opposing unnecessary, excessive
REVOLT Newsletter 369
Revolt news 18/08/2013 Print (pdf) Version
1. EMF health issues arise with buried cables as well as with overhead lines. This may be a disappointment to campaigners arguing for burial, but at least the fields are more closely contained near the cables, so a reasonable solution may still be achieved by ensuring a short minimal distance from homes (news368). The same problem even happens with HVDC cables because of the EMF 'noise' created by the conversion process, as we have seen with Eirgrid's EWIC cables.
2. The question of distance of buried cables from homes was not addressed by the UK government advisory group SAGE when it considered precautionary measures. SAGE expressly concluded that a general policy of a 60 metre corridor separating overhead national grid lines from homes was not justified on cost-benefit grounds, but that should not be the end of the matter. Smaller measures for reducing EMF exposures are still "reasonable and warranted" according to WHO. SAGE itself adopted an ALARA (as low as reasonably achievable) approach.
3. Yet power companies can seem to take a view that no such consideration at all is necessary. They tend to rely on the easier ICNIRP guidelines and even to avoid mention of the much lower field levels of evidence-based public concern. A current example in North Wales is the Dong Energy proposed cable from the Burbo Bank offshore wind farm. A letter of 15-08-2013 from Welsh Assemble member Mark Isherwood to Denbighshire CC expresses the public concern very well, and is reproduced below at Appendix A.
4. Mark Isherwood's letter refers to Health Impact Assessment (HIA) which is promoted in Wales. Typically for major powerline developments in the rest of the UK there is an Environmental Impact Assessment (EIA) but not an HIA. The EIA is obligatory under EU law, whereas the HIA is not. It is interesting to read Mark Isherwood's comments on HIA and to note the example with windfarms on Lewis in Scotland, where 100 m separation of cables from homes was recommended, though of course the population on Lewis is relatively sparse.
5. A letter of 14-8-2013 from government department DECC announces that the Dong Energy application for CPO powers for substation and cables will go to a public inquiry, not expected to be held until April 2014 "due to inspector availability".
6. Dogger Bank offshore wind developer Forewind has completed pre-application consulting on the Dogger Bank Creyke Beck connection and substation on Humberside and is on track to submit the application by the end of August. The consultations have resulted in a number of cable route changes. The consent decision is expected to take at least a year. Meanwhile the final stages of pre-application consulting on Dogger bank Teesside A & B are expected to be completed this year.
7. The US Council for Agricultural Science and Technology (CAST) Issue Paper 52 of June 2013 on the Precautionary Principle (PP) quaintly illustrates a "Goldilocks strategy" (just the right amount of precaution, neither too little nor too much). So far, so good! But the paper looks like another weapon from the anti-precaution industry.
8. The CAST paper (top right page 5) misrepresents a paragraph of the World Charter for Nature by selective truncated quoting (of only the last 13 words), to make it appear like demanding a ban without any supporting evidence. The full paragraph is
(b) Activities which are likely to pose a significant risk to nature shall be preceded by an exhaustive examination; their proponents shall demonstrate that expected benefits outweigh potential damage to nature, and where potential adverse effects are not fully understood, the activities should not proceed;
The point here is that the activities are already predicated on being "likely to pose a significant risk", so it's far from wanton obstruction of innocent activities. However, the PP does not presume the precautionary measure to be a ban. There may be alternative exposure reduction measures. The World Charter statement went too far in the precautionary direction. Goldilocks is still searching!
APPENDIX A Letter 15-08-2013 from WA member Mark Isherwood
Re: THE DONG ENERGY BURBO BANK OFFSHORE WIND FARM EXTENSION PLANNING APPLICATION: ONSHORE ELECTRICITY CABLES.
I have been contacted by constituents resident on Glascoed Road, St Asaph, which is within the development corridor for the above, who advise that DONG Energy are seeking a CPO from DECC and Planning Consent from Denbighshire County Council for their extension to Burbo Bank offshore wind farm.
I am further advised that DONG Energy are proposing to put high kV underground cables from Burbo Bank Extension Offshore Wind farm to a new onshore substation close to residents. This has generated evidence-based objections to the close proximity of the cables to family homes with resident children (believed to run as close as 3metres).
It is my understanding that although DONG Energy's own application details show magnetic fields greater than 0.4 microtesla (µT) at the proposed location of cables immediately adjacent to residents, they have only considered health effects on the basis of International Commission on Non-Ionizing Radiation Protection (ICNIRP) Industry standards, which are concerned with proven harm, not precaution against possible harm.
'WORLD HEALTH ORGANIZATION INTERNATIONAL AGENCY FOR RESEARCH ON CANCER (IARC) MONOGRAPHS ON THE EVALUATION OF CARCINOGENIC RISKS TO HUMANS' states that "Extremely low-frequency magnetic fields are possibly carcinogenic to humans (Group 2B)" and " Effects in children - In one pooled analysis based on nine well conducted studies, no excess risk was seen for exposure to ELF magnetic fields below 0.4 µT and a twofold excess risk was seen for exposure above 0.4 µT".
In a letter to a Glascoed Road resident dated 7th August 2013, Dong Energy states "the nearest that the cable(s) are actually likely to pass the property within the 25 m cable corridor would be at over 16 m away". However, the 22nd July 2013 'Magnetic Field Calculations Summary' prepared by Tom Dearing, Environmental Consultant, on behalf of Dong Energy, shows a 'magnetic flux density' of 1.09 µT (Scenario 1) or 1.01 µT (Scenario 2), at a distance of 16 m - well in excess of 0.4 µT - and that a distance of 28 m would be needed to bring the 'magnetic flux density' below 0.4 µT.
Serious concerns have therefore been expressed to me regarding EMF (ELECTRIC AND MAGNETIC FIELDS) and recognised health risk associations.
I am informed that residents have met with DONG Energy, but that DONG Energy have to date not offered any improvements with cable location, stating instead that the time scale would not permit delays.
It is felt very strongly by the residents that reassurance will only be achieved by positioning the cables further west than currently proposed. It is understood that the Planning Department at DCC has communicated verbally to DONG Energy that it may be possible to consider a "revision" to the current planning application which may alleviate residents concerns.
I further understand that Neil Walters (DCC Planning Case Officer) has stated that although it should be possible to amend DONG Energy's application and alter the cable route without the need for another application and without incurring time penalties, etc., he has spoken with DONG Energy and they are not prepared to alter the cable route.
When this was referred to Liz Green, Principal Health Impact Assessment Development Officer, Wales Health Impact Assessment Support Unit, she stated "If moving the cables will not incur any time slippage nor re application then I don't see why the cabling cannot be moved".
The precautionary principle is detailed in Article 191 of the Treaty on the Functioning of the European Union (EU).
The EU definition of the precautionary principle states:
"The precautionary principle enables rapid response in the face of a possible danger to human, animal or plant health, or to protect the environment. In particular, where scientific data do not permit a complete evaluation of the risk…..".
According to 'common guidelines on the application of the precautionary principle' established by the EU Commission: "the precautionary principle may be invoked when a phenomenon, product or process may have a dangerous effect, identified by a scientific and objective evaluation, if this evaluation does not allow the risk to be determined with sufficient certainty".
'World Health Organization 2007 Report Environmental Health Criteria 238 EXTREMELY LOW FREQUENCY FIELDS' states "Consistent epidemiological evidence suggests that chronic low intensity ELF magnetic field exposure is associated with an increased risk of childhood leukaemia. However, the evidence for a causal relationship is limited, therefore exposure limits based upon epidemiological evidence are not recommended, but some precautionary measures are warranted".
Health Protection Agency document HPA CRCE NIP 28/01/13 'Planning Act 2008: HPA position in relation to applications for onshore and offshore wind farms' includes in its text:
"There is concern about the possible effects of long-term exposure to electromagnetic fields, including possible carcinogenic effects at levels much lower than those given in the ICNIRP guidelines. In the NRPB advice issued in 2004, it was concluded that the studies that suggest health effects, including those concerning childhood leukaemia, could not be used to derive quantitative guidance on restricting exposure. However, the results of these studies represented uncertainty in the underlying evidence base, and taken together with people's concerns, provided a basis for providing an additional recommendation for Government to consider the need for further precautionary measures, particularly with respect to the exposure of children to power frequency magnetic fields"
"The scientific evidence, as reviewed by HPA, supports the view that precautionary measures should address solely the possible association with childhood leukaemia and not other more speculative health effects. The measures should be proportionate in that overall benefits outweigh the fiscal and social costs, have a convincing evidence base to show that they will be successful in reducing exposure, and be effective in providing reassurance to the public".
I am also advised that the independent EMF expert consulted by residents, Mike O'Carroll, has confirmed that it is reasonable and warranted to exercise precaution. He also states:
"a comment on the Information for Residents…….It is disappointing that the section on EMF refers only to the ICNIRP Guidelines (though they are an important part of the picture) and fails to mention the evidence-based public concern recognised by WHO and IARC and classified as a Class 2B possible human carcinogen in relation to residential average exposures above 0.4 µT. That is a serious omission, because this is what the public concern on EMF is about. The company should have nothing to fear from mentioning (and from being seen to mention rather than being seen to suppress) this formal classification and concern, since it is not an exposure limit or standard. The company could without jeopardy adopt a more considerate approach by recognising these concerns and by adopting an open policy of avoiding positioning cables unnecessarily close to homes where the practical situation permits".
The World Health Organization define health as a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity.
Health Impact Assessment (HIA) may be defined as … a combination of procedures, methods and tools that systematically judges the potential, and sometimes unintended, effects of a policy, plan, programme or project on the health and well-being of a population and the distribution of those effects within the population. HIA identifies appropriate actions to manage those effects.
The Welsh Government has taken a keen strategic policy interest and international lead in HIA (Welsh Assembly Government, 2003; 2007) and is committed to developing its use as a key part of strategies to improve health and reduce inequalities.
Liz Green, Principal Health Impact Assessment Development Officer, Wales Health Impact Assessment Support Unit, has been consulted regarding DONG Energy's application and her response included:
"The Lewis Wind Farm Proposal HIA which was completed by public health specialists in Scotland, does look at the wider determinants of health and specifically refers to the issue of power cables and EMFs. Its recommendations for the developer to follow - see attached - included that the cables be as far away as possible from residential dwellings ('Cables and pylons should be as far from houses as possible. Not less than 100m').
The robust evidence that I have looked at (including WHO guidance) generally demonstrates that EMFs are safe at low levels and from a distance on adults. However, an association of EMFs with the incidence of childhood leukaemia has been highlighted in some studies. I understand that thresholds are not being breached with this proposal but that does not necessarily mean that there will not be any health impacts. In this instance, if the cables remain as planned there will be health and wellbeing impacts on local residents that are avoidable (stress and fear of ill health for example, potential impacts on children) and by providing mitigation and following the precautionary principle they could be alleviated. Any high quality and robust HIA would identify this as a potential health impact based on evidence and provide some form of recommendation for mitigation of this. It would involve all stakeholders (those affected by or have an interest in the proposal) as part of the assessment process and agree realistic and achievable recommendations for action as part of a future Management Plan. It would be reasonable to expect that a HIA would recommend that the evidence and issues be explored further and/or cables be sited away from residential dwellings and be monitored in the future - which is what was included in the Lewis Wind Farm HIA.
Health is a material consideration in planning applications and although HIA is not yet mandatory, If a HIA is completed then the assessment is evidence to be considered by the decision makers in their decision making process".
I would therefore be grateful if you could give your attention to all the above information, apply the precautionary principle to cable location, consider the completion of a HIA (following the Welsh approach) - and/or the delay of any decision until one is done by the developer - and confirm your intended course of action.
Statements made by the editor or by other parties and quoted for information do not necessarily represent the views of Revolt. Criticism of government and industry, and grievances from members of the public, are in the nature of Revolt's work, though we try to give credit where it is due. Revolt is strictly non-party-political and regrets any offence which may be inadvertently caused.
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