VI. Modeling EMF Mitigation

CCAE and FUND and 280 Citizens recommend that Commission EMF policies measure actual EMF on constructed transmission lines and thus validate whether persons living, working or attending schools near power lines are exposed to particular levels of EMF. CCAE and FUND argue that it is irrelevant whether particular EMF reductions have resulted; instead, persons need to know absolute EMF exposure values. As an additional criticism of utility modeling, CCAE and FUND recommend that EMF modeling assume maximum peak power flow rather than projected peak loads in the year of construction.

Our review of the modeling methodology provided in the utility design guidelines indicates that it accomplishes its purpose, which is to measure the relative differences between alternative mitigation measures. Thus, the modeling indicates relative differences in magnetic field reductions between different transmission line construction methods, but does not measure actual environmental magnetic fields. In the same way, these relative differences in mitigation measures will be evident regardless of whether a maximum peak or a projected peak is used for the comparisons.

It is also true that post construction measurement of EMF in the field cannot indicate the effectiveness of mitigation measures used as it would be extremely difficult to eliminate all other EMF sources. We note that ordering EMF field measurements would lead to arguments regarding the risks associated with absolute EMF values and an attempt to determine health based standards, an issue excluded from this proceeding.