IX. Choosing the Location for Measuring EMF
Mitigation

280 Citizens proposes that the Commission state that the proper location for measuring EMF mitigation is at the edge of the utility ROW,²³ if the public is barred from the ROW. Otherwise, 280 Citizens would measure EMF mitigation from the nearest point to a point that is "routinely" used by people. Although PG&E, SDG&E and Edison's current design guidelines generally use the ROW as the location of measurement, PG&E proposes that measurement occur at the edge of occupied buildings.

For determining the appropriate location for measuring EMF mitigation, we point out that our EMF policy seeks to reduce public EMF exposure at those locations where people tend to live, work, or go to school, and not in every area that may be used by people for short periods of time. Second, as explained above with regard to undeveloped land, it is not in the interest of ratepayers who must bear utility construction costs to speculate about future land uses and pay additional costs that cannot be justified by what is unknown at the time a FMP is developed. As PG&E points out, people contemplating changes in land use will have a choice regarding whether to construct buildings, including homes, next to existing or planned transmission lines or substations.

Generally we favor measurement of EMF mitigation at the ROW as this is the location where the utilities maintain access control; however exceptions may occur. For example, D.04-08-046 directed PG&E to strategically locate portions of the Jefferson-Martin transmission line at least 34 feet from occupied buildings where feasible, even if the EMF reduction was less than 15%.²⁴ In ordering this line location, we noted that the strategic line placement generally would entail minimal costs,²⁵ and in this way we balanced slightly greater construction costs against unique circumstances.

Consistent with our policy stated above that FMP should not include low-cost mitigation for undeveloped land, measuring EMF mitigation at the ROW should not apply to agricultural, rural and undeveloped land where people can make choices about future construction and decide whether they choose to permanently live and work in these areas. For land uses in which rural housing or schools exist, we expect utilities to treat these locations as if the area was an urban school or residential location. As we have stated elsewhere, this policy applies only to consideration of low-cost mitigation measures. No cost mitigation measures that currently exist, or which may result from the recommendations of the utility workshop ordered in this decision should always be applied in all locations, including undeveloped land.

²³ SDG&E points out that the EMF measurement location was as a result of workshops that followed the adoption of D.93-11-013.

²⁴ Parties disagree whether the use of a 15% reduction factor is a significant measure of EMF mitigation. CCAE and FUND argue that absolute measures of EMF are necessary to determine meaningful mitigation. However, this proposal is based on numeric measures of EMF, an issue not considered in this proceeding. As no party has proposed changes in use of the 15% factor, we find no reason to change our use of 15% as a factor for measuring significant EMF mitigation.

²⁵ D.04-08-046, mimeo., p. 107.