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Earnings Call: Q3 2017

Oct 26, 2017

Operator

Good morning, everyone, and welcome to the CMS Energy 2017 third quarter results and outlook call. The earnings news release issued earlier today and the presentation used in this webcast are available on CMS Energy's website in the investor relations section. This call is being recorded. After the presentation, we will conduct a question-and-answer session. Instructions will be provided at that time. If at any point during the conference you need to reach an operator, please press the star key followed by zero. Just a reminder, there will be a rebroadcast of this conference call today beginning at 12:00 P.M. Eastern Time, running through November 2nd. This presentation is also being webcast and is available on CMS Energy's website in the investor relations section. At this time, I would like to turn the call over to Mr. Sri Maddipati, Vice President of Treasury and Investor Relations.

Sri Maddipati
VP of Treasury and Investor Relations, CMS Energy

Good morning, and thank you for joining us today. With me are Patti Poppe, President and Chief Executive Officer, and Rejji Hayes, Executive Vice President and Chief Financial Officer. This presentation contains forward-looking statements which are subject to risks and uncertainties. Please refer to our SEC filings for more information regarding the risks and other factors that could cause our actual results to differ materially. This presentation also includes non-GAAP measures. Reconciliations of these measures to the most directly comparable GAAP measures are included in the appendix and posted on our website. I will turn the call over to Patti.

Patti Poppe
President and CEO, CMS Energy

Thank you, Sri. Good morning, everyone. We are happy to have you with us. I know that we saw many of you at our Investor Day on September 25th, and we'll see many of you at EEI. I'll be brief this morning. We do have a few updates to share, including our results for the quarter, and not to worry, we have another exciting story of the month. Rejji will walk you through the financial results and our outlook. We're happy to announce that for the first nine months of 2017, we reported a $1.66 of adjusted EPS. On a weather-normalized basis, this is up 8% from last year. Despite challenging weather and storms through the year, we're well on track to meet our guidance, and we're raising our bottom end of our full year guidance from $2.14-$2.15 per share.

Our top end remains unchanged at $2.18 per share. We're also introducing 2018 full-year guidance of $2.29-$2.33 per share, which implies another year of 6%-8 % annual growth. This is a good opportunity for me to remind you what we mean when we say 6%-8 %. For 14 years in a row, we have delivered 7%, so it would be easy to assume that when we moved from 5%-7 % to 6%-8 %, we meant to imply 8%. What we actually signaled is our confidence in 7%, and frankly, we took 5% off the table. Our self-funding model and our adaptability under a variety of changing conditions each year puts us in a unique position to deliver sustainable 6%-8 % annual growth.

This is why we have confidence in the midpoint of our range. In years where we have particularly strong performance and don't have higher priorities for reinvestment, we could go to the high end. However, our bias is to reinvest in the business and to stack the deck for next year and deliver our growth trajectory for longer. We know it is both our growth rate and the consistency of it that is valued. To that end, we remain unwavering in our commitment to the triple bottom line. Our focus on people, planet, and profit underpinned by our performance will deliver the consistent and sustainable results that you have come to expect. When we say people, we're referring to our customers, our coworkers, our communities, and of course, our investors. Driving economic development in Michigan is a great way to enable growth and to serve the people of Michigan.

We know that when Michigan wins, our business wins. It's a competitive environment in these large site selection efforts, and Michigan is winning, in part due to the speed of our in-house economic development team, which has identified 23 energy-ready sites so that when a company wants to locate here, we can quickly help them find the site that's available and best suited to their needs. For example, we were pleased that when Lear Corporation, a large auto supplier, was looking for a place to locate a new manufacturing facility, we were ready. As a result, Lear recently announced plans to invest in a new plant in Flint, a community we are proud to serve. This is another win for Michigan, creating approximately 450 new jobs. Turning to the planet, we're thrilled with the response to our renewable tariff.

This program allows us to partner with our large business customers to meet their commitments to renewable energy at a very competitive price. We're already looking for ways to expand this program to keep up with our customers' demand and partner with them to protect the planet. Finally, our commitment to people and the planet can't be fulfilled without the critical capital that you have all provided. We know that pensioners, retirees, and moms and pops have entrusted you with their life savings to invest in safe and reliable places. We want you to count on us to be just that sort of place. Therefore, we are equally committed to delivering consistent and predictable financial results. We continue to progress on the regulatory agenda and look for ways to support longer-term planning.

The 2016 energy law creates the framework for the governor's long-term energy plan, and our commission has been systematically implementing the different elements of it. For example, we'll be filing our integrated resource plan required by the new law next year. Combined with the commission's ordered five-year electric distribution plan, we'll be providing a vivid picture of the future replacements, upgrades, and enhancements to our large and aging electric supply and distribution system in partnership with the commission and its staff, yielding more transparency and regulatory certainty going forward. Our rate cases remain on track. Our gas rate case was approved at $29 million, and it included an expanded $18 million capital tracking mechanism. We plan to file our upcoming gas case in the next couple of weeks. Our new electric rates were self-implemented at $130 million on October 1st. We expect a final order in March of 2018.

These rate cases enable the infrastructure improvements that deliver real value to our customers and reflect the cost savings that help reduce the price of that infrastructure. One way we are driving our ongoing cost savings is through the implementation of the Consumers Energy Way, our lean operating system. Most of the coverage about the Consumers Energy Way has been about the benefits of those cost savings. My story for this month, however, demonstrates the power of the CE Way to not only reduce cost through waste elimination, but also to enable better system performance in areas like electric reliability to the benefit of our customers. You know we've been in business for 130 years, and yet we still find things we can improve every single day. About a year ago, we realized that our approach to improving reliability was just not working as fast as we wanted.

We stepped back and, leveraging our CE Way playbook, we tackled this systemic issue in a whole new way. The results speak for themselves. In spite of challenging weather and storm activity, we had our best system reliability ever recorded this quarter. Our talented team tackled the problem through the use of data and applied problem-solving techniques, as a result, we improved the prioritization of capital investments on our worst-performing circuits. We actually call those our Dirty 30. We had more targeted tree trimming, and we realized that we could more effectively engineer animal mitigation at our substations. Yes, the CE Way even helps us protect our local critters. This coordinated effort resulted in a 40% improvement in reliability for this quarter versus our last 10-year average. Every dollar we spend is more effective. The waste is eliminated, and our customers have a better experience.

I am sure this sounds simplistic, but when we apply the CE Way every day, all across our system, in big and small ways, we fuel our simple but powerful business model. Higher value at lower cost builds on our consistent past and yields a sustainable future that you and your clients can count on. I'll turn the call over to Rejji.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you, Patti. Good morning, everyone. We know how busy this time of year is for the investment community, and as such, we greatly appreciate your interest in our company. As posted earlier this morning, we reported $0.61 earnings per share on a GAAP basis for the third quarter and $0.62 per share on an adjusted basis. Our third quarter results are down $0.08 from last year, largely due to continued mild weather. However, on a weather-normalized basis, adjusted EPS for the quarter was up 7% year-over-year. Year to date, we reported earnings per share of $1.65 on a GAAP basis and $1.66 on an adjusted basis, which is down $0.07 from the prior year due to mild weather and significant storm activity, but up 8% year-over-year on a weather-normalized basis.

We remain quite pleased with our performance to date, which is $0.16 per share ahead of plan, largely due to favorable sales mix and strong cost performance. We are well on track to meet our annual financial objectives. As a result, as Patti highlighted, we decided to raise the low end of our 2017 EPS guidance range. Our revised range is now $2.15-$2.18 per share. As you can see on the waterfall chart on slide eight, weather and storms have negatively impacted our year-to-date results by $0.24 per share. As noted, we have largely offset those impacts through strong cost performance and favorable sales mix coupled with rate relief and outperformance at enterprises, which positions us well for the fourth quarter.

As we look ahead to the remainder of the year, you'll note that the regulatory outcomes achieved this year, including the aforementioned electric rate case self-implementation of $130 million, provided $0.08 of pickup relative to last year, which gets us over a third of the way home. As we've discussed in the past, in the fourth quarter of 2016, we took on a number of discretionary reinvestment activities, which equated to $0.14 per share in aggregate that we do not need to replicate this year. The sum of those two factors alone put us within the implied range of required EPS outperformance versus Q4 of 2016 to meet our revised 2017 EPS guidance range. Consequently, we have a great deal of optionality in the final months of the year to manage weather uncertainty and/or to reinvest in the business to support our future financial and operational objectives.

Our 2017 EPS outlook curve on slide nine embodies our efforts to date and the good financial flexibility that we have going into the fourth quarter. As you'll note, weather and storms have hurt us in every quarter this year. Every quarter, we have responded with sound operational and financial planning to stand course to meet our financial objectives while delivering world-class customer experience. As mentioned, favorable sales mix has been helpful to date. We have supplemented that with strong cost performance, including lower-than-planned financing costs, higher energy efficiency incentives, and strong property and income tax planning. As always, every year offers varying levels of uncertainty, such as weather and storm activity. We have always managed the work and driven cost savings to position ourselves well to deliver another year of consistent financial performance.

As Patti noted, our bias is to reinvest in the business to stack the deck for next year. We're cautiously optimistic about our ability to do so again this year. In order to stay on this path over the long term, we'll remain focused on executing on our capital plan at the utility going forward, while self-funding roughly 70% of that rate base growth. This approach minimizes customer rate impact and allows us to grow at 6%-8% annually. This simple but unique business model has driven our historical success and offers a sustainable plan to deliver the triple bottom line in the years to come. At our Investor Day, we highlighted the current customer investment plan of $18 billion over 10 years. We also reiterated the incremental $7 billion of customer investment opportunities, which is evenly split between infrastructure and supply investments.

We have a relatively large and old system. The proposed investments would improve system reliability and safety to the benefit of our customers and investors. We will look to execute on these incremental opportunities over time, assuming we can continue to identify cost-saving opportunities to fund such investments. As we've said in the past, our key constraint is customer affordability. We do not intend to compromise that principle going forward. To that end, in order to fund our robust capital plan, we will continue to scour our cost structure for savings opportunities. We have emphasized O&M as a key component of our cost reduction strategy in the past. We will continue to do so. O&M only represents about $1 billion of a roughly $5 billion cost structure. We don't limit our thinking to just O&M.

For example, future expirations of above-market PPAs will reduce fuel and power supply costs. Our clean and lean capital investment philosophy will prioritize modular investments to reduce costs and allow us to adapt to changing load patterns. Through the CE Way, we will identify process improvements and efficiencies to eliminate waste. We will couple that with good business decisions, such as attrition management, to reduce future O&M costs. We will always seek opportunistic non-operating savings on our balance sheet or through good tax planning to supplement our operational efforts as we've done for the past several years. These are just a few examples that will enable us to reduce costs well into the future for our customers and create headroom for future investments.

Moving to operating cash flow, we have generated approximately $1.2 billion year to date. We feel good about our ability to deliver approximately $1.65 billion for the full year, with steady growth thereafter. As a reminder, our cash flow generation, coupled with strong tax planning, will enable us to fund our capital plan cost efficiently by avoiding block equity issuances. On slide 14, we show our historical EPS trajectory for the past few years and where we're headed. It should come as no surprise that our guidance is consistent with the past and reflects our long-term growth aspirations. As we have done in the past, we've raised the bottom end of this year's guidance. We initiated next year's base in the midpoint. As you know, we grow off our actual results without adjusting for things like weather or rebasing off a prior midpoint.

Needless to say, we've been on a steady climb for more than a decade. We plan to continue to deliver well into the future. In closing, as we look ahead, we see a number of customer investment and cost reduction opportunities that will enable us to continue to deliver the triple bottom line of people, planet, and profit underpinned by performance. With that, we would like to open it up for Q&A.

Operator

Thank you very much, Mr. Hayes. The question and answer session will be conducted electronically. If you'd like to ask a question, please do so by pressing the star key, followed by the digit one on your touchtone telephone. If you are using the speaker function, please make sure you pick up your headset. We'll proceed in the order you signal us, and we'll take as many questions as time permits. If you do find that your question has been answered, you may remove yourself by pressing the star key followed by the digit two on your touchtone telephone. We'll pause for just a second. Today's first question comes from Julien Dumoulin-Smith of Bank of America Merrill Lynch. Please go ahead.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Hey, good morning. Congrats on the impressive results given the weather and everything.

Rejji Hayes
EVP and CFO, CMS Energy

Thanks, Julien. Good morning.

Patti Poppe
President and CEO, CMS Energy

Good morning, Julien.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Excellent. A quick question, perhaps starting a little bit bigger picture here. You talked about the IRP coming up here. You also have in your slides talk of a gradual coal evolution in the plan and ops of 21% to 15%. Can you talk about how the IRP might reconcile against slide 15 here and what you talk about in terms of future coal capacity in the portfolio?

Patti Poppe
President and CEO, CMS Energy

Yeah, it actually will provide a lot of visibility to that, Julien. We're really excited about having the IRP available to us. It provides the framework and the certainty so as we make those long-term transitions, we are able to have alignment with our commission and make good decisions together about balancing a variety of factors, fuel diversity, cost for customers, how we want to fulfill the RPS standard, how much energy efficiency and demand response we want. In fact, our IRP looks like it's going to have 47 different model runs that we're undertaking right now as we speak. It's a complex set of variables, and we're excited about what the opportunities will be provided and the transparency and, frankly, regulatory certainty that will be a result of it.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Got it. Oh, sorry. Please go for it, Rejji.

Rejji Hayes
EVP and CFO, CMS Energy

Julien, this is Rejji. The only thing I would add is as you look at slide 15 and that coal capacity from 21% to 15%, one of the underlying assumption is the conversion of the Filer City plant at Enterprises. We're planning to convert that from coal to natural gas. Basically going from 60 MW of coal to about 225 MW of natural gas. That is in the regulatory process and is trending well, and that is one component of the road to get from 21% to 15%.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Got it. Can you elaborate a little bit just on what the timing of that transition is as well, and how you think about that? Perhaps to the extent to which it may not necessarily be finalized, what the key variables you all are thinking about in that transition there?

Patti Poppe
President and CEO, CMS Energy

Yeah, I would say the timing is over this 10-year time horizon that we're looking at making these transitions. At 22% coal, we're already one of the lowest in the country. We feel good about that. The fuel diversity of having our sites remaining is an important part of the mix. We'll build that into the plan, and frankly, we look forward to the results of the model because it will be informing to us about when the best time is to transition those plants. The reality is we've done some environmental upgrades at those facilities, so they're best-in-class environmental controls currently. To rush any additional retirements probably isn't necessary, but they do have a natural end of life within that cycle. We'll be thinking through the IRP, and frankly, with all of our critical stakeholders, internal and outside the company.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Excellent. Just a quick one on the numbers here. Obviously, you've done very well on cost management and some of the recovery factors on slide nine there again this year. Since you've launched 2018 guidance, might you be able to elaborate a little bit on some of the key factors we should be thinking about in the year-over-year comparison in that range? What are perhaps some of the known variables that you might be thinking about or leverage, shall we say, in cost management next year? Is there anything that you can say today that we should be paying attention to?

Rejji Hayes
EVP and CFO, CMS Energy

Yeah.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

As you think about that plan?

Rejji Hayes
EVP and CFO, CMS Energy

Yes, I'd offer a couple of thoughts. When we talk about particularly O&M cost reduction opportunities, we've talked in the past about the very nice annuity that we've gotten through attrition management over the years. That has been something that we've said has been a benefit in the past and should be an ongoing benefit in the years to come. Specifically, on average, we've got about 350-400 employees who turnover who are on defined benefit plans, which obviously are not as cost-effective as defined contribution plans. We froze those plans in the early aughts. Now when we have new employees come in, by definition, they're on defined contribution plans. We generally save about $40,000 per FTE when you have turnover between defined benefit plan employees and then defined contribution plan employees coming in.

If you have $40,000 of saving per FTE and you turn over about 400 per year, that generates about $16 million of savings per year. You think about our cost structure on the O&M side of about $1 billion, that's about 1.5% savings. That gets us a good portion of the way there. Obviously, we always look to do opportunistic refinancings, and so we do have some high-coupon bonds in our portfolio that we may look to be opportunistic around. That introduces opportunities for savings. Clearly, as mentioned before, we're always looking at tax planning opportunities on the property tax or income tax side. Those are a variety of opportunities that we look for.

Also, as I mentioned, because we're in reinvestment mode for the fourth quarter, this is the time of year where we look for pull aheads. If there are operational-related expenses that we have currently forecasted in 2018 that we can pull forward because we're trending well this year, we'll look to do that as well. That's a small list of the opportunities that we have before us, Julien.

Patti Poppe
President and CEO, CMS Energy

Julien, I'll add just a couple more just to reinforce that there's plenty. We've got the CE Way is just taking shape, so we're finding operational savings across the board around the organization. Our technology adoption, so going from our traditional phone calls to our digital channels, is a fundamental cost savings and cost reduction. Part of what you're hearing from Rejji and I here, and for everyone on the phone, is that we have the luxury of focus. Our business model is not complex. We don't have big bets. We're not betting on big outcomes. We've got a series of small, focused efforts that allow us to deliver consistently, and the consistency is what we know you've come to expect, and we're pretty excited about the breadth and depth of opportunities that are in front of us.

Rejji Hayes
EVP and CFO, CMS Energy

Julien, the only other thing I would note, and this is not related to cost savings, but it is worth noting that for the first nine months of the year, weather and storms have hurt us to the tune of about $0.24. We don't plan for that type of extreme or mild weather and that type of extreme storm activity. In a normalized year, we'd like to think that that offers a tailwind going into 2018.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Excellent. Just a quick clarification because you mentioned the tax item just now for 2018. Anything about describing the $0.05 benefit here in the, I suppose it would've been the third quarter here on that slide, too?

Rejji Hayes
EVP and CFO, CMS Energy

Yeah. Happy to provide some color on that. The $0.05 benefit realized in Q3, that's largely attributable to a reduction in deferred income taxes associated with electric sales into MISO.

Julien Dumoulin-Smith
Analyst, Bank of America Merrill Lynch

Got it. Okay, fair enough. Thank you very much for all the detail.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Operator

Our next question comes from Michael Weinstein of Credit Suisse. Please go ahead.

Michael Weinstein
Analyst, Credit Suisse

Hi, guys.

Patti Poppe
President and CEO, CMS Energy

Hey, Michael.

Rejji Hayes
EVP and CFO, CMS Energy

Hi, Mike. How are you?

Michael Weinstein
Analyst, Credit Suisse

Hey, just to follow up on some of Julien's questions. When you think about the $7 billion of opportunity for CapEx, I know that half you said is from distribution transmission, the other half from supply. Understood that supply is probably going to be dealt with in the IRP, but on the T&D side, how do you think about pacing of when you can possibly move that into the official $18 billion side of the forecast, the one that's not an opportunity, but actually part of the plan going forward?

Patti Poppe
President and CEO, CMS Energy

I'll start, and then if Rejji wants to add some additional comments. The commission has requested a five-year distribution plan, and we filed an initial version in August. We're receiving comments and having working sessions with the staff at the commission right now. We'll be submitting a final plan in January, and it's through that plan, and this is what I think is really a great part of what the commission is leading right now, these longer-term viewpoints of where the right investments in infrastructure exist. By filling in our IRP in the spring of next year, in conjunction with this T&D distribution, in particular five-year modernization plan, we'll have a really good picture about where the investment opportunities are and have some real alignment with the commission, an agreement about what those investments will be.

Frankly, because of the age and the size and scope of our system, we have internal competition with trying to decide where best to put the dollars because there's so many parts of the distribution system and the supply system that require investment. When you layer in our large gas system, our constraint is not do we have capital we can do? The constraint is customers' ability to pay, which is why we put so much emphasis on reducing the cost of that infrastructure in any way possible so that we can provide more value for every dollar that we invest. That's what we've been working on. With the five-year distribution plan and the IRP combined, we'll be able to build out that five-year investment strategy in much more detail and with a lot more certainty.

Michael Weinstein
Analyst, Credit Suisse

Do you think there's a possibility that the $7 billion in opportunities could also be expanded as you work your way through both this plan and the IRP?

Patti Poppe
President and CEO, CMS Energy

Yeah, we do. Again, it's only constrained by customers' ability to pay, so that in the 10-year time horizon, in particular, when we have these PPAs that do peel off and are at the end of their contractual life, that creates some real headroom to make additional investments without raising customers' prices beyond what they can afford. That definitely is a key ingredient in our 10-year plan.

Rejji Hayes
EVP and CFO, CMS Energy

Michael, this is Rejji. The only thing I would add to that, I think that's all 100% right. Just to give you some specifics, as you may recall from Investor Day, Garrick went into great detail on the volume of capital investment opportunities that we have, just given the age of our system. On the electric side, we talked about the average age of the system, and I think 75% of our assets were constructed before 1970, and that the industry average is about 65%. We also just have the very old gas distribution mains, most of which, or a good portion of which, were constructed around World War II.

There's a lot of opportunities there, if you extrapolate on that math, that are well in excess of the $25 billion that we've highlighted in our $18 billion 10-year plan, plus the $7 billion of upside opportunities. There's a lot of capital investment opportunities, and as Patti noted, the key constraint is obviously affordability. If we can accelerate the cost reduction or savings, then that will allow us to execute on the upside opportunities as well.

Michael Weinstein
Analyst, Credit Suisse

Right. Makes sense. Thank you very much.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Patti Poppe
President and CEO, CMS Energy

Thanks, Mike.

Michael Weinstein
Analyst, Credit Suisse

Bye.

Operator

Our next question today comes from Jonathan Arnold of Deutsche Bank. Please go ahead.

Jonathan Arnold
Analyst, Deutsche Bank

Good morning, guys.

Rejji Hayes
EVP and CFO, CMS Energy

Morning, Jonathan.

Patti Poppe
President and CEO, CMS Energy

Morning, Jonathan.

Jonathan Arnold
Analyst, Deutsche Bank

I was just curious on, again, this tax item in the quarter sounds like it was largely to do with past periods, probably a one-timer. Is that fair?

Rejji Hayes
EVP and CFO, CMS Energy

Yeah. Largely one-timer. There could be a little bit of upside to the tune of about $0.01 in 2018, but largely one-timer.

Jonathan Arnold
Analyst, Deutsche Bank

Rejji, my question is, i s this something you'd sort of anticipated going into this year, or was it the timing is fortuitous? Had you not got this, how would you be feeling around the range? Were there other things you could have done, et cetera?

Rejji Hayes
EVP and CFO, CMS Energy

I'll answer the last question first, and then I'll get to the initial part of your question. We would feel good about our ability to hit our fourth quarter full year, and then going forward, feel good about hitting our financial objectives irrespective of whether this tax opportunity came about. I mean, the reality is we're $0.16 ahead of plan, and the tax savings that we realized in this quarter would've, absent that, we would still be about $0.10 ahead of plan. It was helpful, but it's not what we're hanging our hat on. As always, we manage the work accordingly in the event we have unexpected variances like weather, like storms, and this is just yet another example of us identifying cost savings opportunities. That's the sort of quick answer to the last part of your question.

As to the initial part, we have actually been evaluating this deferred income tax reduction opportunity for some time. What allowed us to take advantage of it this quarter is that there were a couple of legal precedents that emerged that allowed us. There'll be more disclosure around this in the Q. They allowed us to revisit our methodology for portioning electric sales into MISO. That's really the gist of why we took advantage of this opportunity now.

Jonathan Arnold
Analyst, Deutsche Bank

Thank you.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Operator

Our next question comes from Ali Agha of SunTrust. Please go ahead.

Ali Agha
Analyst, SunTrust

Thank you. Good morning.

Rejji Hayes
EVP and CFO, CMS Energy

Morning, Ali.

Patti Poppe
President and CEO, CMS Energy

Morning, Ali.

Ali Agha
Analyst, SunTrust

Morning. Looking at the data year to date, weather-normalized electric sales were running behind your full year target. Any insight into that? Does that change your long-term planning for weather-normalized sales going forward?

Rejji Hayes
EVP and CFO, CMS Energy

The quick answer, Ali, this has been kind of a recurring theme for the first couple of quarters of the year, now the third quarter. We actually feel like we're trending quite well on a weather-normalized basis. As you may recall, in our fourth quarter earnings call, we forecasted about half a percent growth on the weather-normalized electric sales, and that's net of energy efficiency programs. If you look at the data on page 13 of our pack, we're about, call it, 40 basis points. What has been really in excess of our expectations has been the performance on the commercial side. You can see from a commercial perspective, we are about 1.5% up year-over-year. Industrial, which was down 1% in the first half of the year, is now basically flat.

That's starting to turn around, so we're seeing good industrial activity. Residential was strong for the first half of the year, up about 50 basis points or 0.5% , and is now about flat. I think what the residential trends do not pick up in the third quarter is that, like most of the country, we had very nice weather in the latter part of September, which effectively has not picked up in our performance but will be picked up in October. Effectively, those sales are still on the meter. We are trending not only on target to get to about 0.5% to 1% of growth year-over-year by the end of the year, but also the sales mix has been quite favorable over the first half of the year, and it continues on to this Q3.

We're very pleased actually with the performance today. Is that helpful?

Ali Agha
Analyst, SunTrust

Yes, it is. Thank you. Secondly, the last 12 months' earned ROEs, weather normalized, both electric and gas, are above your authorized. Any concerns with that as you're going through the rate cases, or do you think that gets reduced by the future CapEx opportunities?

Rejji Hayes
EVP and CFO, CMS Energy

Yeah, that should normalize over time. I think we're maybe 10 - 20 basis points on the electric side above the authorized ROE. That's probably has to do with a little bit of lag attributable to some of the cost savings and just not having the opportunity to pass those on as soon as we'd like. We obviously, as we always do, we pass those on as quickly as we can through the annual rate filings. On the gas side, I'm sure you noted that we're well below the authorized ROE. That's because of the loss of self-implementation attributable to the new energy law that was implemented in April this year. Again, we expect those to normalize over time and 10- 20 basis points above the authorized level. We think again that will get back to the authorized levels fairly soon.

Ali Agha
Analyst, SunTrust

Thank you.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Operator

Our next question comes from Travis Miller of Morningstar. Please go ahead.

Travis Miller
Analyst, Morningstar

Good morning. Thank you.

Patti Poppe
President and CEO, CMS Energy

Morning, Travis.

Travis Miller
Analyst, Morningstar

I was thinking about the regulatory activities. I had one short-term question and one long-term question. I was wondering if you could point out the key 2018 regulatory, either decisions or filings or other activities that might change that guidance range or put you at the top end or the low end.

Patti Poppe
President and CEO, CMS Energy

Well, okay. We do have some significant regulatory outcomes in 2018 planned, but as it relates to our guidance, our 6%-8%, as I mentioned, we work every year under a variety of changing conditions, weather, regulatory outcomes, politics, et cetera. We always work to make sure that we can adapt to those changing conditions, and that's the strength of this business model. I think as you're thinking about our 2018 guidance, I would stay anchored in that point. That our strength comes from our simple but powerful business model. It has strong CapEx underpinned by cost savings ongoing throughout the year, and then a real core competence in adaptability. A lot of people do point to our business model, and I love it, and it's straightforward, and I can see why we would.

One of the core strengths of this company, and Rejji highlighted it in his remarks, is the fact that no matter what comes, we manage to work it out. Because we don't have big bets, because we're not waiting on one big regulatory outcome, because we're not waiting on one big project to get approved, we can adapt and make those changes throughout the year and manage to deliver for all of you. For 14 years in a row, delivering 7% EPS growth, we feel pretty good about our track record. What we're trying to share is that we have plenty of visibility into being able to deliver it again going forward.

Travis Miller
Analyst, Morningstar

Okay, thanks. The long-term question was how sensitive is that long-term growth number to that IRP filing and whatever outcome, plus or minus, that might come about?

Patti Poppe
President and CEO, CMS Energy

I think, if anything, the IRP provides more certainty to the performance because we'll have more visibility into longer-term planning and be able to do more cost-effective investments and cost-effective generation, which is how our model works. The heart of our model is that our system is large and aging, and we have significant infrastructure replacement upgrades, enhancements required. Any certainty we can have going forward allows us to most cost-effectively do those upgrades and make the changes necessary. We have a large and aging system between the gas and electric, and so really we look forward to the certainty that the IRP can provide so that we can do really even better planning than we've been able to do in the past.

Rejji Hayes
EVP and CFO, CMS Energy

The only other point I would add is obviously the utility drives a good portion of the lion's share of our earnings on an annual basis, but we still have the unregulated businesses, both enterprises and EnerBank, that provide additional levers to risk mitigate our annual plan. Obviously, we will seek out cost reduction opportunities, either operating or non-operating, to make sure that we can again risk-mitigate any unfavorable regulatory outcomes.

Travis Miller
Analyst, Morningstar

Great, thanks. I appreciate it.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Patti Poppe
President and CEO, CMS Energy

Thanks, Travis.

Operator

Our next question comes from Andrew Levi of Avon Capital. Please go ahead.

Andrew Levi
Analyst, Avon Capital

Hi, good morning.

Patti Poppe
President and CEO, CMS Energy

Hey, Andrew.

Andrew Levi
Analyst, Avon Capital

Just real quick because I've been off and on. Just on this deferred tax item, I don't know if I heard it correctly, but is it what potential that there could be upside to this year's number if you deem to book more of that? Is that correct?

Rejji Hayes
EVP and CFO, CMS Energy

No . We would say the $0.05 of realized benefit in this quarter, that's effectively it for 2017. There may be a $0.01 of upside next year, as I highlighted, I wouldn't expect anything further beyond that in this fiscal year. Does that help?

Andrew Levi
Analyst, Avon Capital

Y eah, okay. What I thought first I heard there would be higher 2017. Obviously, you just changed your 2017 a little bit. You'd have a higher base to grow off of, and that would change 2018, 2019, whatever. That's not the case. I misheard. Thank you.

Rejji Hayes
EVP and CFO, CMS Energy

Thank you.

Patti Poppe
President and CEO, CMS Energy

Thanks, Andy.

Operator

This concludes our question and answer session. I'd like to turn the conference back over to Ms. Poppe for any closing remarks.

Patti Poppe
President and CEO, CMS Energy

Well, thanks everyone for joining us, and we do look forward to seeing you at EEI right around the corner.

Operator

This concludes today's conference. We thank everyone for your participation.