Health Impact Concerns from Data Supplied With the Badger Hollow Wind Power Plant Proposal (Docket, 9827-CE-100 )

Affected Landowner Comments Due Dec. 20, 2024. Instructions.

On November 21, 2024, the Public Service Commission and Department of Natural Resources of Wisconsin sent this IMPACT COMMENT OPPORTUNITY NOTICE to residents, local governments, counties, schools and other organizations that would be affected by the construction and operation of the 24.5 square mile, Badger Hollow wind power plant in the Towns of Clifton, Eden, Linden, Mifflin, Wingville, Lima and Belmont in Iowa, Grant and Lafayette Counties, Wisconsin.

“[T]he agencies are requesting comments from the public to help the state agencies determine the potential impacts associated with the project and the scope of the Environmental Assessment (EA). . . Comments for the EA scoping are most effective when they discuss:

Any potential human and environmental impacts of the proposed wind generation project; or

Any specific actions or changes to the proposed project that might minimize or mitigate the potential impacts of the project.“

Impacted residents may find benefit in reviewing the following impact estimations from Invenergy’s commissioned, health-related analyses, Appendix Y-Noise; Appendix Z-Shadow Flicker; Appendix Y-EMF, and maps in Figure 4.1.2 and Figure 4.4.1 .

IMPORTANT UPDATE!! Due to determined project infrastructure layout changes in January 2025, the above referenced appendices and associated maps have been changed– particularly proposed and alternative wind turbine sites East of Livingston. See revised Appendixes U, H, Z, Y, X & L in the application docket, here. These changes affect some of the resident impacts listed in the below analyses.

• ~370 Residents Predicted to Experience Audible Noise Under Quiet Conditions
• Nauseogenic Illnesses from wind turbine air pulses documented up to distances of 4 miles (Vertigo, dizziness, headaches, nausea, tiredness, irritation, uneasiness and difficulties with concentration.
• ~100 Residents predicted to be subject to at least 10 Shadow Flicker Hours per year with some residences undergoing 48 hours per year. Approximately 452 residencies would be subject to at least one minute of Shadow Flicker per year with a mean of 3 hours and 20 minutes per year.
• ~22 miles of vegetation management on easements through Agricultural Fields, Pastures
• 25 Stream Crossings
• Electromagnetic Field Concerns From ~22 miles of buried 34,500 volt (34.5 kV) connection lines.

Step 1. Find Your Assigned Residency Number to Assess Your Exposure to the above, Negative Impacts.

A. Click on the below map to open it in another window and zoom into it or, click on one of these links if you live in a village Invenergy has evaluated: Cobb, Livingston and Rewey. WRITE DOWN YOUR RESIDENT NUMBER (eg.”R-0018″). Iowa Grant High School residency numbers are R-1708 & R-1709

Step 2. Determine the Predicted, Audible Noise Impacts For Your Location

Click-on the two, below lists and search for your Resident/Farm number. If your house is not included, your exposure to audible wind turbine is probably at the lower range of concern.

56 Most Noise-Affected Residents

313 Additional Noise-Affected Residents

Step 3. Determine the Nauseogenic Health Risks for Your Location

Refer to the 2-MIle and 4-Mile impact maps, below. Darker shaded areas reflect higher concentrations of air pulses– the extremely rapid changes in barometric air pressure that produce a variety of short and long-term health risks.

All persons are not subject to immediate negative impacts including, vertigo, dizziness, headaches, nausea, tiredness, irritation, uneasiness and difficulties to concentrate, but person who experience motion sicknesses frequently are. The slower blade rotations from the extremely large, 6.2 MW turbines are expected to increase health risks. Negative health impacts from the smaller, Red Barn turbines near Montfort/Livingston, have already been documented at a distance of 4 miles.

Affected schools, places of worship and assisted living/nursing home sites have been added to the 4 Mile radius impact map from Invenergy’s Figure 4.1.7.2. Iowa Grant High School residency numbers are R-1708 & R-1709

Step 4. Determine Shadow Flicker Health Risks for Your Location

The experience of Shadow Flicker,  the effect of pulsating light and shadow is produced by the sun shining through rotating wind turbine blades. The developer proposing the Badger Hollow wind power plant has predicted the number of hours per year that residents in the impact area can expect to experience Shadow Flicker. A list of 234 farm/residential locations predicted to be subject to at least 5 hours of Shadow Flicker per year has been provided, below. One can also use one’s residence number and the below map to help assess one’s risk exposure. If you are not aware of the experience of Shadow Flicker, this video produced at a Wisconsin location provides useful documentation.

Step 5. Determine Low Frequency, Electromagnetic Field Health Risks for Your Location

There is continuing controversy about how to test and predict EMF health impacts. Developers favor short-term sampling, lab-based modeling while medical findings incorporate long-term field/patient observations. As for potential EMF impacts with the Badger Hollow Wind proposal (BHW), it is important to note the lack of short and long-term studies of close to the surface, buried, 34.5 kV “connection” transmission lines. Invenergy’s study for BHW proposes to bury 1 to 5 circuits of these high voltage/high current lines only 4.5 feet below pastures, croplands and other areas– creating about 22 miles of 20-100 foot wide impact swaths. Further, the lab analysis suggests each of these connection line circuits would produce continuous EMF levels to 10 milliGauss– the level of radiation emitted by the average microwave oven at 2 feet.

In direct testimony filed before the Minnesota Public Utility Commission, Dr. David Carpenter accounts for, “strong scientific evidence that exposure to magnetic fields from power lines greater than 4 milliGauss (“mG”) is associated with an elevated risk of childhood leukemia” based on his epidemiological research including patient experiences. While communities await long-term field studies on buried 34.5 kV lines, Dr. Carpenter warns, “there is sufficient scientific evidence to cause concern about leukemia risks at [sustained] exposures above 2 mG.”

This PSC WI Publication has considerable info on EMH health studies and origins of epidemiological research.

The below graphic was made from data supplied in Invenergy’s commissioned EMF analysis for BHW.

All studies seem to agree that steady, close-range exposure to EMF is needed to produce higher end risks. Below is a list of BHW residency numbers with closer proximities to proposed, buried, 34.5 kV collection lines.

On November 21, 2024, the Public Service Commission and Department of Natural Resources of Wisconsin sent this COMMENT OPPORTUNITY NOTICE to residents affected by the Badger Hollow wind power plant proposal. The facility would install about 19, 656′ tall wind turbines and 22 miles of transmission lines with health and environmental impacts. Some of these negative impacts been estimated and are accessible in Invenergy’s commissioned studies: Appendix Y-Noise; Appendix Z-Shadow Flicker; Appendix W-EMF, and maps in Figure 4.1.2 and Figure 4.4.1 .

• ~370 Residents Predicted to Experience Audible Noise Under Quiet Conditions
• Nauseogenic Illnesses from wind turbine air pulses documented up to distances of 4 miles (Vertigo, dizziness, headaches, nausea, tiredness, irritation, uneasiness and difficulties with concentration.
• ~100 Residents predicted to be subject to at least 10 Shadow Flicker Hours per year with some residences undergoing 48 hours per year. Approximately 452 residencies would be subject to at least one minute of Shadow Flicker per year with a mean of 3 hours and 20 minutes per year.
• ~22 miles of vegetation management on easements through Agricultural Fields, Pastures
• 25 Stream Crossings
• Electromagnetic Field Concerns From 22 miles of buried transmission lines.

The PSC Notice Explains:

“[T]he agencies are requesting comments from the public to help the state agencies determine the potential impacts associated with the project. . . Comments for the EA scoping are most effective when they discuss:

Any potential human and environmental impacts of the proposed wind generation project; or

Any specific actions or changes to the proposed project that might minimize or mitigate the potential impacts of the project.“

“The deadline for submitting Environmental Review Scoping Comments is Friday, December 20, 2024

1. By written letter mailed to Olivia Poelmann PSC Wisconsin, Docket 2817-CE-100, P.O. Box 7854, Madison, WI 53707-7854 [ And through email at olivia.poelmann@wisconsin.gov where attachments may be added ]

2. Through the Commission’s, On-Line comment form accessible at: https://apps.psc.wi.gov/ERF/ERF/comment/filecomment.aspx?util=9827&case=CE&num=100

Notes: (A) One can file comments with text and inserted images using a writing program and exported as a “PDF” document. The PDF is up-loaded to the case docket by creating an PSC account and following these document uploading steps . Make sure the file is uploaded to the docket before the published deadline. (B) Questions about scoping process and how to find topics can be directed to: Olivia Poelmann, Badger Hollow Wind Environment Assessment Coordinator at olivia.poelmann@wisconsin.gov or via phone, (608) 266-5528.

https://bit.ly/Newspapers-SW-WI

In 2009, The Wisconsin Wind Siting Council was established in state law WI ACT 40 for these purposes and terms:

196.378(4g)(e)  The Wind Siting Council shall survey the peer-reviewed scientific research regarding the health impacts of wind energy systems and study state and national regulatory developments regarding the siting of wind energy systems. No later than October 1, 2014, and every 5 years thereafter, the wind siting council shall submit a report to the chief clerk of each house of the legislature, for distribution to the appropriate standing committees under s. 13.172 (3), describing the research and regulatory developments and including any recommendations of the council for legislation that is based on the research and regulatory developments.

Despite a steady increase in pending wind power plant proposals including a 600 MW, ~400 square mile plant in SW Wisconsin that would be 3.7 times larger than any prior state wind facility, the Public Service Commission of Wisconsin failed to convene the Wind Siting Council by the legislation-specified, “no later” date of October 1, 2019.  

The quasi-Council that the Commission marshaled and charged with duties four years late (in July, 2023), failed to include required membership. Most glaringly, the body charged with recommending needed changes in Chapter PSC 128 regulating state wind power plants lacked the expert essential for council assessment of “peer-reviewed scientific research regarding the health impacts of wind energy systems,” which law designates:

“One member who is a University of Wisconsin System faculty member with expertise regarding the health impacts of wind energy systems .

Wis. Chapter 15.797

Unfortunately, the Commission has, instead, tried substituting faculty persons with no health or medical backgrounds. As a result, when Council members make motions to introduce studies, articles and other considerations of health and safety impacts not acknowledged in 2014, there is no expert on the Council with professional reputation at risk or professional avenues to pursue to conduct basic business such as:

• Answer questions posed by council members
• Make researched, clarifications about study findings
• Proof read PSC staff accounts of medical studies beyond their expertise
  • Move the consideration of impacts from the much larger and more powerful turbines forward.

The detrimental impact on the Council can no longer be pushed aside.

In 2023 the US Department of Energy released an agency-sponsored study accounting for larger setback distances in use with popularly used, larger, wind turbines ranging from 3.2 to 5.8 MW. Council members did not become aware of this extremely rare report until an arbitrary deadline for study submission had passed. Rather than make accommodations to insert this single report pertaining to vastly changed technologies, Wind industry appointees and members in broad support of wind development voted to reject inclusion of the study on mere basis of late submission by narrow margin.

If, at the end of a thorough process, no changes in PSC 128 setback distances or other protections are made, the council, the legislature and the citizens of Wisconsin have lost nothing by the delayed report. But rather than pausing and finding a way to meet the legislative requirements, recent minutes indicate that the Council Chair is hurrying to “finalize the report, in total, for April [2024].”

Consistent with verbal accounts of Council members representing landowner and community interests, an agenda item addressing the newer, more powerful and taller wind turbines being proposed in Wisconsin has yet to be scheduled.

If submitted in April, the Wisconsin Wind Siting Council’s report to the state legislature report would unacceptably lack:

• Input from a medical professional with expertise regarding the health impacts of wind energy systems.
  
• Informed acknowledgment of, not to mention appropriate regulation for the much larger and more powerful wind turbines being presently proposed in Wisconsin.
  
• Incorporation of the US Department of Energy’s sponsored study concerning much larger setbacks being used to meet acoustic noise standards set for much smaller wind turbines
  
• Incorporation of fundamental infrasound data for the larger turbines.
  
• Studies the Council has not yet considered taking up in their impactful decision making included:  

Effects of land-based wind turbine upsizing on community sound levels and power and energy density, Ben Hoen, Ryan Darlow, Ryan Haac, Joseph Rand, Ken Kaliski, January 2023 

Symptoms intuitively associated with wind turbine infrasound, Anu W. Turunen, Pekka Tiittanen, Tarja Yli-Tuomi, Pekka Taimisto, Timo Lanki, 2021

Does Stochastic and Modulated Wind Turbine Infrasound Affect Human Mental Performance Compared to Steady Signals without Modulation? Results of a Pilot Study, Paweł Małecki, Małgorzata Pawlaczyk-Łuszczynska, Tadeusz Wszołek, Anna Preis, Maciej Kłaczynski, Adam Dudarewicz, Paweł Pawlik, Bartłomiej Stepien ́and Dominik Mleczko,  2023

Health Effects Related to Wind Turbine Sound: An Update, Irene van Kamp and Frits van den Berg, 2021

Self-reported health in the vicinity of five wind power production areas in Finland, 
Anu W. Turunen, Pekka Tiittanen, Tarja Yli-Tuomi, Pekka Taimisto, Timo Lanki, 2021

Commercial wind turbines and residential home values: New evidence from the universe of land-based wind projects in the United States, 
Eric J. Brunner, Ben Hoen, Joe Rand, David Schwegman, 2023

Property value impacts of commercial-scale solar energy in Massachusetts and Rhode Island, 
Vasundhara Gaur and Corey Lang, Department of Environmental and Natural Resource Economics University of Rhode Island, 2021 

Visualizing Occupied Dwelling Impact Differences between Wisconsin’s 2014, 1250′ setback and the 2023 NREL-Sponsored Study’s Assumed 4,560′ setback distance for 3.4 MW Turbines.

APPROXIMATELY 392 DWELLINGS LOCATED WITHIN 1 MILE OF WIND TURBINES WOULD BECOME SUBJECT TO INFRASOUND IMPACTS PRODUCING HEALTH RISKS FOR A PERCENTAGE OF RESIDENTS. (Dwelling figures ascertained from Project “Setback” Maps on pdf pages 63, 65 & 67 in the Whitetail Wind Application)/

• APPROXIMATELY 392 DWELLINGS WOULD BE LOCATED WITHIN 1 MILE OF WIND TURBINES AND BECOME SUBJECT TO INFRASOUND/AIR PRESSURE PULSES CAPABLE OF PRODUCING UNDESIRABLE HEALTH IMPACTS FOR A PERCENTAGE OF RESIDENTS.
  

• A MAY, 2023 STUDY SPONSORED BY THE U.S. DEPARTMENT OF ENERGY RECOMMENDS AN AVERAGE SETBACK DISTANCE OF 4,560 FEET (BEIGE AREAS) FOR WIND TURBINES LIKE THOSE PROPOSED BY THE MERCHANT UTILITY DEVELOPER TO SURROUNDING LIVINGSTON, WISCONSIN.* The 3.7 greater distance compared to the 1250’ used by the developer significantly reduces exposure to sound and “SPL related requirements.” The discouraged beige impact areas include about 390 dwellings and most of the Village. *The specified GE 3.4-140 turbines align with the 1.39 km average setback for the “Future with STE” scenario. See “Effects of land-based wind turbine upsizing on community sound levels and power and energy density,” by Lawrence Berkeley National Laboratory, Ben Hoen, Ryan Darlow, Ryan Haac, Joseph Rand and Ken Kaliski. May, 2023. Accessible at: https://bit.ly/4560ft .

Informed landowners in Iowa, Grant and Lafayette Counties have the option to consider working together to prevent some industrial-scale wind turbines from being included.

Each of the approximately 150 wind turbines in the Uplands power plant must be connected to expansive transmission networks comprised of dozens of 34,500 volt high voltage “connector lines. These lines that can be buried or carried on poles hold considerably more power than the existing distribution lines in the area.

As diagramed below, wind power plants require a large number of high voltage “Collection” lines that converge at Project Substations. The power from the Uplands Project Substations would then be transported through 41 miles of large-scale, high voltage, 345 kV transmission “Tie Lines” similar to the recently constructed and highly controversial Cardinal Hickory Creek (CHC) Transmission line. But unlike CHC, most of the 345 kV Tie Lines and 34.5 kV Connector Lines for Uplands would not follow pathways of existing transmission but rather new swaths across the properties of landowners who grant easements through “good neighbor” or other contracts.

When landowners choose to not provide access for these transmission facilities, it stands discourage the inclusion of nearby wind turbines or even more infrastructure.

[Below filing from the Public Service Commission of Wisconsin Docket 9300-WF-2023, by Ben Hoffman, October 3, 2023.]

Subject: Docket ID: 9300-WF-2023
Required Notices and Filings under Wis. Admin. Code ch. PSC 128 Related to Wind Siting for CY 2023 PSC REF # 480525

Uplands Wind LLC (Pattern Energy) submitted a 180 day Pre-Application Notice for the proposed Uplands Wind Project on September 27th 2023. The project, proposed to be located in the Wisconsin Counties of Iowa, Lafayette, and Grant, is a 600-megawatt (MW) wind energy facility requiring a Certificate of Public Convenience and Necessity (CPCN) under Wis. Stat. § 196.491 (3). Having proposed turbine heights greater than 600 feet, Pattern Energy is required to submit this Pre-Application Notice in order to comply with state law.

• –  Per Wis. Admin. Code PSC 128.01 (26), “Wind Energy System Facility” is defined as: “any component of a wind energy system, such as a wind turbine, collector circuit, access road, electric system interconnection facility or operation and maintenance facility.”
• –  Per Wis. Admin. Code PSC 128.105 (2) (b), the owner of a Wind Energy System is required to include “a map showing the planned location of all wind energy system facilities” with their 180 Day Pre-Application Notice.The map included in Pattern Energy’s 180 Day Pre-Application Notice (PSC REF # 480525) does not show the planned location of all wind energy system facilities, and therefore does not satisfy the legal requirements outlined in Wis. Admin. Code PSC 128.105 (2) (b). There are numerous omissions and inaccuracies on the map, but of particular importance:

1. 21 of the 145 “Wind Turbine Locations” on the map have no Collector Circuit lines, which means they are not connected to the overall project/grid.
   
2. At least 50-75% of the “Wind Turbine Locations” on the map have “Access Roads” that do not connect to any identifiable or named public road, which makes it impossible to identify what the access road connects to.
   
3. Up to 10 of the “Wind Turbine Locations” have no access roads identified at all.
   
4. The map is missing key road names that are necessary access points for the operation of the proposed Wind Energy System Facilities.
   
5. At least one (possibly two) of the “Wind Turbine Locations” on the map are located inside designated State of Wisconsin Wildlife Areas that cannot possibly be used for this project given that the land was purchased using State and Federal Stewardship funds that does not permit any type of industrial or commercial use of the land.

It is important to note that this is the second Pre-Application Notice filed for this project by Pattern Energy. On August 11th, 2023, Pattern Energy filed a Pre-Application Notice (PSC REF # 475068) that was embarrassingly incomplete. Fortunately, concerned citizens [Kurt, Zemlicka] recognized this and submitted correspondence to the PSC highlighting the obvious lack of detail in that original filing. It took Pattern Energy just 49 days to file their new/second Pre-Application Notice, which – as outlined above – is still incredibly incomplete and inaccurate.

It is also important to note that Pattern is not the first developer to navigate the approval process in our State. There are numerous other developers that have complied with state law by providing accurate and detailed maps of their proposed wind energy system facilities and were successful in their applications. These projects serve as templates, providing a reliable precedent for what a developer is required to provide during the approval process. It is alarming that Pattern Energy did not feel the need to utilize that information not just once, but twice, in their Pre-Application Notice filings.

The fact that Pattern Energy felt it was necessary to file a second Pre-Application Notice means they acknowledge their first filing did not satisfy state requirements. This second incomplete and inaccurate filing by Pattern Energy supports that this is no longer an “error” on their part as they navigate the approval process – especially since there are many successful wind project applications in our state that can be used as reference. At worst, Pattern’s filings are a blatant disregard for the law. At best, it shows their dishonest business practices and total disregard for the public as they attempt to push this project through. Given Pattern Energy’s track record of submitting incomplete and inaccurate filings, additional scrutiny by state officials and citizens is warranted when reviewing any additional filings by Pattern Energy related to this proposed project.

Due to both Pattern Energy’s Pre-Application Notices (PSC REF #480525 and #475068) omitting essential wind energy system facilities from their map, the 180-day time period prior to application should not commence until the map is updated and fully complies with Wis. Admin. Code PSC 128.105 (2) (b). Proceeding without this information deprives citizens and political subdivisions of their opportunity to defend their substantial interests – most importantly, their health and safety – and therefore deprives them of their due process rights.

Respectfully,

Ben Hoffman
Muskego, WI

On July 6, 2023 The Grant County Conservation, Sanitation and Zoning Committee will meet to assess developer ALLETE Clean Energy’s APPLICATION request to build a 19.9 square mile wind power plant (12,793 acres) with industrial scale turbines reaching as high as 665′ impacting more than 400 occupied dwellings in eastern Grant County.

The proposed, 70 Megawatt plant would make the seventh wind power plant aimed at a 600 square mile, three county utility district in Southwest Wisconsin.

The Conservation, Sanitation and Zoning Committee will read and consider written comments and suggestions about the proposal if submitted by June 27th to Erik Heagle, 150 West Alona Lane, Suite #1 Lancaster, WI 53813 or emailed to erik.heagle@wi.nacdnet.net (Start email with introduction).

Following are some project factors determined from Allete’s 62 MB Application that may not be immediately apparent about the proposal:

• APPROXIMATELY 392 DWELLINGS WOULD BE LOCATED WITHIN 1 MILE OF WIND TURBINES AND BECOME SUBJECT TO INFRASOUND IMPACTS PRODUCING UNDESIRABLE HEALTH IMPACTS FOR ABOUT 20% OF EXPOSED PERSONS. (Dwelling figures ascertained from Project “Setback” Maps on pdf pages 63, 65 & 67 in the Application)
  
• OF THESE DWELLINGS, 69% WOULD BE EXPOSED TO COMPOUNDED IMPACTS FROM 4-8 WIND TURBINES WITH 31% EXPOSED TO COMPOUNDED IMPACTS FROM 1-3 WIND TURBINES.

• A MAY, 2023 STUDY SPONSORED BY THE U.S. DEPARTMENT OF ENERGY RECOMMENDS AN AVERAGE SETBACK DISTANCE OF 4,560 FEET (BEIGE AREAS) FOR WIND TURBINES LIKE THOSE PROPOSED BY THE MERCHANT UTILITY DEVELOPER TO SURROUNDING LIVINGSTON, WISCONSIN.* The 3.7 greater distance compared to the 1250’ used by the developer significantly reduces exposure to sound and “SPL related requirements.” The discouraged beige impact areas include about 390 dwellings and most of the Village. *The specified GE 3.4-140 turbines align with the 1.39 km average setback for the “Future with STE” scenario. See “Effects of land-based wind turbine upsizing on community sound levels and power and energy density,” by Lawrence Berkeley National Laboratory, Ben Hoen, Ryan Darlow, Ryan Haac, Joseph Rand and Ken Kaliski. May, 2023. Accessible at: https://bit.ly/4560ft

• OF THESE AFFECTED DWELLINGS, MORE THAN 60 WOULD EXPERIENCE FROM 10 TO 90 HOURS OF TURBINE SHADOW FLICKER IMPACTS PER YEAR.

• THE APPLICATION CONTAINS NO MENTION OR ACCOUNTABILITY OF HEALTH DANGERS PRESENTED BY THE DOCUMENTED PHENOMENON OF “ICE THROW.” STUDIES SHOW THAT THE ICE FROM SHEETS THAT BUILDS-UP ON TURBINE BLADES UNDER THE RIGHT CONDITIONS CAN BE LAUNCHED DISTANCES AS GREAT AS 500-1700′. THE LATER DISTANCE, ESTIMATED BY PROF. TERRY MATILSKY OF RUTGERS UNIVERSITY FOR TURBINES MUCH SMALLER THAN THOSE BEING PROPOSED, IS CONSIDERABLY GREATER THAN THE 1250′ SETBACK DISTANCE THAT WISCONSIN LAW ALLOWS ALLETE TO BUILD TURBINES FROM OCCUPIED DWELLINGS AND OTHER EXTERIOR EXPOSURES CREATED BY WORK AND OTHER ACTIVITIES.

Letter to the Editor From Dodgeville Chronicle, April 20, 2023:

On a windy day with gusts in the 25 mph range, one can also assess audible sound impacts. Drive west of Montfort, WI on Highway 18 to the last two Red Barn industrial Wind Turbines (circled in white on below map). Turn South on Annaton Road and park off the road between the two turbines. Both of these IWTs are located about1250 ft from the road- the allowable setback distance from residents in Wisconsin under out of date code. Many states have increased setbacks to one mile or further.

This is an excellent excursion to for anyone unfamiliar with the size and impacts of modern day Industrial Wind Turbines. Red Barn turbines are approximately 550 feet high, 100 feet shorter than the 650′ systems being proposed.