Mr. Graves 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.
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.
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.
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.
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.
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.
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 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, 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
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.