Filed 13 Oct 2025 to the IUC

Main arguments:

1. 1. Timing and jurisdiction: The amendment petition is too late and outside IUC jurisdiction since the permit was already granted on June 25, 2024, and is now under judicial review by the Polk County District Court.
   2. No new evidence: Everything in the amendment could have been presented before the permit was issued.
   3. Procedural fairness: Summit initially chose to file 15 separate dockets and opposed earlier consolidation. Now, attempting to consolidate puts other parties—especially impacted landowners—at an unfair disadvantage.
   4. Stress on landowners: Reopening or consolidating the case would cause further unnecessary stress and delay.

 Conclusion:

The Sierra Club formally requests that:

• Summit’s Petition to Amend be dismissed, and
• the Motion to Consolidate be denied.

  /s/ Wallace L. Taylor

  WALLACE L. TAYLOR AT0007714
  Law Offices of Wallace L. Taylor

  ATTORNEY FOR SIERRA CLUB IOWA CHAPTER