20161021Application.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
October 21, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-24
Recovery of Costs Associated with North Valmy Power Plant -Idaho Power
Company's Application and Testimony
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of Idaho Power
Company's Application in the above matter.
In addition , enclosed are an original and eight (8) copies each of the Direct
Testimony of Matthew T. Larkin and the Direct Testimony of Tom Harvey filed in support of
the Application. One copy of each of the aforementioned testimonies has been designated
as the "Reporter's Copy." In addition, a disk containing a Word version of both testimonies
is enclosed for the Reporter.
Lastly, four (4) copies each of Idaho Power Company's press release and customer
notice are also enclosed .
LDN:csb
Enclosures
Very truly yours,
ofbµ~--n~~
Lisa D. Nordstrom
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company ·
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
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. . " i7i ::, COi'JMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-16-24
AUTHORITY TO INCREASE ITS RA TES )
FOR ELECTRIC SERVICE TO RECOVER ) APPLICATION
COSTS ASSOCIATED WITH THE NORTH )
VALMY POWER PLANT. )
-----------)
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code§ 61-524 and RP 052, 121, and 125, hereby respectfully makes application to the
Idaho Public Utilities Commission ("Commission") for an order authorizing the Company
to: (1) accelerate the depreciation schedule for the North Valmy power plant ("Valmy")
to allow the plant to be fully depreciated by December 31, 2025, (2) establish a
balancing account to track the incremental costs and benefits associated with the
accelerated Valmy end-of-life date, and (3) adjust customer rates to recover the
associated incremental annual levelized revenue requirement of $28.50 million with an
effective date of June 1, 2017. This Application is being filed with the Commission
APPLICATION -1
concurrently with an application in Case No. IPC-E-16-23 requesting approval to
institute revised depreciation rates for the Company's electric plant-in-service and adjust
Idaho jurisdictional base rates to reflect the revised depreciation rates ("Depreciation
Application"). Idaho Power is simultaneously filing these applications in order to
facilitate a single rate change for customers. Idaho Power requests the Commission
issue an order approving this Application by April 1, 2017, to allow the Company to
incorporate any rate impacts associated with this Application in the Company's April 14,
2017, Power Cost Adjustment filing.
In support of this Application, Idaho Power asserts as follows:
I. BACKGROUND
1. Idaho Power is to file an updated depreciation study within five years of
the Company's previous depreciation study. The Company's most recent update,
approved by Order No. 32559 in Case No. IPC-E-12-08, went into effect on June 1,
2012 , and reflects a plant life for Valmy of 50 years for each unit, resulting in a
retirement year of 2031 for Unit 1 and 2035 for Unit 2. In 2013, the Public Utilities
Commission of Nevada ("PUCN") approved a 2025 end-of-life date for both Unit 1 and
Unit 2 for NV Energy, Idaho Power's co-owner in Valmy (Docket No. 13-06002, Modified
Final Order dated January 29, 2014). Likewise, in its most recent depreciation study
filed with the PUCN on June 6, 2016, NV Energy used the same end-of-life date for both
units (Docket No. 16-06008).
2. Because nearly five years have passed since the last update, the
Company began preparations in early 2016 to file a new depreciation study. Through
these preparations, the Company identified that significant changes had occurred with
regard to the life of the Valmy plant, warranting the need for specific review separate
from the Company's general depreciation filing. The 2025 end-of-life date currently
APPLICATION -2
utilized by NV Energy provides an indication that the Valmy plant will not be operational
beyond 2025. Therefore, the Company believes it is appropriate to consider Valmy­
related issues concurrently with the comprehensive depreciation study filed in Case No.
IPC-E-16-23.
II. VALMY
3. Valmy is a coal-fired power plant that consists of two units and is located
near Winnemucca, Nevada. Unit 1 went in service in 1981 and Unit 2 followed in 1985.
Idaho Power owns 50 percent, or 284 megawatts 1 ("MW") (generator nameplate rating),
of Valmy. NV Energy also has 50 percent ownership and is the operator of the Valmy
facility. Idaho Power and NV Energy work jointly to make decisions regarding any
environmental investment, plant retirement, or conversion. The plant is connected via a
single 345 kilovolt transmission line to the Idaho Power control area at the Midpoint
substation. Idaho Power has the northbound capacity and NV Energy has the
southbound capacity of this line.
4. Coal for the plant is shipped via railroad from various mines in Utah,
Wyoming, and Colorado. The power plant uses a variety of emissions control
technologies, including state-of-the art fabric filters that remove more than 99 percent of
particulate emissions. Additionally, a Dry Sorbent Injection ("OSI") system is used on
Unit 1 to reduce acid gas emissions and flue-gas scrubber technology is utilized on Unit
2 for the reduction of sulfur dioxide emissions. Both units have an activated carbon
injection system installed to control the emissions of mercury from the flue gas.
Ill. VALMY OPERATIONS
5. A 2031 end-of-life for Unit 1 and a 2035 end-of-life for Unit 2 were used in
the Idaho Power prepared Coal Unit Environmental Investment Analysis for the Jim
1 For planning purposes, Idaho Power uses the net dependable capability of 262 MW.
APPLICATION - 3
Bridger and North Valmy Coal-Fired Power Plants ("2013 Coal Study"). The analysis
performed for the 2013 Coal Study examined future investments required for
environmental compliance at existing coal units and compared those investments to the
costs of two alternatives: (1) replacing such units with combined cycle combustion
turbine units or (2) converting the existing coal units to natural gas . Idaho Power
concluded that installation of the investments required for environmental compliance
was a low-cost approach to retain a diversified portfolio of generation assets for
customers.
6. Therefore, the Company continued to include Valmy in its generation
portfolio for the 2013 Integrated Resource Plan ("IRP") and future resource planning.
Similarly, the preferred resource portfolio identified in the 2013 IRP included continued
operations of the Valmy coal facility in full compliance with environmental regulations
through the 2013-2032 planning period. At that time, Idaho Power committed financially
to the investments required on Unit 1 needed to meet current environmental regulation
and installation of the required emission control systems was complete in the spring of
2015.
7. As part of the Company's 2015 IRP, Idaho Power again analyzed a variety
of retirement dates for Valmy. Results consistently indicated favorable economics
associated with two significant resource actions: the Boardman to Hemingway ("B2H")
transmission line and the early retirement of Valmy. The preferred portfolio selected for
the 2015-2034 planning horizon contained both actions in the year 2025, with
completion of the transmission line preceding the end-of-year coal plant retirement. The
2015-2018 action plan recognized in the 2015 IRP included ongoing permitting,
planning studies and regulatory filings associated with the B2H transmission line during
all four years, and indicated in 2016 Idaho Power would work with NV Energy to
APPLICATION -4
synchronize depreciation dates and determine if a date could be established to cease
coal-fired operations. Case No. IPC-E-15-19, Order No. 33441 . This filing will
synchronize depreciation rates between the two companies.
8. Significant changes in Val my operations have occurred between 2010 and
2014. In 2011, the average price Idaho Power received for off-system sales was $22.71
per MW compared to 2015 when the average price Idaho Power received for off-system
sales was only $11.82 per MW. Moreover, year-to-date 2016, Idaho Power's average
price for off-system sales is only $8.76 per MW. In addition to reducing off-system
sales, the significant decrease in market prices has resulted in a decrease in the
number of hours Valmy operates economically, as the dispatch cost is now typically
higher than the market price. Rather than a resource used to generate off-system
sales, Idaho Power has been relying on Valmy to meet the Company's peak energy
needs, preserving the balanced portfolio needed to reliably serve Idaho Power
customers during all types of system conditions .
9. As shown in the preferred portfolio of Idaho Power's 2015 IRP, the
economics of Valmy's operation are impacted in the long term as new resources such
as 82H or other operating facilities are available to maintain the balanced portfolio
required to serve load reliably. Idaho Power relies on Valmy to meet peak energy
needs and to preserve the balanced portfolio needed to reliably serve customers during
all types of system conditions. When extreme cold weather or extreme hot
temperatures occur in the West, Valmy is providing reliable energy and capacity to
serve customers. Idaho Power will continue to rely on Valmy during similar
circumstances in the future as load increases in the Company's service territory and
until the addition of new resources are available during peak hours or can provide
additional transmission capacity.
APPLICATION - 5
10. In 2016, Idaho Power assessed continued use of the 2025 end-of-life
assumption for Valmy using an updated evaluation of the present value revenue
requirement of operating period alternatives, which is provided as Exhibit No. 6 to the
direct testimony of Company witness Tom Harvey that accompanies this Application .
The Company's analysis determined the net present value of the revenue requirement
associated with a 2025 end-of-life is $103 million less than the revenue requirement of a
2031/2034 retirement date, concluding that a 2025 end-of-life will strike a balance
between long-term revenue requirement savings and the immediate customer rate
impact.
IV. VALMY INVESTMENTS SINCE 2012
11. Since Idaho Power's last general rate case, Valmy plant balances have
increased approximately $70 million due to a number of investments required at Valmy
to ensure the plant continues to operate in a safe, efficient and reliable manner,
including investments required for environmental compliance, as well as a number of
investments for routine maintenance and repair. All the investments made between the
2011 test year and July 31, 2016, were necessary for either environmental compliance,
the safe and economic operation of the plant, or for reliability purposes.
12. Exhibit No. 4 to the testimony of Mr. Harvey details the investments made
at Valmy since the Company's last general rate case, including the spend per year and
whether the investment was for environmental compliance, the safe and economic
operation of the plant, or for reliability purposes. Exhibit No. 4 also includes a
description and justification of the investments made. For all planned capital projects,
Idaho Power receives from the plant operator, NV Energy, a description of the project,
the factors driving the need for the project, and a recommendation for the work to be
performed.
APPLICATION - 6
13. The investments for environmental compliance include OSI installation
and coal pipe replacement on Unit 1, the scrubber upgrade on Unit 2, the coal crusher
belt feeder project, dust collector upgrade, caustic tank building replacement,
evaporation pond liner replacement, bed demineralizer replacement, and the coal
combustion residual compliance project. In addition, a number of investments were
made at the plant and on either or both units to maintain the safe, reliable, and
economic operation of the plant. The capital investments made at Valmy since the last
general rate case were prudent and essential for continued operation of the plant.
V. ACCELERATED RECOVERY OF VALMY-RELATED COSTS
14. As described in the testimony of Mr. Harvey, evidence strongly supports
the modification of the existing Valmy depreciation schedule to reflect a 2025 shutdown
date. It is beneficial to accelerate Valmy's depreciation schedule at this time because
(1) doing so will result in the appropriate matching of cost recovery with the remaining
operating life of the plant and (2) accelerating the deprecation schedule at this time will
mitigate future rate impacts associated with the earlier shutdown of the plant.
15. The Company anticipates that customers will continue to be served by the
Valmy plant until year-end 2025, at which point the plant is no longer expected to be
utilized. By accelerating the depreciation schedule to reflect a 2025 shutdown date, the
recovery of Valmy-related costs will align with the remaining operating life of the plant,
resulting in cost recovery from customers who are served by the plant.
16. The more time that passes before the depreciation schedule at Valmy is
adjusted to reflect the 2025 retirement date, the larger the revenue requirement
increase needed to allow for full cost recovery. A delay of just 12 months would result
in an annual levelized revenue requirement of over $30.54 million and a delay of four
APPLICATION -7
years would result in an annual levelized revenue requirement amount of over $43. 75
million .
VI. RECOMMENDED REGULATORY ACCOUNTING
AND RATEMAKING TREATMENT
17. In addition to the earlier end-of-life date, Valmy will also require
incremental investments to maintain operations prior to ultimately decommissioning the
plant. However, the specific timing and exact amounts of these future investments are
not yet known. For these reasons, Idaho Power proposes the establishment of a
balancing account that would allow flexibility for the timing and recovery of the
remaining Valmy revenue requirement.
18. There are three types of costs the Company anticipates booking to the
balancing account: (1) the accelerated depreciation associated with existing Valmy
plant investments, (2) the return on the undepreciated capital investments at Valmy until
its end-of-life, and (3) decommissioning costs related to the Valmy shutdown . Under
the proposed approach, the Company will replace the base rate revenue recovery
associated with Idaho Power's existing investment in Valmy with a levelized revenue
requirement to be tracked in the Valmy balancing account.
19. The proposed accounting treatment will result in accelerated depreciation
expense related to all Valmy plant investments as compared to current depreciation that
is based on a retirement date of 2031 for Unit 1 and 2035 for Unit 2. In addition ,
although Valmy's end-of-life is expected to occur in 2025, there will be required
investments at the plant in addition to its normal maintenance to keep the plant
operational until that time, including outages scheduled in 2018 and 2019 . Both units
are on a three-year outage cycle that requires each unit to be taken down once every
three years for full inspection and selected refurbishment. The outages should be the
APPLICATION -8
last large ones performed and will help ensure the units are operational and can
continue to provide reliable service through 2025. The return and associated
depreciation expense will be tracked in the balancing account. Finally, Idaho Power is
also proposing to track decommissioning costs related to the Valmy 2025 end-of-life in
the balancing account.
20. The Valmy balancing account will smooth revenue requirement impacts of
a 2025 Valmy shutdown over the remaining eight and a half years of the plant's life and
allow for full recovery of Valmy-related costs by its end-of-life. This will effectively align
the cost recovery period with the remaining operating life of the plant, resulting in an
appropriate matching of cost recovery from customers who benefit from the plant's
operations while mitigating the risk of future customers bearing the costs of a plant that
will no longer be providing service. Additionally, through the proposed accounting
treatment, customers will pay no more or no less than the actual fixed costs of operating
the Valmy plant between the proposed effective date of June 1, 2017, and the proposed
end-of-life date in 2025.
21. The proposed accounting treatment will result in accelerated depreciation
expense related to all Valmy plant investments as compared to current depreciation
based on a retirement date of 2031 for Unit 1 and 2035 for Unit 2. As described more
fully in the direct testimony of Company witness Matthew T. Larkin that accompanies
this Application, the Company is requesting recovery of the levelized revenue
requirement that includes the costs of accelerating the depreciation of the Valmy plant,
the return associated with the Valmy capital investments net of accumulated
depreciation forecasted through the remaining life of the plant, and the
decommissioning costs associated with the Valmy 2025 end-of-life. The Idaho
APPLICATION -9
jurisdictional incremental annual levelized revenue requirement the Company is
requesting to recover in this proceeding is $28,497,934.
22. The Company proposes to allocate the increase related to the Valmy
balancing account using the jurisdictional separation study methodology consistent with
that utilized to determine the Idaho jurisdictional revenue requirement in Case No.
IPC-E-11-08. The Company requests that the incremental revenue requirement of
approximately $28.50 million be recovered from all customer classes through a uniform
percentage increase to all base rate components except the service charge. The
proposed change equates to an overall increase of 3.10 percent (see Attachment
No. 1).
VII. PROPOSED TARIFF
23. As explained above, Idaho Power is separately proposing rate changes
associated with the Depreciation Application in Case No. IPC-E-16-23 in addition to the
Valmy balancing account requested by this Application. The Company is filing one set
of proposed tariff sheets specifying the proposed rates for providing retail electric
service to its customers in the state of Idaho following the inclusion of both of the
proposed rate changes. The tariffs are being filed as Attachment Nos. 4 and 5 to the
Company's Depreciation Application , in both clean and legislative format, respectively.
24. The Company believes that filing individual sets of tariff sheets with each
case as required by RP 121 .01 would be administratively complex and would not aid
the Commission and interested parties with their review of these proposed rate
adjustments. Idaho Power considers the filing of one set of tariff sheets with the
cumulative impact of the proposed rates will comply with the spirit of the Commission's
rule. The Company will make a compliance filing when final orders are received on both
of the proposed requests to change rates effective June 1, 2017. The compliance filing
APPLICATION -10
will include tariff sheets that show the cumulative impact of rate changes associated
with both cases.
25. Attachment No. 2 to this Application shows a comparison of revenues
from the various tariff customers under Idaho Power's existing rates to the
corresponding new revenue levels resulting from the proposed Valmy ratemaking
treatment and the updated depreciation study.
VIII. MODIFIED PROCEDURE
26. Idaho Power believes that a hearing is not necessary to consider the
issues presented herein, and respectfully requests that this Application be processed
under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201
et seq. If, however, the Commission determines that a technical hearing is required, the
Company stands ready to present its testimony and support the Application in such
hearing.
IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
27. This Application will be brought to the attention of Idaho Power's
customers by means of both a press release to media in the Company's service area
and a customer notice distributed in customers' bills, both of which are accompanying
this Application. The customer notice will be distributed over the course of the
Company's current billing cycle, with the last notice being sent on December 6, 2016.
In addition to describing this filing, these customer communications also describe
proposed rate changes associated with the Company's Depreciation Application. Idaho
Power will also keep its Application open for public inspection at its offices throughout
the state of Idaho. Idaho Power asserts that this notice procedure satisfies the Rules of
Practice and Procedure of this Commission; however, the Company will, in the
APPLICATION -11
alternative, bring the Application to the attention of its affected customers through any
other means directed by the Commission.
28. Service of pleadings, exhibits, orders, and other documents relating to this
proceeding should be served on the following:
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Matt Larkin
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
X. REQUEST FOR RELIEF
29. Idaho Power respectfully requests that the Commission issue an order by
April 1, 2017, authorizing the Company to: (1) accelerate the depreciation schedule for
Valmy to allow the plant to be fully depreciated by December 31, 2025, (2) establish a
balancing account to track the incremental costs and benefits associated with the
accelerated Valmy end-of-life date, and (3) adjust customer rates to recover the
associated incremental annual levelized revenue requirement of $28,497,934 with an
effective date of June 1, 2017.
DATED at Boise, Idaho, this 21 51 day of October 2016.
~£2 .~Mrn= LJSD.NORDSTi OM
Attorney for lda~ower Company
APPLICATION -12
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-24
IDAHO POWER COMPANY
ATTACHMENT NO. 1
Idaho Power Company
Calculation of Revenue Impact 2017 -2018
State of Idaho
Valmy Plant Depreciable Life
Filed October 21, 2016
Summary of Revenue Impact
Current Billed Revenue to Proposed Billed Revenue
Total Percent
Rate Average Normalized Current Adjustments Proposed Change
Line Sch. Number of Energy Billed Mills to Billed Total Billed Mills Billed to Billed
No Tariff Description No. Customers 11> (kWh)1'l Revenue Per kWh Revenue Revenue Per kWh Revenue
Uniform Tariff Rates:
1 Residential Service 1 435,407 5,011 ,095,429 $510,150,917 101.80 $12,357,022 $522,507,939 104.27 2.42%
2 Master Metered Mobile Home Park 3 22 4,157,443 $406,059 97.67 $10,345 $416,405 100.16 2.55%
3 Residential Service Energy Watch 4 0 0 $0 0.00 $0 $0 0.00 N/A
4 Residential Service Time-of-Day 5 1,304 24,071 ,367 $2,365,671 98.28 $58,283 $2,423,955 100.70 2.46%
5 Small General Service 7 27,766 123,114,157 $15,795,244 128.30 $363,195 $16,158,439 131.25 2.30%
6 Large General Service 9 35,288 3,767,082,018 $273,952,670 72.72 $7,064,758 $281 ,017,428 74.60 2.58%
7 Dusk to Dawn Lighting 15 0 6,361 ,595 $1 ,292,427 203.16 $36,276 $1 ,328,703 208.86 2.81%
8 Large Power Service 19 113 2,210,706,735 $128,106,195 57.95 $3,316,216 $131 ,422,411 59.45 2.59%
9 Agricultural Irrigation Service 24 18,485 1,867,191,356 $149,024,634 79.81 $3,928,428 $152,953,062 81.92 2.64%
10 Unmetered General Service 40 1,359 11,414,394 $994,146 87.10 $26,771 $1 ,020,917 89.44 2.69%
11 Street Lighting 41 1,742 27,412,831 $3,609,056 131.66 $99,040 $3,708,095 135.27 2.74%
12 Traffic Control Lighting 42 563 2,811,020 $178,096 63.36 $4,671 $182,767 65.02 2.62%
13 Total Uniform Tariffs 522,049 13,055,418,345 $1,085,875,115 83.17 $27,265,006 $1 ,113,140,121 85.26 2.51%
14 Special Contracts:
15 Micron 26 1 549,560,120 $28,305,770 51.51 $724,865 $29,030,635 52.83 2.56%
16 JR Simplot 29 1 192,745,251 $9,369,630 48.61 $238,092 $9,607,722 49.85 2.54%
17 DOE 30 1 209,846,587 $10,572,786 50.38 $269,971 $10,842,757 51.67 2.55%
18 Total Special Contracts 3 952,151 ,958 $48,248,186 50.67 $1,232,928 $49,481,114 51 .97 2.56%
19 Total Idaho Retail Sales 522,052 14,007,570,303 $1,134,123,301 80.97 $28,497,934 $1,162,621,235 83.00 2.51%
(1) June 1, 2017 -May 31, 2018 Forecasted Test Year
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-24
IDAHO POWER COMPANY
ATTACHMENT NO. 2
Idaho Power Company
Calculation of Revenue Impact 2017 -2018
State of Idaho
Valmy Plant Depreciable Life and Depreciation Study Combined
Filed October 21, 2016
Summary of Revenue Impact
Current Billed Revenue to Proposed Billed Revenue
Total Percent
Rate Average Normalized Current Adjustments Proposed Change
Line Sch. Number of Energy Billed Mills to Billed Total Billed Mills Billed to Billed
No Tariff Description No. Customers ('l (kWhl('l Revenue Per kWh Revenue Revenue Per kWh Revenue
Uniform Tariff Rates:
Residential Service 1 435,407 5,011,095,429 $510,150,917 101 .80 $15,250,330 $525,401,247 104.85 2.99%
2 Master Metered Mobile Home Park 3 22 4,157,443 $406,059 97.67 $12,768 $418,827 100.74 3.14%
3 Residential Service Energy Watch 4 0 0 $0 0.00 $0 $0 0.00 N/A
4 Residential Service Time-of-Day 5 1,304 24,071,367 $2,365,671 98.28 $71,930 $2,437,601 101.27 3.04%
5 Small General Service 7 27,766 123,114,157 $15,795,244 128.30 $448,235 $16,243,479 131.94 2.84%
6 Large General Service 9 35,288 3,767,082,018 $273,952,670 72.72 $8,718,921 $282,671 ,591 75.04 3.18%
7 Dusk to Dawn Lighting 15 0 6,361,595 $1 ,292,427 203.16 $44,770 $1 ,337,197 210.20 3.46%
8 Large Power Service 19 113 2,210,706,735 $128,106,195 57.95 $4,092,685 $132,198,879 59.80 3.19%
9 Agricultural Irrigation Service 24 18,485 1,867,191 ,356 $149,024,634 79.81 $4,848,241 $153,872,875 82.41 3.25%
10 Unmetered General Service 40 1,359 11 ,414,394 $994,146 87.10 $33,040 $1 ,027,185 89.99 3.32%
11 Street Lighting 41 1,742 27,412,831 $3,609,056 131.66 $122,229 $3,731 ,285 136.11 3.39%
12 Traffic Control Lighting 42 563 2,811 ,020 $178,096 63.36 $5,765 $183,860 65.41 3.24%
13 Total Uniform Tariffs 522,049 13,055,418,345 $1 ,085,875,115 83.17 $33,648,913 $1 ,119,524,028 85.75 3.10%
14 Special Contracts:
15 Micron 26 1 549,560,120 $28,305,770 51 .51 $894,587 $29,200,357 53.13 3.16%
16 JR Simplot 29 1 192,745,251 $9,369,630 48.61 $293,839 $9,663,469 50.14 3.14%
17 DOE 30 1 209,846,587 $10,572,786 50.38 $333,183 $10,905,969 51.97 3.15%
18 Total Special Contracts 3 952,151 ,958 $48,248,186 50.67 $1 ,521 ,609 $49,769,795 52.27 3.15%
19 Total Idaho Retail Sales 522,052 14,007,570,303 $1,134,123,301 80.97 $35,170,522 $1,169,293,823 83.48 3.10%
(1) June 1, 2017 -May 31, 2018 Forecasted Test Year