Throughout the test/trial period and immediately upon the start of the Wind Farm's commercial operation, Plaintiffs noticed the following significant and material intrusions upon their properties and inside their homes (collectively "Intrusions"):
a) Frequent and highly distressing noise created by and emitted from the Turbines of the wind farm;
b) Vibrations and/or a pulse sensation caused by the rotating blades of the Turbines as the blades passed by the pedestal;
c) A flicker/strobe light effect that often covers some and/or all of the Plaintiffs' properties and intrudes into their homes when sunlight passes through the rotating blades of the Turbines;
d) A highly visible glare which emanates from the Turbines of the Wind Farm when sunlight shines on the Turbines; and
e) Numerous flashing red lights which reflect off the rotating blades of the Turbines, overwhelm the night sky and are readily apparent from inside Plaintiffs' homes.
As a result of the Intrusions caused by Defendant's operation of the Wind Farm, Plaintiffs, as the case may be, began experiencing, by way of example not limitation, some and/or all of the following physical conditions, among others:
a) Inability to sleep and repeated awakening during sleep;
b) Headaches and pressure;
c) Ringing and aching in the ears;
e) Stress and tension;
f) Extreme fatigue;
g) Diminished ability to concentrate;
h) Nausea; and
i) Other physiological and cognitive effects.
In sum, the actions of the Defendant have directly and proximately caused Plaintiffs substantial damage, including but not necessarily limited to:
a) Physical harm and adverse health effects;
b) Disruption of Plaintiffs' lives and general emotional distress;
c) Diminution of the value of Plaintiffs' properties;
d) Loss of the ability to partition their properties to sell residential lots;
e) Difficulty carrying on normal recreational activities;
f) Difficulty conducting work related activities on their properties and/or harm to the business enterprises some Plaintiffs conduct on their properties;
g) Loss of use and enjoyment of Plaintiffs' properties;
i) Other damages that naturally and consequently flow from Defendant's actions.