VI. Next Steps

The DHS, along with the Commission, has spent almost nine years and almost $10 million on reviewing existing scientific data, developing policy research and promoting public education regarding EMF exposure risk. Nonetheless, the DHS report does not conclusively associate or find direct causation of disease or cancer as a result of exposure to EMFs. The Commission has made a good faith effort to gather and process the available scientific knowledge regarding exposure to EMFs and their anthropogenic effects. Some nine years later we are not in a position develop a specific numerical standard or threshold based on the existing science regarding human health impacts from exposure to EMFs. Given the continued scientific uncertainty associated EMFs we think it is appropriate to continue with the Commission's existing EMF mitigation policy of Prudent Avoidance. This line of reasoning appears to be supported by the 2002 DHS report that declines to make recommendations regarding the policy implications from its study of EMF exposure. The DHS report included known national and international studies and recent epidemiological studies. The Commission will consider new scientific data in this proceeding as it becomes available, but currently will focus its attention on improving the existing EMF mitigation policy. We believe that the Commission's existing policy can be updated where technically feasible and cost-effective. Further, we believe that implementation of the Commission's existing EMF mitigation policies could be further improved.

Public concern about EMFs and the activities utilities should undertake in response to those concerns continues unabated. In numerous transmission siting proceedings, such as the recent matter involving the Jefferson-Martin project (A.02-09-043) and the Mission-Miguel project (A.02-07-022) some parties expressed great concern regarding potential health effects from EMF exposure. Participants expressed special concerns about exposures to schools, day care centers, and residences. Intervenors also often object to the way that the utility applies the 4% rule in establishing its EMF exposure mitigation strategy. It appears that the Commission could review its existing framework of EMF guidelines to determine if there are additional mitigation measures that are cost-effective and technically feasible which could be used to reduce public exposure to EMF impacts from electric transmission projects. While the Commission is considering whether additional mitigation measures are necessary, it also should consider better methods to require the utilities to implement the existing "low-cost/no-cost" EMF mitigation policy to ensure that public exposure is minimized where possible and reasonable.