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EMF (Electromagnetic Field) Effects and the Precautionary Principle
Nils E. Stolpe/FishNet USA
Copyright 2017 Nils E. Stolpe

http://fishnet-usa.com/

December 20,2017

The following is taken from an OSPAR Commission (https://www.ospar.org/) report from 2008. It clearly shows that at the time when interest in offshore wind turbines was really starting to grow there was very little knowledge of, nor had much significant research been done on, the effects of electromagnetic fields on marine or estuarine species, and what little had been done was on mature organisms, with little or no attention given to immature stages.

Background Document on potential problems associated with power cables other than those for oil and gas activities: Conclusions in regard to electromagnetic fields
Our current knowledge about effects of electromagnetic fields on the marine environment, in particular fauna, is not sufficient. Only a few preliminary conclusions can be reached.

Occurrence of magnetic fields associated with power transmission is best limited by field compensation to be achieved by an appropriate transmission system layout (preference of AC transmission systems or bipolarDC transmission system against monopolar systems). In case of monopolar transmission systems magnetic fields in close vicinity to the cable exceed natural ambient conditions significantly.

Directly generated electric fields are regarded to be controllable by adequate shielding. However, an induced electric field generated by the magnetic field occurs. In case of high current flows during power transmission the electric fields in proximity to the cable significantly exceed values typical under natural conditions.

Simulation studies revealed the potential for induced electric field mitigation by using highly specialized materials with high permeability or conductivity values for armouring of cables.

Development of modern materials with such properties has to be encouraged. Though cable burial will not effectively mitigate against magnetic fields and induced electric fields it is likely to reduce exposure of electromagnetically sensitive species to the strongest electromagnetic fields that exist at the ‘skin’ of the cable owing to the physical barrier of the substratum i.e. the greater distance to the cable, and cable burial should therefore be realized.

There is an apparent lack of information on electromagnetic fields emitted from communication cables (with electric components).

In regard to effects on fauna it can be concluded that there is no doubt that electromagnetic fields are detected by a number of species and that many of these species respond to them. However, threshold values are only available for a few species and it would be premature to treat these values as general thresholds. The significance of the response reactions on both individual and population level is uncertain if not unknown. More field data would be needed to draw firm conclusions but data acquisition under field conditions is complicated. (OSPAR Commission, 2008 – https://www.ospar.org/documents?d=7128)

An electromagnetic field (EMF) is “a field (as around a working computer or a transmitting high-voltage power line) that is made up of associated electric and magnetic components, that results from the motion of an electric charge, and that possesses a definite amount of electromagnetic energy” (Webster’s on-line dictionary). With the potential proliferation of offshore energy, telecommunications and internet infrastructure, (see “Fish Wars” or a Regime Shift in Ocean Governance? At http://www.fishnet-usa.com/Fish%20Wars%20or%20Regime%20Shift.pdf ), we can expect to see a corresponding increase in the propagation of EMFs in the oceans, and particularly in those parts of the oceans adjacent to population centers.

The Bureau of Offshore Energy Management (BOEM) has leased tens of thousands of acres of offshore ocean (for use from below the sea floor to hundreds of feet above the water’s surface) for siting offshore wind turbines, other electrical “generators” and the necessary support and transmission infrastructure. Part of the transmission infrastructure, in fact from the EMF perspective the most significant part, will be the vast network of transmission cables that will crisscross the ocean floors, potentially imposing significant (and perhaps insurmountable) barriers to some of the organisms that either live in proximity to or transit over such networks.

It’s plain from the quotation above that the scientific community didn’t have a clue about what these barriers might be, let alone how significant their impacts on marine fauna.

Several years later, in May of 2011, the U.S. Department of the Interior’s Bureau of Ocean Energy Management (BOEM) received a 169 page report with an additional 250 pages or so of appendices titled Effects of EMFs (Electromagnetic Fields) from Undersea Power Cables on Elasmobranchs and Other Marine Species (https://www.boem.gov/Environmental-Stewardship/Environmental-Studies/Pacific-Region/Studies/2011-09-EMF-Effects.aspx). The study was done for the Pacific OCS Region but wasn’t geographically limited and included an extensive bibliography that appeared to be world-wide in scope.

The Executive Summary starts “anthropogenic electromagnetic fields (EMFs) have been introduced into the marine environment around the world and from a wide variety of sources for well over a century. Despite this, little is known about potential ecological impacts from EMFs.”
From there it goes on for several hundred pages discussing just how much is not known about the effects of these fields on aquatic, estuarine and marine organisms, be they invertebrates, fish, amphibians, reptiles or marine mammals.

For a little bit of history, BOEM was formed during and was a direct result of the political fallout from the BP debacle in the Gulf of Mexico – aka Deepwater Horizon Oil Spill – that began in April of 2010 (and the bureaucratic response of which I wrote about – see NOAA Inaction in the Gulf of Mexico at http://www.fishnet-usa.com/NOAA_Inaction.pdf and Fish and Oil: NOAA’s Attitude Gap at http://www.fishnet-usa.com/FishAndOil.pdf).

Needless to say, some dramatic political intervention was called for, and not surprisingly that intervention resulted in the formation of yet another bureaucracy, the BOEM. But this bureaucracy was supposed to differ from its predecessor agency in more than its name. From BOEM’s current website:

OUR VALUES

Responsible Stewardship: The bureau is responsible for stewardship of U.S. OCS energy and mineral resources, as well as protecting the environment that development of those resources may impact. The resources we manage belong to the American people and future generations of Americans; wise use of and fair return for these resources are foremost in our management efforts.

Science-Informed Decisions: BOEM is committed to using the best available science in bureau decision making. To fill critical gaps in the information needed to inform the wide range of decisions within the bureau, BOEM facilitates world class research by talented scientists in many disciplines. The bureau also employs a significant number of scientists and technical experts across a range of relevant disciplines that provide the foundation of human capital needed to make sound decisions at all levels of the organization.

Integrity and Ethics: As public servants, we adhere to fundamental principles of ethical behavior. The bureau as a whole is committed to conducting its business according to the highest ethical standards. In accordance with the examples set by BOEM leadership, each BOEM employee is expected to conduct their daily operations in a way that demonstrates both professional and personal integrity. This includes a commitment to the highest level of scientific and scholarly integrity.

The following quotes are from the report submitted to BOEM in 2011.

“Studies indicate that sandbar shark also respond to magnetic stimuli. A magnetic sense may assist with seasonal migratory movements of adults and juveniles through coastal waters along the eastern seaboard. Thus, this combination of sensory capabilities and natural history attributes makes the sandbar shark a good example species for potential responses to power transmission cables from offshore wind generation facilities on the US East Coast.” (Page 68)

“Based on evidence for sensitivity to either electric or magnetic fields, fish species from 12 families in 10 orders were targeted for review in this report. This includes 183 species of fish that occur in coastal waters (bottom depth <200 meters) of the continental US. Either direct evidence for these species or evidence for a closely related taxon suggested that these species should be prioritized for consideration of potential sensitivity to EMFs.” (Page 75)

“…in some cases, segments of long power cable runs can transect migration routes, feeding grounds, or spawning sites for those species sensitive to EM fields and alter their normal behavior. Such effects are currently unknown.” (Page 77)

“…if a species uses a magnetic sense for homing capabilities, these capabilities maybe affected in close proximity to certain cable systems.” (Page 77)

“Induced electric fields may also potentially affect functions such as prey detection or social interaction and reproduction.” (Page 78)

“No studies were found that have tested effects of power cable EMFs (AC or DC) on salmon.” (Page 87)

“North Atlantic right whales inhabit coastal waters to at least 200 m, and because they have been observed to be feeding near bottom (180 m), this behavior may expose them to magnetic field levels above their sensitivity threshold. There is no scientific evidence as to what the response to exposures to such a field would be however.” (Page 96)

“Scientific studies examining effects of EMF on marine mammals have not been conducted. However, it is possible that many marine mammals are capable of detecting the magnetic fields resulting from undersea power cables, particularly those species that can detect the Earth’s magnetic field and use it (in addition to other cues) for migration. Responses to exposure to cable-induced magnetic fields are likely to vary depending on the geographic region for the energy project, available habitat for each species, the resulting intensity of the EMF cables orientation and direction combined with local geomagnetic intensity. In addition, depending on the depth of burial, those marine mammals feeding on benthic organisms may excavate or uncover buried power cables. Potential responses from exposure to EMF may include a temporary change in swim direction, a more serious delay to the animal’s migration, possibly stranding if EMF from undersea cables resulted in magnetic minima.” (Page 96)

“Responses to exposure to cable-induced magnetic fields are likely to vary depending on the geographic region for the energy project, available habitat for each species, the resulting intensity of the EMF cables orientation and direction combined with local geomagnetic intensity. In addition, depending on the depth of burial, those marine mammals feeding on benthic organisms may excavate or uncover buried power cables. Potential responses from exposure to EMF may include a temporary change in swim direction, a more serious delay to the animal’s migration, possibly stranding if EMF from undersea cables resulted in magnetic minima.” (Page 98)

“Many displacement and sensory manipulation experiments have proven that changes in field intensity and inclination angle can cause turtles to deviate from their original direction. The mechanisms for sea turtles sensory abilities are not known and to date, there are no data on impacts from magnetic fields from underwater cables for sea turtles.” (Page 105)

“Sea turtles are known to use multiple cues (both geomagnetic and nonmagnetic) for navigation and migration. However, conclusions about the effects of magnetic fields from power cables are still hypothetical as it is not known how sea turtles detect or process fluctuations in the earth’s magnetic field. In addition, some experiments have shown an ability to compensate for “miscues,” so the absolute importance of the geomagnetic field is unclear.” (Page 105)

“No direct evidence of impacts to invertebrates from undersea cable EMFs exists. Few marine invertebrates have ever been evaluated for sensitivity to electric or magnetic fields; and the available data for those that have been studied are limited. In addition, these magnetoorientation studies are focused on the behavior of mobile adults and the effects on their pelagic larval stages are poorly studied. Thus, discussion of potential impacts to invertebrates from anthropogenic EMFs must rely on speculation and very likely overlooks a number of sensitive species.” (Page 115)
“…disorientation within the range of the magnetic field surrounding some DC cables could presumably confuse or delay lobsters. Nonetheless, the (Florida or Caribbean spiny) lobster’s ability to rely on backup orientation and navigation cues and their adaptability to change in magnetic cues is not well known.” (Page 121)

“Acknowledgement of substantial gaps in our understanding of the effects of EMF in the marine environment should not be construed as a recommendation to avoid installation of new undersea cables until these gaps are closed however. The modeling presented in Section 4.1 is representative of the types of existing and proposed cables that are suitable to support the offshore wind (or other types of offshore renewable energy) industry and can be used to develop at least a preliminary understanding of field strengths of proposed cables. Coupled with the available information on the ability of various species to sense these fields, it is evident that there are spatial boundaries surrounding each cable beyond which the fields are unlikely to have an effect on biota. Historical use of undersea power cables (e.g., connecting islands and oilrigs to the mainland, offshore wind projects in Europe) provides no documented evidence in the literature of major impacts to marine species from EMFs although there have been few studies that have actually assessed the interaction between marine organisms and cable EMF. Given that the offshore renewable energy industry in the US is in its infancy, it is reasonable to believe that any potential risks of exposing particularly sensitive species or populations to EMFs from undersea cables can be substantially reduced by careful site selection, mitigation, and an increased knowledge base on the sensitivities and responses of marine species to EMFs to improve siting decisions. The current hierarchy of offshore wind project development anticipated in US waters, with early emphasis on the Mid-Atlantic and New England, allows us to focus on key species and research topics.” (Page 121)

This report demonstrates that no one had much of an idea of what the actual impacts of anthropogenic EMFs would be on estuarine/marine ecosystems even after several more years of intensive planning for and promoting of offshore energy production. So it was with some relief that I read near the top of the listing of BOEM values on their website that “the bureau is responsible for stewardship of U.S. OCS energy and mineral resources, as well as protecting the environment that development of those resources may impact” (my emphasis).

But it seems that to BOEM “protecting the environment” didn’t extend to EMFs. Three years after the above quoted BOEM funded report was completed, in Effects of offshore wind farms on marine wildlife—a generalized impact assessment (Bergström et al, 03/19/14), the authors wrote “there was paucity in studies on cumulative impacts and long-term effects on the food web, as well as on combined effects with other human activities, such as the fisheries. These aspects remain key open issues for a sustainable marine spatial planning (http://iopscience.iop.org/article/10.1088/1748-9326/9/3/034012/meta).

Then in 2016, quoting from A Review of the Evidence of Electromagnetic Field (Emf) Effects on Marine Organisms (Emma B*, Journal of Ecology and Environmental Sciences, 11/28/16) “it was logical to conclude that the worst outcome for the future would be if cable manufacturers disregarded the best available scientific advice regarding the potential effects of subsea cables. Presently, there is insufficient evidence to suggest biological impacts upon marine organisms from EMFs. Nonetheless, there is a significant gap in understanding of any long-term impacts marine organisms might face” (http://www.rroij.com/open-access/a-review-of-the-evidence-of-electromagnetic-field-emf-effects-onmarine-organisms-.pdf).

Apparently, and assuming that Bergström et al and Emma B. completed reasonable reviews of the literature, the people at BOEM haven’t taken their agency’s assurance that it’s personnel would protect the environment as they would like us to think they had, because we seem to know little more about EMF effects now than we did in 2011 (or previously).
Evidently the authors of the BOEM report in 2011 had quite a different perspective on the environmental acceptability of offshore cable installations.

Of course this difference in perspectives brings up the precautionary principle, to wit “when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.” (Wingspread Statement on the Precautionary Principle,1998).

For an interesting discussion of the application of the Precautionary Principle when dealing with human exposure to EMF see the World Health Organization’s The Precautionary Principal and EMF (L.I. Kheifets, http://www.who.int/peh-emf/meetings/southkorea/Leeka_Kheifets_principle_.pdf).

Anyone who is familiar with fisheries management, particularly as it has “evolved” over the last decade or so, is almost certain to be familiar with the Precautionary Principle. As applied to fisheries it means that fishermen should not be allowed to do anything until it is proven beyond a reasonable doubt that what they wish to do won’t affect the fishery they propose to participate in, any other fishery, or the environment of the area where the potentially affected fisheries are located.

This makes it extremely difficult (if not impossible) to develop new fisheries or to expand existing fisheries – but some would argue that’s what fisheries management is for.

As far as the Precautionary Principle as applied to fisheries is concerned, Peter Shelley, Conservation Law Foundation Senior Counsel wrote in a 2009 CLF press release “we are dismayed that the NMFS chose to base its determination on untested hypotheses that leave the future of the wolffish to chance, rather than to use well-recognized principles of precaution to ensure its survival.” In April of 2012 in a CLF blog he wrote “we think catch levels were set too high, too little was done to reduce the growing cod catches of recreational fishermen, and nothing was done to balance fishermen’s economic and social pain by directing the small allocation of Gulf of Maine cod toward coastal fishing boats. The decision of the National Marine Fisheries Service (NMFS) to accept the New England Fishery Management Council’s quota recommendation had little to do with precautionary principles and much to do with politics.” And in the CLF blog Talking Fish in November, 2014, “the precautionary principle should have triggered greater caution by the managers and the fishing industry in the face of mounting uncertainty about the health of the remaining cod biomass but it didn’t. Now, the price has to be paid.” (This isn’t to imply that attempts to limit fishermen or fishing via the Precautionary Principle are limited to Mr. Shelley or the Conservation Law Foundation. To the contrary – and in spite of Mr. Shelley’s attempts to lump fisheries managers in with fishermen as ocean “bad guys,” the (over)application of the Precautionary Principal permeates federal fisheries management at every level, in large part due to strenuous lobbying efforts by foundation funded ENGOs including the CLF.

And yet, in shilling for the recently sunk Cape Wind Project (see What Was Once Hailed as First U.S. Offshore Wind Farm Is No More at https://www.bloomberg.com/news/articles/2017-12-01/cape-wind-developer-terminates-project-opposed-by-kennedys-koch) another CLF release titled Conservation Law Foundation Applauds DPU Conclusion That Cape Wind is in the Public Interest in 2010 stated “the Conservation Law Foundation (CLF) hailed today’s decision by the Massachusetts Department of Public Utilities (DPU) approving a fifteen-year contract for the sale of Cape Wind’s power and renewable energy credits to electric utility National Grid, a crucial step toward advancing the country’s first utility-scale offshore wind farm. The decision, based on extensive expert testimony and other evidence brought forward by supporters and opponents of the Cape Wind offshore wind energy project, reached the important conclusions that Cape Wind’s long-term power purchase agreement is “cost-effective” and “in the public interest,” and will deliver substantial benefits for ratepayers and the Commonwealth. John Kassel, president of CLF, said, “The DPU’s decision to approve the Cape Wind power purchase agreement brings Massachusetts one step closer to realizing the economic and environmental promise of offshore wind energy (https://www.clf.org/newsroom/conservation-law-foundation-applauds-dpu-conclusion-that-cape-wind-in-public-interest/ ).

From the Cape Wind Final Environmental Impact Statement (FEIS at https://www.boem.gov/Cape-Wind-FEIS/) Section 9-2 Lessons Learned From European Wind Farms: (Emphasis added)

“In order to identify possible lessons learned from other offshore wind energy projects, MMS reviewed the monitoring results from a recent study on two demonstration wind farms in Denmark (Horns Rev and Nysted), which have been the subject of research and monitoring programs to examine the potential environmental impacts of offshore wind farm projects. Horns Rev, constructed during the summer of 2002, is sited 8.7 to 12.4 miles (14 to 20 km) off the coast of Denmark in the North Sea, and consists of 80 turbines totaling 160 MW. Nysted was constructed between 2002 and 2003 approximately 6.2 miles (10 km) offshore in the Baltic Sea, and incorporates 72 wind turbines placed in 8 rows of 9 turbines each, with a total installed capacity of 165.5 MW. The monitoring data at both sites consist of three years of baseline monitoring, monitoring during construction, and three years of monitoring during operation. The environmental monitoring program focused primarily on the effects of construction and operation of the offshore wind farms on the infauna, epifauna, and vegetation of the benthic community; on fish, marine mammals and birds; and on peoples’ attitudes towards offshore wind farms locally and nationally….

Overall, the results from the Danish wind farms suggest that with proper siting and placement of turbines, offshore wind farms can be engineered and operated without significant damage to the marine environment and vulnerable species. In general, the monitoring results show that the wind farms seem to pose a low risk to birds, mammals, and fish. The studies stress that appropriate siting is an essential precondition for ensuring limited impact on nature and the environment, and that careful spatial planning is necessary to avoid damaging cumulative impacts. Important differences between the two sites were observed in the results of some studies, suggesting that environmental impacts are likely to vary by location even with careful site planning. Therefore, it is difficult to generalize the results of this monitoring program to potential environmental impacts at other offshore wind sites including the proposed action….

Conclusions reached from the Danish offshore wind farms, therefore, showed generally minimal environmental impacts over the long term at these sites, but enough differences between sites to recommend caution in generalizing too much from these limited studies. New benthic habitats were colonized fairly rapidly, without strong observed effects on the surrounding soft bottom communities. The effects of the offshore wind farms were neutral with regard to fish density, species composition and abundance, showing neither positive nor negative effects. Results from the study on the potential effects of EMFs were inconclusive. Marine mammals, in general, were affected during construction temporarily, but their use of wind farm areas recovered during the operation phase, with the exception of the porpoises at Nysted, which exhibited long-term avoidance of the area. Bird studies showed general avoidance of wind farm areas for migration in most species, as well as avoidance by some species that otherwise use the area as a feeding ground. Collision rates with turbines for a large diving duck, the common eider, during migration, were predicted and observed to be very low….”

The study at Nysted also looked for effects on fish and fish behavior that might be caused by the EMFs created by submarine cables during the operation phase of the wind farm. The Nysted study was not conclusive on this point, but suggests that there is no strong effect. There was some evidence of either avoidance or attraction to the magnetic fields depending on the fish species. The data, however, did not rule out the possibility that physical conditions, not EMFs, along the cables might have caused the observations. Only one species, flounder, showed a correlation between the inferred strength of the EMF and increased avoidance of the cable. It may be invalid, however, to assume that other species do not feel an effect of the EMFs; a weakness of this study was that the EMFs around the cables were not measured directly, and the strength of the fields was inferred from turbine output only, which may not be sensitive enough to produce a correlation.

It appears as if research on the EMF effects of these two “demonstration” wind farms in Norway were as cursory and as inconclusive as those that have been reported by other researchers cited above, being extremely limited temporally and spatially and in species/life stages considered.

Yet the FEIS for the Cape Wind project was apparently good enough for the Conservation Law Foundation, the personnel of which write about their focus on their website “together, we can ensure a healthy future for New England’s ocean. The ocean plays an integral role in New Englanders’ lives, our economy, and our communities. But pollution, overfishing, and climate change threaten its health and our future. CLF has safeguarded New England’s ocean for decades – from blocking oil and gas drilling on Georges Bank, to curbing overfishing, to pioneering smart ocean planning across the region. Today, we’re fighting for a clean, healthy, and productive ocean – for today and for generations to come.”

Obviously to ENGOs like the CLF the precautionary principle doesn’t apply to possible EMF effects in marine or estuarine environments the way it does to limiting fishermen and fishing – or to excoriating fisheries managers who have the temerity to disagree with the CLF in general and Peter Shelley in particular on how to best manage the New England fisheries.

But as anyone with even an elementary understanding of fish, shellfish and fisheries knows, one of main characteristics of many fish stocks is migratory behavior – either North (cold) and South (warm) or inshore and offshore. These migrations are not necessarily confined to adults and are not necessarily accomplished by the critters themselves but may be aided by ocean currents. Can anyone say with any certainty that EMFs spread across these migratory paths won’s interfere with the migratory patterns of recreationally/commercially important species of fish/shellfish, or on other species which they are dependent on? Or won’t interfere with reproductive behavior or larval development? The science on these issues is severely limited, yet the ENGOs and management bodies that are not willing to allow any management actions without “definite” proof that such actions won’t have even a minimal downside are more than willing to permit the installation of extensive networks of EMF producing cables adjacent to or within some of our most productive – and heavily fished – areas. Evidently In these instances the Precautionary Principle isn’t all that important – or seemingly makes no difference at all.