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Dr. Broehm is an economic expert in the electric utility industry specializing in the areas of market competition, impacts of regulatory policies on wholesale power markets and power assets and valuation, and the evaluation of power procurement.

Dr. Broehm has has assisted clients in both litigation and consulting settings. She has submitted testimony in a number of market-based rate (MBR) proceedings before the Federal Energy Regulatory Commission (FERC). She has analyzed potential competitive impacts of M&A transactions on wholesale power markets for both horizontal and vertical market power aspects in various power markets, such as ISO-NE, NYISO, PJM, SERC, FRCC, SPP, Entergy System, and WECC. She has also led numerous studies related to price forecasting and short- and long-term marginal costs, and advised utilities on how potential demand-side management and demand response programs could impact both integrated resource planning and economic evaluations of generation and transmission expansions.

Dr. Broehm has experience analyzing and testifying on potential market manipulation allegations. She co-authored comments submitted to the Commodity Futures Trading Commission (CFTC) that proposed a practical definition of market manipulation. She has also presented on navigating the complexities of the Dodd–Frank Wall Street Reform and Consumer Protection Act, which focuses on how energy companies should address the economic, governance, regulatory, and transaction issues they will face as they begin implementing the requirements of the Act.

In addition, Dr. Broehm provides to her clients analyses and litigation support on the prudence of particular investment decisions and power procurement decisions, as well as the valuation of "provider of last resort" supplies. Her experience in pricing and ratemaking includes designing and evaluating dynamic pricing programs, such as a real-time pricing programs and block rate designs. She has implemented demand simulation models to analyze changes in net economic benefits due to changes in rate design.

Prior to joining The Brattle Group, Dr. Broehm taught Economics and Statistics at the University of Wisconsin-Milwaukee and Cardinal Stritch College.

Testimony

Affidavit on behalf of Arizona Public Service Company, Section 203 Application of Arizona Public Service Company Requesting Authorization for Acquisition of El Paso Electric's Ownership Interest in Four Corners Power Plant under EC15-159, before the Federal Energy Regulatory Commission, Docket No. EC15-159-000

June 26, 2015
Affidavits regarding Triennial Update Market-Based Rate Filing and Change-in Status, United States of America before the Federal Energy Regulatory Commission, 2005 – Present. Market areas cover the Northeast, WSCC and Florida
2005 to Present
Testimonies on behalf of the California Parties, United States of America before the Federal Energy Regulatory Commission, Puget Sound Energy, Inc., Complainant, v. All Jurisdictional Sellers of Energy and/or Capacity at Wholesale into Electric Energy and/or Capacity Markets in the Pacific Northwest, Including Parties to the Western System Power Pool Agreement, Respondents, Docket No. EL01-10-085
2012-2013
Independent Auction Monitor, Annual Report for Southern Companies’ Energy Auction April 23, 2009 to February 10, 2009, The Brattle Group, Federal Energy Regulatory Commission, Docket Nos. 09-88
April 2010
Affidavit on Behalf of Watson Cogeneration Company, Application of Watson Cogeneration Company for Order Accepting Initial Market-Based Tariff, Waving Regulations, and Granting Blanket Approvals, Federal Energy Regulatory Commission, Docket No. ER08-337
December 2007
Affidavit with Dr. Fox-Penner on Behalf of American Wind Energy Association, The Wind Coalition, and John Deere Renewables, LLC, Motion to Intervene and Protest Opposing SPP IOU’s Request to Terminate PURPA Purchase Obligations, Federal Energy Regulatory Commission, Docket No. QM07-5
November 2007
Publications
Report
Market Power Screens and Mitigation Options for AESO Energy and Ancillary Service Markets
January 26, 2018
Prepared for the Alberta Electric System Operator (AESO)
Presentation
U.S. Federal and State Regulations: Opportunities and Challenges for Electricity Storage
November 02, 2017
Presented at BIT Congress, Inc.'s 7th World Congress of Smart Energy
Report
Comments of Drs. Romkaew Broehm, Jeremy Verlinda, and James Reitzes to the Federal Energy Regulatory Commission Regarding Modifications to Commission Requirements for Review of Transaction Under Section 203 of the Federal Power Act and Market-Based Rate Applications under Section 205 of the Federal Power Act (Docket No. RM16-21-000)
November 28, 2016
Prepared for the Federal Energy Regulatory Commission
The comments offer commentary on four proposed changes by the FERC regarding its horizontal market power review standards for M&A and market-based rate approvals.
Report
Market Power Analysis of Proposed Transaction Between Duke Energy Corporation and Piedmont Natural Gas Company
January 2016
Prepared for the North Carolina Utilities Commission
Book
Market Power and Market Manipulation in Energy Markets: From the California Crisis to the Present
April 2015
Gerald A. Taylor, Shaun D. Ledgerwood, Romkaew P. Broehm, Peter S. Fox-Penner, Romkaew P. Broehm, Shaun D. Ledgerwood, Gerald A. Taylor, and Peter S. Fox-Penner
Published by PUR Inc.
Report
Comments of Dr. Romkaew Broehm and Mr. Gerald A. Taylor to the Federal Energy Regulatory Commission Regarding Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities (Docket No. RM14-14-000)
September 2014
Prepared for the Federal Energy Regulatory Commission
Presentation
Electric Utility Integrated Resource Plan (IRP): Demand-Side Resources
July 16, 2014
Presented to the Thai Energy Regulatory Commission, OERC, and Utilities Delegation, Boston, MA
Report
Summary of Proposed Refinements to Market-Based Rates Policies & Procedures
June 2014
Romkaew P. Broehm and Richard Sweet
Published by The Brattle Group, Inc., in response to Notice of Proposed Rule Making (Docket No. RM14-14)
Presentation
Is It Possible to Charge Market-Based Pricing for Ancillary Services in a Non-ISO Market? Regulation and Operating Reserves
May 16, 2014
Presented at the Center for Research in Regulated Industries 33rd Eastern Conference
Article
Dodd Frank Compliance for Oil and Gas Companies
February 06, 2012
Julia E. Sullivan, Cary Oswald, and Romkaew P. Broehm
Published in Oil & Gas Monitor
Report
Comments of Romkaew P. Broehm, Peter S. Fox-Penner, Oliver Grawe, and James Reitzes to the Federal Energy Regulatory Commission Regarding the Analysis of Horizontal Market Power Under the Federal Power Act, Docket No. RM11-14-000
May 23, 2011
Prepared for Federal Energy Regulatory Commission Staff
Report
Comments of Romkaew P. Broehm and Peter S. Fox-Penner, re: Market-Based Rates for Wholesale Sales Of Electric Energy, Capacity and Ancillary Services by Public Utilities
May 2011
Report
Losing Money to Increase Profits: A Proposed Framework for Defining Market Manipulation
March 2011
Published by The Brattle Group, Inc.
Report
Comments of Dr. Daniel Arthur, Dr. Romkaew P. Broehm, and Mr. Gerald A. Taylor to the Commodity Futures Trading Commission Regarding the Notice of Proposed Rulemaking on the Prohibition of Market Manipulation, 17 CFR Part 180
January 2011
Prepared for the Commodity Futures Trading Commission
Report
Changes to the FERC's Market-Based Rates Requirements
June 2007
Published by The Brattle Group, Inc.
Report
Comments on the FERC Notice of Proposed Rulemaking on Market Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities (with Peter S. Fox-Penner), Docket No. RM04-7
August 07, 2006
Published by The Brattle Group, Inc.
Article
The New Art of Plant Acquisition
June 2006
Published in Public Utilities Fortnightly
Report
Deregulated Electricity Pricing in the U.S.: Dramatic New Rules From the FERC
April 25, 2004
Published by The Brattle Group, Inc.
Article
The Regulation of Competition in Wholesale Electric Power Markets
October 2002
Published in Energy Law Journal
Article
Price-Responsive Electric Demand: A National Necessity, Not an Option
2002
In Electricity Pricing in Transition, edited by Ahmad Faruqui and B. Kelly Eakin, and published by Springer
Report
Impact of Changing Fuel and Power Market Structures on Price Behavior
2001
Published by Electric Power Research Institute (EPRI)
Report
How Competitive Market Dynamics Affect Coal, Nuclear and Gas Generation and Fuel Use — A 10 Year Look Ahead
1999
Published by Electric Power Research Institute (EPRI) and Gas Research Institute (GRI)
Report
Energy Market Impacts of Electric Industry Restructuring: Understanding Wholesale Power Transmission and Trading, Final Report
March 1998
Lynda S. Borucki, Romkaew P. Broehm, Frank C. Graves, S.L. Thumb, and A.M. Schaal
Published by Electric Power Research Institute (EPRI)
News & Events
May 03, 2018
Romkaew Broehm to Present on Market Design at Petroleum Institution of Thailand's Seminar

Brattle Principal Romkaew Broehm will present during the Petroleum Institution of Thailand’s (PTIT) Seminar, taking place May 3, 2018 in Bangkok, Thailand.

November 02, 2017
Romkaew Broehm to Present at BIT's World Congress of Smart Energy

Brattle Principal Romkaew Broehm will present at BIT Congress, Inc.’s World Congress of Smart Energy, taking place November 2-4, 2017 in Wuxi, China.

June 01, 2017
Brattle Economists to Present at Rutgers Center for Research in Regulated Industries Annual Eastern Conference

Several Brattle consultants will present at Rutgers Center for Research in Regulated Industries’ (CRRI) 36th Annual Eastern Conference, taking place May 31 to June 2, 2017 in Annapolis, MD.

September 12, 2016
Brattle Consultants Contribute to Significant Win for the State of California on Energy Crisis Tariff Violations

Testimony by Brattle consultants contributed to a favorable outcome for the State of California in a recent decision by the U.S. Court of Appeals for the Ninth Circuit, which upheld a ruling by the Federal Energy Regulatory Commission (FERC) finding that several electric power sellers committed tariff violations during the California Energy Crisis in the summer of 2000.

July 18, 2016
Analysis by Brattle Economists Cited in FERC Decision on MISO’s Export Pricing to PJM for MVPs

A recent order issued by the Federal Energy Regulatory Commission (FERC) on export pricing cites an analysis conducted by Brattle Academic Advisor Peter Fox-Penner and Principal Romkaew Broehm on behalf of the Midcontinent Independent Transmission System Operation (MISO) and MISO Transmission Owners.

April 13, 2016
Brattle Consultants Contribute to Significant Win for the State of California on Energy Crisis Long-Term Contracts

Based on evidence presented by Brattle consultants, a FERC Administrative Law Judge issued a ruling that found that the Mobile-Sierra doctrine does not protect two long-term wholesale electricity contracts entered into during the Western Energy Crisis in 2001.

May 20, 2015
Brattle to Sponsor Symposium on Market Power and Market Manipulation in Energy Markets

The Brattle Group will be sponsoring the upcoming program, “A Symposium on Market Power and Market Manipulation in Energy Markets," taking place Wednesday, May 20th, 2015 and hosted by the Center for Business & Public Policy at Georgetown University's McDonough School of Business.

April 14, 2015
Brattle Consultants Release Book on Market Power and Market Manipulation in Energy Markets

Brattle principals Gerald Taylor, Shaun Ledgerwood, Romkaew Broehm, and Peter Fox-Penner have authored a book that provides insights and an analytical framework for understanding the legal and economic nuances associated with energy market manipulation. Market Power and Market Manipulation in Energy Markets: From the California Crisis to the Present will be published in April 2015 by PUR Inc.

November 18, 2014
Brattle Economists Contribute to FERC Ruling Supporting Findings of Manipulative Behavior by Power Suppliers During the California Energy Crisis

Testimony provided by Brattle consultants supported a FERC order affirming the initial decision in the matter of San Diego Gas & Elec. Co. v. Sellers of Energy and Ancillary Servs, which found power suppliers engaged in manipulative behavior during the California Energy Crisis.

July 16, 2014
Brattle Consultants Lead Demand Response Workshop Before Thai Energy Regulatory Commission and Utilities Delegation

Brattle consultants presented a half-day workshop on the growth of demand response technology in the electric utility industry before the Energy Regulatory Commission of Thailand, along with other representatives on July 16, 2014 at EnerNOC’s Boston headquarters.