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Mr. Graves, the leader of the firm’s Utilities practice, specializes in regulatory and financial economics, especially for electric and gas utilities, and in litigation matters related to securities litigation and risk management.

He has over 30 years of experience assisting utilities in forecasting, valuation, and risk analysis of many kinds of long-range planning and service design decisions, such as generation and network capacity expansion, supply procurement and cost recovery mechanisms, network flow modeling, renewable asset selection and contracting, and hedging strategies. He has testified before the Federal Energy Regulatory Commission (FERC) and many state regulatory commissions, as well as in state and federal courts, on such matters as integrated resource planning (IRP), the prudence of prior investment and contracting decisions, risk management, costs and benefits of new services, policy options for industry restructuring, adequacy of market competition, and competitive implications of proposed mergers and acquisitions.

In the area of financial economics, he has assisted and testified in civil cases in regard to contract damages estimation, securities litigation suits, special purpose audits, tax disputes, risk management, and cost of capital estimation, and testified in criminal cases regarding corporate executives’ culpability for securities fraud.

Representative Engagements
Strategy review and diagnostics
For the Board of Directors or executive management teams of several utilities, led strategic retreats on disruptive issues facing the electric industry in the future and how a utility should choose which risks and opportunities to embrace versus avoid.
Pricing of long-term power supply contracts
Successful merchant power plant development and financing depends in part on obtaining a long-term power purchase agreement. Directed a study of what pricing points and risk-sharing terms should be attractive to potential buyers of long-term power supply contracts from a large baseload facility.
Research on the performance of alternative market designs in the power industry
For a major participant in the Japanese power industry contemplating reorganization of that country’s electric sector following Fukushima, led a research project on the performance of alternative market designs in the U.S. and around the world for vertical unbundling, RTO design, and retail choice.
Risk Management Workshops
For several utilities facing disputes over appropriate use of their hedging strategies, Mr. Graves has conducted a series of workshops before state public service commissions (PSC) for stakeholders in natural gas procurement costs. Developed a series of presentations providing a framework for discussing hedging strategies and aimed at ensuring all stakeholders were aware of the pros and cons of specific approaches to enable reaching a consensus about the trade-off between risk management and ex post regret. As a result of these workshops, new modes of hedging were agreed upon and have been used without controversy for several hedging seasons.
Developed financial reporting normalization adjustments tool
For a holding company with utility subsidiaries in several states, developed a means of normalizing financial statements so that multi-year performance could be compared across companies. Goal was to determine how much of performance gains was due to regulatory outcomes, managerial control, financial practices, or just luck, and what changes should be considered part of a sustainable trend versus non-recurring circumstances.
Testimony
Direct testimony in regard to a claim for a share of lime consumption reduction costs obtained by Plum Point as one of SMEPA’s power plant operator/suppliers, on behalf of SMEPA, before the American Arbitration Association in the matter of Southwest Mississippi Electric Power Association vs. Plum Point Energy Associates, Case No. 01-15-0002-6062
September 2016
Direct testimony in regard to a claim for a share of lime consumption reduction costs obtained by Plum Point as one of SMEPA’s power plant operator/suppliers, on behalf of SMEPA, before the American Arbitration Association in the matter of Southwest Mississippi Electric Power Association vs. Plum Point Energy Associates, Case No. 01-15-0002-6062
September 01, 2016
Direct, Rebuttal and Supplementary Rebuttal reports regarding damages from loss of a nuclear generation facility, on behalf of Southern California Edison Company, Edison Material Supply LLC., San Diego Gas and Electric Company and City of Riverside before the International Chamber of Commerce in the matter of Southern California Edison v. Mitsubishi Nuclear Energy Systems, Inc. and Mitsubishi Heavy Industries, Ltd., Case No. 19784/AGF/RD
July 27, 2015 (direct), January 19, 2016 (rebuttal), and March 14, 2016 (supplemental)
Direct, Rebuttal and Supplementary Rebuttal reports regarding damages from loss of a nuclear generation facility, on behalf of Southern California Edison Company, Edison Material Supply LLC., San Diego Gas and Electric Company and City of Riverside before the International Chamber of Commerce in the matter of Southern California Edison v. Mitsubishi Nuclear Energy Systems, Inc. and Mitsubishi Heavy Industries, Ltd., Case No. 19784/AGF/RD
July 27, 2015 (direct), January 19, 2016 (rebuttal), and March 14, 2016 (supplemental)
Direct report re determination of an appropriate level of return needed for Standard Offer Service (SOS), on behalf of Delmarva Power & Light Company and Potomac Electric Power Company before the Maryland Public Service, Case Nos. 9226 and 9232
July 24, 2015
Direct report re determination of an appropriate level of return needed for Standard Offer Service (SOS), on behalf of Delmarva Power & Light Company and Potomac Electric Power Company before the Maryland Public Service, Case Nos. 9226 and 9232
July 24, 2015
Direct testimony in regard to the prudence of its gas hedging, on behalf of Hope Gas, Inc., before the West Virginia Public Service Commission, Case No. 12-1070-G-30C
June 24, 2013
Direct testimony in regard to the prudence of its gas hedging, on behalf of Hope Gas, Inc., before the West Virginia Public Service Commission, Case No. 12-1070-G-30C
June 24, 2013
Direct testimony on behalf of Public Service Company of New Mexico before the NM Public Regulation Commission re appropriate profit incentives for energy conservation activities, Case No. 12-00317-UT
October 5, 2012
Expert and Rebuttal reports on spent fuel removal at Trojan nuclear facility, on behalf of Portland General Electric Company, The City of Eugene, Oregon, and PacifiCorp before the United States Court of Federal Claims No. 04-0009C
August 2010, June 29, 2011
Expert and Rebuttal reports regarding contract termination damages, on behalf of Hess Corporation before the Unites States District Court for the Northern District of New York, Case No. 5:10-cv-587 (NPM/GHL)
April 29, 2011, May 13, 2011
Rebuttal and Rejoinder testimonies on the approval of its Smart Meter Technology Procurement and Installation Plan before the Pennsylvania Public Utility Commission on behalf of West Penn Power Company d/b/a Allegheny Power, Docket No. M-2009-2123951
October 27, 2009, November 6, 2009
Supplemental Direct testimony on the need for an energy cost adjustment mechanism in Utah to recover the costs of fuel and purchased power, on behalf of Rocky Mountain Power before the Public Service Commission of Utah, Docket No. 09-035-15
August 2009
Oral and written direct testimony regarding resource procurement and portfolio design for Standard Offer Service, on behalf of PEPCo Holdings Inc. in is Response to Maryland Public Service Commission, Case No. 9117
October 1, 2008, December 15, 2008
Direct testimony in support of Delmarva’s “Application for the Approval of Land-Based Wind Contracts as a Supply Source for Standard Offer Service Customers,” on behalf of Delmarva Power & Light Company before the Public Service Commission of Delaware
July 24, 2008
Direct and rebuttal testimonies on the shareholder impacts of Dynegy’s Project Alpha for the sentencing of Jamie Olis, on behalf of the U.S. Department of Justice before the United States District Court, Southern District of Texas, Houston Division, Criminal Number H-03-217
September 12, 2006
Expert report, April 1, 2002, and oral testimony, February 17, 2003, before the United States District Court, Southern District of Ohio, Eastern Division on behalf of Ohio Edison Company and Pennsylvania Power Company, Civil Action No. C2-99-1181, regarding coal plant maintenance projects alleged to trigger New Source Review
February 17, 2003
Publications
Report
Resetting FERC ROE Policy: A Window of Opportunity
May 2018
Published by The Brattle Group, Inc.

The whitepaper discusses potential long-term changes to the Federal Energy Regulatory Commission's (FERC) return on equity (ROE) policy.

Report
The Future of Cap-and-Trade Program in California: Will Low GHG Prices Last Forever?
December 05, 2017
Yingxia Yang, Michael Hagerty, Ashley Palmarozzo, Hannah Sheffield, Metin Celebi, Marc Chupka, and Frank C. Graves
Published by The Brattle Group, Inc.

A discussion paper examining the trends of the California greenhouse gas (GHG) market and analyzes the underlying future drivers that will affect California GHG prices to achieve the state’s ambitious goal of 80% decarbonization by 2050.

Presentation
Modeling the Utility of the Future and Developing Strategies to Adapt and Lead
September 2017
Presented at Edison Electric Institute’s (EEI) Strategic Issues Roundtable
Article
Using Electric And Gas Forwards To Manage Market Risks
May 2017
Published in North American Windpower
Report
LIPA Generation Planning Review: Caithness Long Island II, and E.F. Barrett and Port Jefferson Repowerings
April 06, 2017
Prepared for the Long Island Power Authority (LIPA)
Report
Nuclear Retirement Effects on CO2 Emissions: Preserving a Critical Clean Resource
December 2016
Published by The Brattle Group, Inc.
Article
How Will The EPA's Clean Power Plan Impact Wind?
July 01, 2014
Published in North American Windpower
Article
Computerized and High-Frequency Trading
May 2014
Published in The Financial Review, Vol. 49, No. 2
Presentation
Power Market Prices, Nuclear Generation & Greenhouse Gas Policy
February 04, 2014
Presented at the EUEC 2014 Conference
Report
Coal Plant Retirements: Feedback Effects on Wholesale Electricity Prices - Revised
November 2013
Published by The Brattle Group, Inc.
Article
Low Tech Resilience
September 2013
Published in Fortnightly Magazine
Article
Low Voltage Resiliency Insurance:  Ensuring Critical Service Continuity During Major Power Outages
September 2013
Published in Public Utilities Fortnightly
Report
Potential Coal Plant Retirements: 2012 Update
October 2012
Metin Celebi, Frank C. Graves, and Charles Russell
Published by The Brattle Group, Inc.
Report
Centralized Dry Storage of Nuclear Fuel: Lessons for U.S. Policy from Industry Experience and Fukushima
August 2012
Frank C. Graves, Mariko Geronimo Aydin, and Glen A. Graves
Published by The Brattle Group, Inc.
Report
The Emerging Need for Greater Gas-Electric Industry Coordination, comments to the FERC NOI, Docket AD12-12-000
March 30, 2012
Published by The Brattle Group, Inc.
Report
Analysis of Strategic Organizational Options for the Long Island Power Authority
October 2011
William P. Zarakas, Frank C. Graves, and Michael J. Beck
Prepared for The Long Island Power Authority
Presentation
Dodd-Frank and Its Impact on Hedging Strategies
February 10, 2011
Presented at Law Seminars International Electric Utility Rate Cases Conference
Newsletter
Trading at the Speed of Light: The Impact of High-Frequency Trading on Market Performance, Regulatory Oversight, and Securities Litigation
2011
Published by The Brattle Group, Inc.
Report
Managing Natural Gas Price Volatility: Principles and Practices Across the Industry
November 2010
Prepared for the American Clean Skies Foundation
Presentation
A Changing Environment for Distcos
March 15, 2010
Presented at NMSU Center for Public Utilities, The Santa Fe Conference, Santa Fe, NM
Article
Risk-Adjusted Damages Calculation in Breach of Contract Disputes: A Case Study
2010
Frank C. Graves, Bin Zhou, Melvin Brosterman, and Quinlan Murphy
Published in Journal of Business Valuation and Economic Loss Analysis
Article
Hedging Effects of Wind on Retail Electric Supply Costs
December 2009
Frank C. Graves and Julia Litvinova
Published in The Electricity Journal
Presentation
Some Theory on Price and Volatility Modeling
January 2009
Frank C. Graves and Julia Litvinova
Published by The Brattle Group, Inc.
Report
Volatile CO2 Prices Discourage CCS Investment
January 2009
Published by The Brattle Group, Inc.
Article
Utility Automatic Adjustment Clauses Revisited: Why They Are Needed More Than Ever
June 2007
Frank C. Graves, Philip Q Hanser, and Gregory N. Basheda
Published in The Electricity Journal
Article
Utility Supply Portfolio Diversity Requirements
June 2007
Published in The Electricity Journal
Presentation
How Transmission Grids Fail
March 22, 2004
Frank C. Graves and Martin L. Baughman
Presented at the NARUC Staff Subcommittee on Accounting and Finance, Spring 2004 Meeting, Scotsdale, AZ
Article
Transmission Management in the Deregulated Electric Industry: A Case Study on Reactive Power
October 2003
Published in The Electricity Journal
Report
Economic Cost of the August 14th 2003 Northeast Power Outage: Preliminary Estimate
August 18, 2003
Lisa V. Wood and Frank C. Graves
Published by The Brattle Group, Inc.
Presentation
POLR and Progress Towards Retail Competition – Can Kindness Kill the Market?
2001
Presented at the Winter Committee Meeting of NARUC
Presentation
Capturing Value with Energy Storage in the Energy and Reserve Markets
September 18, 2000
Frank C. Graves, Thomas Jenkin, Dean M. Murphy, and Rachel Polimeni
Presented at the Electric Energy Storage Applications and Technology Conference, Orlando, FL
Presentation
Stages of Power Plant Development – A Survey
August 2000
Presented at Electric Power Research Institute conference on “Boom-Bust” business cycles in the power industry, Cambridge, MA
Article
PBR Designs for Transcos: Toward a Competitive Framework
August 2000
Frank C. Graves and Steven E. Stoft
Published in The Electricity Journal
Article
Opportunities for Electricity Storage in Deregulating Markets
1999
Dean M. Murphy, Frank C. Graves, and Thomas Jenkin
Published in The Electricity Journal
Report
Pipeline Pricing to Encourage Efficient Capacity Resource Decisions, Filed on behalf of Columbia Gas Transmission Corporation, et al., FERC Docket No. PL98-2-000
February 1998
Published by The Brattle Group, Inc.
Article
Price Caps for Standard Offer Service: A Hidden Stranded Cost
1998
Frank C. Graves and Paul C. Liu
Published in The Electricity Journal
Article
The Economics of Negative Barriers to Entry: How to Recover Stranded Costs and Achieve Competition on Equal Terms in the Electric Utility Industry
1997
Published in Natural Resources Journal
Report
Optimal Use of Ancillary Generation Under Open Access and its Possible Implementation
1995
Frank C. Graves and Marija D. Ilic
Published by M.I.T. Laboratory for Electromagnetic and Electronic Systems Technical Report
News & Events
May 21, 2018
Brattle Economists Outline Recommendations for Reformulating FERC ROE Policy in New Whitepaper

Brattle economists have authored a whitepaper that discusses potential long-term changes to the Federal Energy Regulatory Commission's (FERC) return on equity (ROE) policy.

April 17, 2018
Frank Graves and Hannes Pfeifenberger to Present at Gulf Coast Power Association's Spring Conference

Brattle Principals Frank Graves and Hannes Pfeifenberger will moderate sessions at the Gulf Coast Power Association’s (GCPA) 32nd Annual Spring Conference, taking place April 17-18, 2018 in Houston, TX.

December 05, 2017
Reaching California's Deep Decarbonization Goals May Require Large Increases in Carbon Prices in the Absence of Further Technological Breakthroughs, According to Brattle Economists

A discussion paper by economists at The Brattle Group examines the trends of the California greenhouse gas (GHG) market and analyzes the underlying future drivers that will affect California GHG prices to achieve the state’s ambitious goal of 80% decarbonization by 2050. 

September 27, 2017
Frank Graves to Present at Edison Electric Institute’s Strategic Issues Roundtable

Brattle Principal Frank Graves will present at Edison Electric Institute’s (EEI) Strategic Issues Roundtable, taking place September 27-29, 2017 in New Orleans, LA.

May 14, 2015
Brattle Experts Assist in Securing Favorable Outcome for Client in Nortel’s Bankruptcy Allocation Trial

A decision reached by the Courts' regarding the allocation of Nortel's $7.3 billion liquidation proceeds relied heavily on the findings by Brattle experts.

October 29, 2014
Brattle Featured in Bloomberg Businessweek for Report on the Potential Impact of Coal Plant Retirements on Future Power Prices

The Brattle Group was recently featured in a Bloomberg Businessweek article, “Breathing Cleaner Air to Cost Americans on Utility Bills,” which outlines the implications U.S. electricity markets will face as clean-air regulations shut down more coal-fired power plants, forcing producers to rely more on natural gas.

October 09, 2014
Frank Graves and Steve Levine to Participate in American Gas Association’s Seventh Annual Energy Market Regulation Conference

Brattle principals Frank Graves and Steve Levine will be speaking at the upcoming American Gas Association’s Seventh Annual Energy Market Regulation Conference, taking place October 9, 2014 in New Orleans, LA.

August 08, 2014
Brattle Consultants Provide Expert Testimony and Litigation Support in Recently-Concluded Nortel Bankruptcy Proceedings

The Brattle Group was retained by counsel for the UK Pension claimants to opine on allocation and claims issues in Nortel’s bankruptcy proceedings. Brattle experts sponsored and supported two testifying experts in recently-concluded trials.

June 02, 2014
Brattle Economists Revisit Findings on Potential Effects of Carbon Emissions Rulemakings Ahead of EPA's Clean Air Act

In anticipation of the EPA's proposed guidelines under Section 111(d) of the Clean Air Act, The Brattle Group has released a compendium of prior studies examining the effects of a potential carbon emissions rulemaking.

Personal Interests

Frank is an active professional violinist, performing frequently with freelance orchestra groups in the Boston area.

He has a second degree black belt in Tae Kwon Do, which is his main form of exercise.

In addition, Frank is an avid birdwatcher and wine aficionado.