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REVOLT Powerline Concerns Health Hazards Need UK Energy Policy

City of Lincoln Local Plan Public Inquiry

Proof of Evidence of M J O'Carroll
14 April 1997

City of Lincoln Local Plan Public Inquiry

Proof of Evidence of M J O'Carroll  14 April 1997


1. Résumé of M J O'Carroll MA MSc PhD CMath FIMA FRSA

1.1 I hold the MA degree of Cambridge University in mathematics with physics, an MSc in mathematical existence theory and a PhD in computational fluid dynamics.

1.2 I am a chartered mathematician and a Fellow of the Institute of Mathematics and its Applications. My research, publications and consultancy have been mainly in numerical analysis and computational mechanics but have embraced other fields including formal logic, applied statistics, energy and epidemiology. I have given evidence at public inquiries on environmental and health aspects of power lines.

1.3 I am Emeritus Professor at the University of Sunderland, where I recently retired as Pro Vice-Chancellor. I am a member of the Northern Epidemiology Group. I am Chairman of Rural England Versus Overhead Line Transmission, which opposes the major Yorkshire grid development and promotes a co-ordinated UK energy distribution policy.


2. Scope of this evidence

2.1 This evidence relates to Policy 39D (High Voltage Lines), electromagnetic fields (EMFs), health implications and prudent avoidance. Amenity is not included. A full scientific inquiry would not be appropriate in these proceedings. A relevant summary paper for the non-specialist is included as Appendix 1. It is almost six months old but remains valid and underpins my evidence.

3. Assessment of the scientific evidence

3.1 There is a large body of evidence and comment on possible health effects of EMFs. Terms such as "weak evidence", "persuasive" and "suggestive" are used without any scientific definition. There is a wide range of possible levels of evidence from the spurious or frivolous up to evidence accepted by official bodies as "proof" of cause or "established" cause or risk. The Bradford-Hill criteria are tentative guidelines for establishing cause. They are neither necessary nor sufficient, but are based broadly on statistical association together with a plausible biological mechanism. Once cause is "established", it is generally treated as certain, so that risk calculations are then made on the basis of incidence in the population. When the evidence falls short of establishing cause, the WHO use the term "uncertain hazard". Uncertainty in causation is not quantified, and so risk analysis is usually only applied to established causes.

3.2 The evidence on EMFs from powerlines falls short of establishing cause of ill health. There is evidence about many minor and major ill effects, but they are not well enough researched to be established. My own direct observations suggest that minor but debilitating effects, principally headaches and sleeplessness, may affect a substantial minority of people exposed, but research has concentrated on cancer. The most significant evidence concerns childhood leukaemia.

3.3 The evidence relating EMFs to childhood leukaemia is much more than spurious or frivolous. "Significance" is a well defined statistical term. The key evidence is significant at a level of 99.5%, some ten times stronger than the conventional 95% required for this term. NRPB has recognised "some evidence to suggest the possibility (of cause of cancer) exists" and calls for urgent research. Its Director has stated "the possibility that EMFs may cause cancer cannot, however, be dismissed" (Radiation Protection Bulletin 152, 1994, page 3). While NRPB finds "no persuasive biological evidence", potential mechanisms for EMFs to cause cancer have been identified, and cause by EMFs remains the most likely explanation for the observed increased incidence of cases.

4. Prudent avoidance and precaution

4.1 Appendix 2 gives an outline and definition of prudent avoidance, which reflects the "precautionary principle" enshrined in EU law and considered in Mr Judd's evidence. The "background paper" referred to is Appendix 1.

4.2 The precautionary principle is a response to uncertainty. By definition it applies only to uncertain hazards. The UK interpretation in This Common Inheritance refers to "significant risks ... even where scientific knowledge is not conclusive" and "good grounds for judging ...". The Sustainable Development document rejects "precipitate action on the basis of inadequate evidence". The Calderdale inspector's report calls for "reasonable grounds to suspect that a risk to health is likely to arise". Note that no evidence was advanced to the Calderdale inquiry to support the concerns. In my opinion the evidence summarised here does support such concerns and presents reasonable grounds for suspicion. Given that important research results are expected in the next two years, a holding policy subject to review would be prudent and not precipitate. The Gateshead case mentioned by Mr Judd is not directly comparable.

4.3 The Radiological Protection Act 1970 (see Appendix 3) established the NRPB. Its functions include advising local and national government on radiation hazards, including non-ionising EMFs by order of Secretary of State (S1 (6)). Councils may consider its advice directly, not only through national government interpretations. NRPB does not recommend prudent avoidance, but does not reject it. Government statements, e.g. Mr Sackville's response in Hansard 21.2.94, have unreasonably taken the absence of recommendation to support rejecting prudent avoidance.

4.4 NRPB has rejected "quantitative restrictions on human exposure" to powerline EMFs, as in 5.10 of Dr Male's proof. This however refers to mandatory restrictions supported by established cause, and is beyond the realm of precautionary policy. I do not recognise the wording of Dr Male's 5.13 referring to restrictions on development, and wonder if this is his wording and not NRPB's.

4.5 Local authorities should be entitled to some discretion having regard to formal guidance and advice. This would not be "contravening current practice of formulating and disseminating policy from Central Government downwards" as in 2.4 of Mr Judd's proof. It would be unreasonable to deny an authority discretion simply because RPG8 "does not suggest any policy" in support, as Mr Judd's 3.1. Policy 39D is not in conflict with formal guidance or advice. Discretion was used to exclude beef from school meals even against advice that beef was safe.

4.6 Policy 39D reflects public concern which in my opinion is justified by the evidence albeit short of establishing cause. The court's decision in Mr Judd's 4.13 would then endorse such concern as a material consideration. The public concern is not frivolous and it has been firmly endorsed in the European Parliament Resolution A3-0238/94 of 5.5.94 and elsewhere.

5. Comparison with other hazards

5.1 Attention is drawn to the comparisons with passive smoking and CJD in Appendix 1 section 12 and in Appendix 2. Those hazards present weaker evidence than EMFs. The government's SBO ban in 1989 is a precedent for prudent avoidance, on far weaker grounds than we have with EMFs, which is now regarded as crucial.

6. Official and industrial fallibility

6.1 Government views, and even pronouncements of government scientific advisory bodies, deserve critical appraisal. They are not infallible and may be ultra cautious where costs are implied. Industry views are directly self interested and should not be expected to be balanced. Some examples may be found in the BSE-CJD affair, where strenuous denials supported by government scientists had later to be reversed, and with Gulf War Syndrome.

6.2 A form of words used in government statements on EMFs, e.g. Hansard 23.3.95 as Dr Male's Appendix 7, is "The significance of an epidemiological study depends, among other things, on the strength of the association, the presence of a dose-relationship, supporting experimental evidence and a credible biological explanation. These tests for causality are not satisfied ...". The features mentioned are some of the Bradford-Hill criteria, but they are not tests and they are neither necessary nor sufficient. "Significance" is not used in the statistical sense and is not defined scientifically. While this is misleading in over-emphasising the criteria, the IEE, a professional body influenced by industry, is over-zealous and wrong (Appendix 1 section 13). NGC's zeal in monitoring and opposing local policies, and winning a false precedent seemingly unopposed in Calderdale, is financial self-interest which might be ultra vires in a public body.

6.3 Government statements have unreasonably departed from NRPB's position on prudent avoidance, as explained in 4.3 above, and it seems Dr Male has done so (4.4 above). Other fallacies perpetrated in denial of health effects are summarised in Appendix 1 section 11, namely geomagnetic comparison, electrical noise, direct hit limitations and large scale current limitations. A fifth can now be added in NRPB's hasty and erroneous dismissal of the radon effect (Appendix 4).

7. Conclusion

7.1 While the stringent requirements of establishing cause are not met, the extensive scientific evidence can not be dismissed and gives rational grounds for suspicion of adverse health effects from exposure to EMFs from powerlines. While scientific advice from NRPB is sometimes misrepresented or erroneously over-dismissive, it does not reject prudent avoidance. Policy 39D is not in conflict with formal guidance or advice, is prudent and not precipitate, and should fall within the scope of the council's discretion.

M J O'Carroll 14.4.97

City of Lincoln Local Plan Public Inquiry

Appendices  to Proof of Evidence of M J O'Carroll  14 April 1997

Appendix 1    Public health concern about supply EMF, November 1996

Appendix 2    Prudent avoidance, 28.11.96

Appendix 3    Extract from Radiological Protection Act 1970

Appendix 4    The radon effect in EMFs, April 1997

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