Frank C. Graves
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principal
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Boston
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.
MIT Sloan School of Management, MS, concentration in Finance
Indiana University, BA in Mathematics
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.
Testimony
For PacifiCorp in Oregon, testimony in Feb 2020 in regard to why the company was systematically underrecovering fuel and purchased power costs relative to forecasted amounts allowed in rates. He showed that there is an inherent cost to balancing variances in short-term power needs (e.g. due to unexpected load levels or unexpected changes in plant performance) regardless of whether the realized needs are higher or lower than had been forecasted. This is because excess demands tend to be correlated across a market and so will usually have to be purchased at higher than expected prices, while demand shortfalls will tend to have to be released at lower prices than the costs of covering the expected need. Either way, there is a loss (or an extra cost). He testified that there is no good forecasting solution for this, so it would be more appropriate to eliminate risk sharing of these variances and flow them through, subject to periodic prudence review adjustments. His testimony reviewed automatic adjustment clauses and risk-sharing for all major utilities in the US not operating in RTOs.
In an arbitration matter involving alleged lost productivity at a wind farm due to wake effects from another upstream wind fleet, Mr. Graves provided rebuttal testimony on the claimed damages. Capacity and energy values, as well as risks and drivers of uncertainty for the likely output quantities were presented, explaining how prices and utilization of the facilities were likely to change over a twenty-year horizon in a deeply decarbonizing power system.
For Nicor Gas, a natural gas distribution company, Mr. Graves co-authored testimony on the cost of equity capital utilizing a broad spectrum of risk-pricing methods and explaining how financial leverage affects it. Testimony was filed with the Illinois Commerce Commission, Docket 18-xxxx, November 9, 2018.
On behalf of Public Service Company of New Mexico, presented testimony before the New Mexico Public Regulation Commission on the merits of replacing the San Juan Generating Station coal units with a fleet of renewables, storage and gas-fired peakers, and on the reasons for appropriateness of allowing full recovery of sunk costs despite early retirement. Case No. 19-00018-UT, November 15, 2019.
