As with several previous principles, IWLA and ME3 note that retail competition is one of a number of restructuring scenarios, that should only come about at the end of the Commission's step-wise movement toward a restructured industry. Second, IWLA and ME3 believe that the driving principle should be to first identify reasonable transition costs, if any. Coal and nuclear plants may be written off, at the expense of ratepayers, only to resurface and displace other less polluting resources. Finally, while sharing of transition costs is in theory equitable, IWLA and ME3 believe that any stranded costs must be assigned to departing customers so that other customers are not forced to pay for not choosing to escape the utility's embedded costs. IWLA and ME3 strongly endorse the Commission's commitment to improving environmental quality as part of regulatory restructuring.
Retail competition is one possible endpoint for a regulatory restructuring effort.
If, however, the Commission determines that retail competition is not warranted, IWLA and ME3 believe that the restructuring process should still incorporate the improvement or retirement of generating plant with environmental liabilities, and the development of clean and renewable resources. State participation in transmission planning. IWLA and ME3 concur that Minnesota's interests and concerns with transmission planning warrant participation and advocacy by state agencies. It must also be noted, however, that the rash of proposed mergers are threatening the viability of most regulatory authority in regard to transmission planning. Given that the industry may soon be regional even in regard to intra-state retail transmission planning, IWLA and ME3 recommend that the Commission consider what regional forms of regulation might be available in which to advocate for Minnesota's environment and the cost and reliability of Minnesota's retail electric services.