Appendix C

ASARCO, BHP Copper, Cyprus Climax Metals,
Phelps-Dodge, and Public Interest Coalition on Energy

The Mines and the Coalition support the implementation of the Commission's Rule on electric competition -- taken as a whole. However, we continue to be concerned that the solar portfolio standard feature of the Rule will hamper the implementation of retail competition by increasing retail prices and by adding supply-side risk to the provision of competitive resources. The recommendation in this Report to create a new class of potentially stranded costs to cover future solar facilities further adds to our concern.

If the portion of the Rule concerning the solar portfolio standard is to be revised, we suggest that consideration be given to scaling back the solar requirement. Reducing the required solar content would mitigate the cost impact on consumers and would lower the supply-side risk.