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
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
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
4.3 The Radiological Protection Act 1970 (see Appendix 3) established the
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
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).
7.1 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,