Duke Energy seeking to "Upgrade" a Bunny to a Brontosaurus

BEFORE THE NORTH CAROLINA  COMMON SENSE COMMISSION
In the Matter of:

Any Citizen in the State of North Carolina
who happens to have a Bunny in their Backyard        
                                         Complainant
VS.

Duke Energy Carolinas, LLC
                                          Respondent 		)
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)		DUKE ENERGY CAROLINAS' MOTION TO DISMISS ANY CITIZEN'S OBJECTION TO DUKE ENERGY CAROLINAS'  "UPGRADE" OF A BUNNY TO A BRONTOSAURUS
NOW COMES  Duke Energy Carolinas, LLC  (herein referred to as Duke Energy)  pursuant to rule ID-10-T  of the NC Common Sense Code, and files its Motion  to Dismiss Any Citizen's Objection to Duke Energy's "Upgrade" of a Bunny to a Brontosaurus.

WHEREAS,
The words "Bunny" and "Brontosaurus" both begin with the letter "B"

AND WHEREAS
The words "Bunny" and "Brontosaurus both  contain the letters "U" and "N"

AND WHEREAS,
Both a Bunny and a Brontosaurus have 1 head, 1 tail and 4 legs each respectively

AND WHEREAS,
A Bunny and a Brontosaurus are both herbivores

AND WHEREAS,
A Bunny and a Brontosaurus are "similar" in nature and as such Duke Energy's "Bunny to Brontosaurus Project"  is not subject to any statutory regulation and/or certification process  due to its status as an "Upgrade" of an existing herbivore.

AND WHEREAS,
Duke Energy predicts that the demand for herbivores will increase, even though current usage is actually dropping due to conservation measures and various economic factors.

AND WHEREAS,
To date, there is not one single  laboratory study proving that a Brontosaurus in a Citizen's backyard is any more  hazardous or potentially damaging to the Citizen's heath and well being than a Bunny.


WHEREFORE, Duke Energy moves that the Commission wave all Rules of Common Sense and
(i) Order that Respondent's "Bunny To Brontosaurus Upgrade"  is plainly exempted from any CSR (Common Sense Requirement) by the Commission.
(ii)grant its Motion to Dismiss the Citizen's Complaint for failure to state a Bunny to Brontosaurus claim upon which relief can be granted.
(iii) grant such other relief as the Commission deems necessary.


Attachment A:   Simulation of Duke Energy's Proposed Upgrade
(NOTE: Bunny and Brontosaurus are not to scale)
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