The Commission first established EMF policies in D.93-11-013. In our recent review of EMF issues, the Commission stated in D.06-01-042 that, "at this time we are unable to determine whether there is a significant scientifically verifiable relationship between EMF exposure and negative health consequences." We affirmed in D.06-01-042 that the Commission's EMF policy is one of prudent avoidance, with application of low-cost/no-cost mitigation measures to reduce EMF exposure for new and upgraded utility transmission and substation projects. The Commission has adopted a benchmark of 4% of total project cost for low-cost EMF mitigation measures, with flexibility to allow expenditures above the 4% benchmark if justified by a project's unique circumstances. In D.06-01-042, the Commission stated that, as a guideline, low-cost EMF mitigation measures should reduce EMF levels by at least 15% at the utility right of way.
The Final EIR/EIS provides information regarding EMF associated with the proposed project. It does not consider magnetic fields20 in the context of CEQA or NEPA and determination of environmental impact because there is no agreement among scientists that EMF creates a potential health risk, and there are no defined or adopted CEQA or NEPA standards for defining health risk from EMF.
B. EMF Management Plan for the Antelope-Pardee Transmission Project
Consistent with its obligations under G.O. 131-D, SCE included, with its application, an EMF Field Management Plan.21 In this plan, SCE proposes to incorporate various no-cost mitigation measures to reduce field levels. It also identifies, but does not propose to adopt, certain low-cost mitigation measures. The proposed plan does not analyze potential impacts across each of the various alternative route alignments identified in the Draft EIR/EIS and carried forward in the FEIR.
As discussed elsewhere in this order, we authorize SCE to construct the Antelope-Pardee Transmission Project along an alignment that differs significantly from that originally proposed by the utility. With these modifications to the Antelope-Pardee Transmission Project, SCE should amend its EMF management plan as needed to apply its no-cost EMF management techniques to the approved project.
Consistent with D.06-01-042 and D.93-11-013, we also require that SCE undertake low-cost EMF mitigation. Where such design modifications are consistent with our low-cost policy, SCE should increase tower and conductor heights by 20 feet along any portions of the transmission corridor where there are residences within 50 feet of the side of the right of way closest to the new 500 kV transmission lines. SCE has established that this design modification would reduce magnetic fields by 15% at the edge of the right of way.
In its existing study, SCE rejects this option for unspecified environmental and engineering reasons. We do not believe that the potential conflict of this low-cost EMF mitigation measure with environmental mitigation efforts would be significant. Few of the areas where EMF mitigation will occur are completely flat, and the towers and conductors would be difficult to line up due to even small elevation changes between existing and new towers. With tower heights of 150 feet, a 20-foot height increase for towers and conductors is unlikely to be noticeable to most observers.
We require that SCE apply this low-cost EMF mitigation measure where there are existing residential properties and also where development of new residences is underway at the time that SCE undertakes final project design. Consistent with guidance in D.06-01-042, we do not require that SCE attempt to determine possible future uses of undeveloped land. If applicable, SCE would not be required to raise tower heights near any residential properties that will be acquired and converted from residential use in order to allow construction of the Antelope-Pardee Transmission Project.
The cost of the adopted EMF mitigation measure may be less than SCE estimated along its proposed route. In any event, it is likely that the cost will be much less than the Commission's 4% benchmark for low-cost EMF mitigation. As described in this order, SCE may seek an increase in the approved maximum cost of the Antelope-Pardee Transmission Project if the adopted low-cost EMF mitigation measure causes the cost cap to be exceeded.
20 Because electric fields are shielded effectively by materials such as trees and walls, the emphasis in the Commission's consideration of EMF is on exposure to magnetic fields.
21 A.04-12-038, Appendix B.