agent and a human health effect, there is an enormous difference between “association” and “causation.”. [sic] In this context “association” means that exposure to an agent and the occurrence of a disease happen in the same group of people. “Causation” means that exposure to the agent is sufficient to produce or “cause” the disease. “Association” is not the same thing as “causation”. The classic teaching example is the rooster crowing at dawn. The two are associated, but no one claims that the rooster’s crow causes the sun to rise. Q. Is an “association” evidence of “causation”? A. It might be, but it also might not be. In order to determine whether an environmental agent which is associated with a health effect (say, in this instance, cancer) can be said to “cause” that health effect, scientists apply certain generally accepted criteria. They evaluate the quantity and quality of the studies, the strength and specificity of the association of exposure to the element with the development of the disease, the internal and external consistency of the studies, the evidence for an exposure-response (dose-response) gradient, and the biological plausibility of the relationship. Q. In your opinion, does application of those criteria warrant a finding that power-frequency fields cause cancer? A. In my opinion, the existing scientific evidence for a causal relationship between exposure to power-frequency fields and cancer is weak and is insufficient to find that a causal relationship exists. Q. Are you familiar with the recent BC Cancer Agency Study, published in May 1999 in the American Journal of Epidemiology? A. Yes. Q. Can you describe this study and briefly summarize what it concluded? A. This study is the work of McBride and colleagues (Reference 19 in Exhibit [JEM-2]). McBride’ s study was the largest study to that date of childhood leukemia and residential exposure to power-frequency electric and magnetic fields. The study found no evidence for any association between power lines and childhood leukemia. The study is notable for its size and the wide range of exposure and metrics tested. When McBridge [sic] and colleagues measured electric and magnetic fields with personal monitors, they found slightly less leukemia then expected in the children with the highest exposures. Similar results were also found when they calculated what the field levels would have been in the past (before the children developed leukemia). When they used the “wire-code” scheme for estimating exposures that the original US studies had used to estimate the intensity of power line fields, no significant increase in leukemia was found. Q. Are you familiar with the recent British study, published in December 1999 in The Lancet, and can you describe it and comment on its significance? A. Yes. This is the work of a group led by Sir Richard Doll (Reference 29 in Exhibit [JEM-2]). This study was a case control study of 2,226 children with cancer and an equal number of matched controls. Power-frequency magnetic fields were measured in residences and schools, and these measurements were used to calculate the average exposure for the year prior to the diagnosis of cancer. In the children with the highest exposures, the incidence of leukemia, brain cancer and overcall cancer was slightly less then expected. Q. What is the significance of the Doll group’s findings? A. In conjunction with the 1997 study by the US National Cancer Institute (Reference 19 in Exhibit [JEM-2]), and the 1999 Canadian Study (Reference ___ in Exhibit [JEM-2]), the Doll study eliminates essentially all grounds for suggesting a causal association between exposure to power line fields and the incidence of childhood leukemia. Q. If that is so, then why, in 1998, did a Working Group assembled by the NIEHS conclude that power-frequency fields should be placed in IARC Class 2B as a “possible human carcinogen”? A. There appear to be several reasons for this statement by the Working Group. First, it did not have access to the McBride and Doll studies. Second, the Working Group had very little time to write the report (less than two weeks), its report was not peer-reviewed, and the report is full of mistakes (it cites articles that do not exist and attributes data to articles that do not contain those numbers). Third, in the IARC classification scheme Class 2B is effectively the lowest category. In the history of IARC, only one agent has ever been placed in the lowest category, “probably not carcinogenic”. It is significant that the full NIEHS report to Congress rejected this classification by the Working Group, and instead stated that power-frequencies were not an agent “reasonably anticipated to be a human carcinogen”. Q. Do you think that the working group misapplied the IARC guidelines in placing powerfrequency fields in Class 2B? A. Yes. The Working Group’s report explained that the placement in IARC Class 2B was based largely on “limited evidence” that residential exposure to power-frequency fields was associated with childhood leukemia. “Limited epidemiological evidence” in the IARC scheme means: “A positive association has been observed between exposure and cancer for which a causal interpretation is considered credible, but chance, bias or confounding could not be ruled out with reasonable confidence.” The scientific evidence does not meet the criteria of establishing “a positive association . . . between exposure and cancer for which a causal interpretation is considered credible” for two main reasons. First, the Working Group did not establish that a causal interpretation of the epidemiology was “credible”. They only argued that there were some weak epidemiological associations that had some consistency. Second, the Working Group essentially ignored a large body of laboratory studies that indicated that power-frequency fields are not carcinogenic. In the years subsequent to the Working Group’s meeting, the negative laboratory studies have become even stronger. Q. If you were to use the IARC classification system, to what category would you now assign power-frequency fields with respect to human cancer. A. The IARC classification system is out-dated and is no longer particularly useful for classifying substances because it does not take into account our increased understanding of carcinogenesis. That is,. it gives little weight to animal, cellular or mechanistic studies. But, if I were forced to use the IARC criteria, in my opinion power-frequency fields should be place in IARC Class 3: “Not classifiable as to carcinogenicity.” Q. Do you have an opinion, based upon your review of the studies and your knowledge of the field, including the scientific research conducted to date, whether power-frequency electric or magnetic fields have been demonstrated to have adverse human health effects? A. I do. In my opinion, no causal relationship between exposure to power-frequency electric and magnetic fields and adverse human health effects has been established. Q. What is the consensus of the scientific community on this issue? A. The consensus of the scientific community is that power-frequency electric and magnetic fields have not been shown to adversely affect human health. In fact, in 1997 the prestigious U.S. Academy of Science, upon completing its review of the body of science on the effect of power-frequency electric and magnetic fields on human health, concluded 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 exposures to residential electric and magnetic fields produce cancer, adverse neuro-behavioral effects or reproductive and developmental effects.” Similarly, in 1999 the U.S. National Institute of Environmental Health Sciences reported to the U.S. Congress that “The scientific evidence suggesting that [power-frequency field] exposures pose any health risk is weak.” Q. Does that mean one can say that power-frequency fields have been proven to be safe? A. No, it is not scientifically possible to prove that anything, including power-frequency electric and magnetic fields, is absolutely safe. As the chair of the committee that wrote the 1997 US National Academy of Science Report said, “Science can’t prove that anything is safe, but so far we have failed to find a hazard.” Q. Do you think it likely that at some future date science will find a human health hazard from power-frequency electric or magnetic fields? A. In my opinion, such a finding is unlikely. Given the amount of research effort expended to date, if major hazards existed, I would expect them to have been identified and established. Q. Have you heard of something called the “Henshaw Hypotheses” as related to high voltage transmission lines? A. Yes. Q. Can you explain the Henshaw Hypotheses? A. Henshaw and colleagues have advanced two different theories regarding transmission lines and leukemia. Originally, they speculated that the radioactive decay products of radon, and other potentially carcinogenic airborne particles, were attracted to strong power-frequency electric field sources, and therefore there could be increased exposure to such carcinogenic agents near high-voltage power lines. Recently Henshaw and colleagues have amended their hypothesis to speculate that ions produced by corona from high voltage power lines might attach to aerosol pollutants (for example, motor vehicle exhaust) and increase the possibility that these pollutants would be deposited in the lung. Q. What is your opinion of the Henshaw Hypotheses? A. The basic observation that radon daughters and other aerosols are attracted to very strong electric field sources is plausible. However, the jump from this observation to a theory of how power-frequency fields could cause childhood leukemia is not plausible. There are major theoretical problems with the hypotheses which indicate that the postulated mechanisms are extremely unlikely to produce adverse human health effects under real-world exposure conditions. Moreover, independent studies have found no evidence that ionizing radiation levels are elevated around high voltage power lines, no evidence that children who live near high voltage power lines are frequently exposed to very strong electric fields, and no evidence that either the incidence of childhood leukemia or adult brain cancer is related to radon exposure. Finally, the adverse health effect suggested by the hypotheses (an increase in adult lung cancer in those who spend significant time in proximity to high voltage lines) has not been found in the epidemiology studies done to date. Q. In your opinion are the Henshaw Hypotheses something which the Pubic Service Commission should consider when it evaluates the effect of a 345 kV transmission line on the human and natural environment? A. No. At this point the hypotheses are far too speculative, conjectural and contrary to existing scientific evidence to be the basis for making sound public policy decisions. Q. Does this complete your direct testimony. [sic] A. Yes .
Our comments on Moulder's testimony will appear in this box as you click on the hyperlinks in the above box. Moulder's background does not include training in non-ionizing radiation. Non-ionizing radiation contains insufficient energy to directly disrupt DNA, and is the type of radiation associated with magnetic fields emitted by transmission power lines. Moulder is entirely correct. His web site is widely referenced by other sites, including this one. The Final Report of the EMFRapid study has been published, although there are some small parts yet to be released. The 1999 National Research Council study is essentially a review of its own 1977 Linet study, which has now been shown in the British Journal and Greenland to demonstrate a link between EMF and Cancer. Accordingly, the 1999 review is now invalid. This statement is incorrect in its entirety. Unlike what Moulder maintains, the generally accepted view is that EMF from power lines is dangerous to human health. There is a vast collection of both biological and epidemiological evidence supporting this conclusion. While there has been recent evidence that reinforces the view that his statements are grossly invalid, there was sufficient evidence at the time he made the statement (early 1999) to make it incorrect even then. Again, Moulder was wrong when he made this statement, and has been proven totally incorrect by studies released since he made his statement. Does that mean that the sun does not induce the rooster to crow? Of course not. Moulder is setting up a false analogy with this example. Experts are not suggesting that cancer causes EMF, no more than they are suggesting that the rooster causes the sun to rise. Rather, just as the sun induces roosters to crow, they have demonstrated that EMF induces cancer. Moulder is word-smithing here. A careful reading show he is not addressing the biological evidence. Rather, he is discussing the pertinent epidemiological studies. What Moulder is saying is that the epidemiological evidence is weak. Remember that, to epidemiologists, "weak" has a special meaning. It means that the increase in risk is not as high as it would be for "strong" relationships such as that between smoking and cancer. It does not mean that the relationship is not proved beyond a reasonable doubt, for we know now the epidemiological evidence is statistically signficant and that it fully supports the plentiful biological evidence. The McBride study has been reversed. Dr. McBride herself participated in the British Journal study that shows her data demonstrates a statistically significant association between EMF and cancer. Her study was similarly reversed in the Greenland Sudy published in the November 2000 edition of Epidemiology. He is talking about the United Kingdom Childhood Cancer Study (UKCCS). This study was led by Nicholas Day, not Richard Doll. The UKCCS study was one of the studies overturned by the British Journal study. In short, all of the studies cited by Moulder have now been overturned. The 1999 Canadian Childhood Cancer study is one of the study that has been reversed by the British Journal study. The Canadian Childhood data display a relationship between EMF and Cancer. The lead researcher in the Canadian study, Mary McBride, participated in the British Journal study, and, accordingly has effectively reversed her own data. This reversal was also validated by the Sander Greenland Epidemiology study. The conclusions of the 1997 study have been reversed by the study's prime author, Martha Linet. The study's data do now demonstrate an association between cancer and EMF. The Working Group did have access to, and was influenced by, the the now-discredited 1977 NRC Study. That study has been reversed by its prime author, Martha Linet. The confusion engendered by that study resulted in the Group 2B classification. It is likely that, if the Working Group had access to the British Journal study, which reverses both the McBride (Canadian Childhood Cancer) and the Doll (UKCCS) conclusions, it almost certainly would have assigned EMF to Group 2A (probably carcinogen) or, nearly as likely, to Group 1 (demonstrated carcinogen). It is not outdated as demonstrated by the fact it is still being actively used, and, indeed, low frequency EMF is the subject of a forthcoming (June 2001) report. This statement is totally wrong. In fact, the consensus in the scientific community is that EMF is associated with human cancer. The NRC is part of the Academy of Science, so he is just referring to the now-discredited 1997 NRC research. This is a significant (and frequently repeated) misstatement of the relevant NIEHS conclusion. The cited paragraph refers to average residential exposures, which, indeed, appear to be safe. They do not apply to the much higher exposures experienced by those who live next to power lines. With respect to such exposurs, the NIEHS had only one recommendation: "NIEHS suggests that the power industry continue its current practice of siting power lines to reduce exposures." The adverse health effect suggested by the hypotheses has been confirmed by epidemiology studies conducted since his testimony. The Henshaw studies validated were validated by both biological and epidemiological research.
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