Actually debating about it without parsing is always dangerous, but I don't believe that 51 SC is anywhere near a 3x/3x build. In AoE Fights (where SC shines) you hardly do any ice damage, only occasionally with Hailstorm and Arctic Blast. In singletarget boss fights (where SC is not on par with other Speccs, sadly) you're argument is coherent, but again the only ice damage comes from Icicle and Cloudburst. Compare it with a secondary Elemental Specc, you gain:
- Lighting Strike (crits up to 2600 with my mostly blue gear)
- 30% higher Crits
- Air Ele with more than 100dps, charge buff for you and spelldamage buff for your entire group
- Very nice timer (doubles the pets dmg and increasing your own dmg by 50% for 15s)
- Very nice debuff (7% more magical dmg taken)
- 5% higher chance to crit
Stretch of Cold can not compete with all these gimmicks, not as long as it is only increasing water/ice damage. And Eye of the Storm is just redundant, I can't see a niche for that spell

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