Free Response to Motion - District Court of Federal Claims - federal

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Principal

FrankC. Graves

reprice pipeline services. In addition to traditional DCFandrisk positioning ~cfi~; the fisk implications of different degrees of financial leverage (debt capitalizAtion)

were modeled and quantified. J\spec~ of rate design and Cost allocation betWeen '

services that also affect pipeline risk were considered.
Mr. Graves has assistedin the coordination and leadership o(EPRICataQl,stplanning , sessions, tWo-day semin~ held With managers from several departmentswithit1 the
, saIi1eutility to coristrUctively brainstonn about the critical dimensions ora strategic

problem and the optionS for dealing witldt~ ' He has supported both environmen~

and transmission access seminars.
, For an electric utility with a troubled nuclear plant, Mr. Graves pres~nted testimony' oil the economic benefits likely to ensue from it proposed reorganization. The plant was to be spun off to a jointly-owned subsidiary that would sell available en~rgy back to the original owner under a contract indexed to industry unit costexpenence. This proposal afforded a considerable reduction of risk to ratepayers in e'tchaIlge fora reasonable , but highly uncertain prospect of profits for new investors. Testimony compared the incentive benefits and potential conflicts t.mder this arrangement to the outcomes foreseeable from more conventional incentive ratem~g arrangements.

7"'

For the World Bank and several investor-o wned electric utilities , Mr. Graves , nas" presented tutorial ~eminars on applying methods of financial economics to, the . evaluation of power production investments. Recently developed techniques for using option pricing to appraise the value of flexibility (such as, arises from fuel
switching capability or small plant siZe) were emphasized. He has applied these . methods in estimating the value ~f contingent contract terms in fuel contracts (such

as Gas Inventory Charges , or price caps and floors) for natural gas pipelines.

Mr. Graves has helped design Gas -Inventory Charge (OIC) tariffs for interstate pipelines seeking to reduce their risks of not recovering the full costs ofmulti-year
gas supply contracts. The costs of holding supplies in anticipation of future unCertain demand were evaluated with models of the pipeline s supply portfolio that reveal, how many non-production costs (demand charges, take-or-pay penalties
reservation fees ,

or remarketing costs for released gas) would accrue under a range

00054

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. . . ..Case 1:98-cv-00126-JFM Document 792-6 Filed 04/16/2004 Page 2 of 14

C~Graves Principal
Frank

of demand -scenarios. The expected ,present value of these costs providcct"iL basis for, the GIC tariff. '

, For an electric utility seeking to improve its plantmamtenancepro~ Mr. Graves direCted ' a study on: the , incrementaI value of a percentage ,point decrease in the" ex~ted forced outage rate at each plant owned and operated by the company. This defined an economic priority ladder for efforts to reduce outagethafcoUld be usCci in lieu of engineering stai1d~ds for each plant' s availability. , The potentialsavin~s v.' ere compared to the costs of alternativ~schedulesand contracting policies for preventive and reactive maintenance, in order to specify a cost reduction program~
Mr. Graves performed a review and critique of a state energy ,coImi1ission

, assessment of regional naturai gas and ,~lectric power markets in order to determine

economic. A proposed facility under review for regulatory approval was found to depend strongly on uneconomic bypass of existing pipelines and LDCs. In testimony, modular expansion of existing pipelines was shown to have significantly lower, costs and risks. Mr. Graves conducted a study on the risk-adjusted discount rate appropriate to a
publicly~owned electric utility's capacity planning. Sincereveriuerequite.nents(the

what kinds ' of pipelinee;!Cpansion into the area was

amounts being discounted) include operating Costs in addition to capital recovery

costs; the weighted average cost of capital for a comparable utility, with traded securities may not be the correct rate for every alternative or scenario. The risks
implicit in the utility' s expansion alternatives were broken into component sources and phases , weighted , and compared to the risks of bonds and stocks to estimate project-specific discount rates and their probable bounds.

For several electric utilities with generation capacity, in excess of target reserve
margins, Mr. Graves has designed and supervised market ~al!ses that compared the " marginal operating costs of all power plants not needed to meet target reserves for 50 to 100 neighboring utilities. ' These cost curves were then overlaid on the

corresponding curve for the client utility to identify which neighbors were
competitors and which were potential customers. The strength of their relative threat

or attractiveness could be quantified by the present value of the product of the

00055

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, Frank

C. Graves

Principal'

utility.
, e

amount, duration, and diffe~i1tial cost of capacity that was dlsplaceableby the client

Mr. Gtaves has s~cifiCd al$orithms for the enhancement, of theEPRI EGEAS genetationexpansion optimization model, to capture the tiist-otder effects of
financial andre~ato1)' ~nstfaints on the preCerredgeneration
mix.

For a major, electric power .wholesaler~ Mr. ' Graves developed , aframewotk for estimating 'how priciQ.gpolicies alterth~' atttactiveri~s ' of ~pacity ~xpansiOIi

alternative$'. Traditional

cost-recQvery priciIlg rules can

significantly distort the

choice between two otherwise equivalent capacity

pl~if one includes a severe, .

"front end load'" while " the other does not. Priee-demand feedback loops, ' in simulation models and quantification of consumer satisfaction measures were used to appraise the problem. , This " value of service" framework has beengeneralize~ for the Electric Power Res~ch Institute!
,e

For a large ' gas, and electrIc utility, Mr. ' Graves participated in coordinating and
evaluating the design of a strategic and operational planning' system. '1'1$ included

computer models of all aspects of utility operations, from demand forecasting
through generation planning to financing and rate design; Efforts were split between technical contributions to model design and attention to organizational priorities and
behavioral norms with which the system had to be compatible.

For a major ~lectronic and semiconductor fmn, Mr. Graves critiqued and refined a proposed procedure for ranking the attractiveness of research and development projects. Aspects of risk peculiar to research projects were emphasized over the
standards used for budgeting an already proven commercial venture.

. Foran oil and gas exploration and production finD, Mr. Gra~esdeveloped

a

framework for identifying what industry groups were most likely to be interested in natural gas supply contracts featuring atypicaJrisk-sharlngprovisions. These provisions, such as price indexing Or performance requirements contingent on market conditions , are a form of product differentiation for the producer, allowing it to obtain a price premium for the insurance-

like services.

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Frank C. Graves

Principal

Fora natural gas, distribution company" Mr., Graves established procedures for
redenmng customer claSses 8I1d, torrepricing gas services according to cUstomcis" , similarities in !oad shape" access toaltemative gas, supplies, expected need for reliability. In thi$ manner, natural gas service~effectivelydifferenti8ted ' into several productS, each with price and risk appropriate to a specific' nwket.. , - based, software was devetoped for balancing gas portfoliQsto ' custom.el' -, group,

gro~and

' c

denumds.
appraised relative to , comple~oii

, for a Midwestern electric utility,

Mr~ GlJives extended a regtdatory

proforma

financial model to captUre the contractual and tax implicatlonsofcancelhig and writing off a nuclear power plant in mid.:.consttuction. ' This possibility Wa$ then
or of substitution alternatives nom the viewpoint$ of

~r.)

revenue requirements).
Fora natural gas production and distribution company; he developed a strategic plan ,
to integratet.'1ecompany s functional policies and to reposition its operations for the

shareholders (market , value

conunoil equity) and ratepayers (present value

next five years. Decision analysis concepts were combined with marginaLco~t '
estimation and fmancial

pro forma

simulation to identify

attraCtive and resilient

alternatives. Recommendations included target markets, supply sources~ capital budget constraints , rate design; and a planning system. Atwo-dayplarining
conference Was conducted with the client' s executives to refme and internalize the strategy.
For a

corporate venture capital group, Mr. Graves conducted a market-risk

assessment ofinvesting in a gas exploration and production company with contracts , to an interstate pipeline~ The pipeline s market growth, competitive strength
alternative suppliers, and regulatory exposure were appraised to detennine whether

its future would support the p~chase volumes needed to make the venture attractive.
Mr. Graves prepared a review of

empirical evidence regarding the stock market'

reaction to alternative dividend , stock repurchase, and stock dividend policies for a major electric utility. Tax effects , clientele shifting, signaling, and ability to sustain any new policies into the future Were evaluated:-A one-time stock repurchase; with
carefulanno.uncement wording, was

recommend ed '

00057

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Frank C. Graves Principal
For the New ~exico Public Service Commission, he analyzed the merits of a corporate reorg8niZation of t1le major New Mexico gas production and distribution, companY. State ownership of the company as a large public utilitY wasconsidCred on concerns over efficiency and theburdening ofperfori11ance,nskS onto but rejected
state tUld local ,

taxpayers.

Mr. Graves has analyzed the ~patialandtemporal patterns of marginal cOstSo~ gas , and elec~ricutilitY ti'ans.mission networks using optimization models ofproduction costs and netwQrk flows. These resultswe!e used by one natural gas transmission , company to design receipt~point-:based transmission serVice tiuiffs and by another to demonstrate the incremental costs and uneven distribUtion of impacts on customers that would res~lt fonn ' a proposed unbundling of

serVices.

'-r--

PROFESSIONAL MEMBERSmpS
IEEE Power Engineering Society

Matl1ematical ASsociation of AmeriCa

, American Finance Association International Association for Energy Economics , Energy Modeling Forum (S~anfordUniversity)

EXPERT TESTIMONY
Prepared direct test4nony before the Federal Energy Regulatory Commission on behalf of National Rur8l Utilities Cooperative Finance Corporation, Inc. Cities of Anaheim and Riverside, California 'V. Deseret Generation Transmission ' Cooperative Docket No. EL97-57-00I, March 1999, regarding cost of service fo~ rural cooperatives versus iiwestor-owned utilities, and coal plant

, valuation.

.Expert report and oral examination before' the Independent Assessment Team for industry restructuring appointed by the Alberta Energy and Utilities Board on behalf of TransAlta Utilities , Corporation; January 1999 , regarding the generation of cost of capital under long-tenn , indexed power purchase agreements.

Oral testimony before the Commonwealth of Massachusetts Appellate Tax Board on behalf of
Irtdeck Energy Services of Turners Falls, Inc. Turners Town of Montague, Board of Assessors, Appellee D01'1r...t
1')
Fairs LImited Partnership, Appellant'Vs.
1\T"",

""~IQI-225t92 , 233732-233733

00058

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Frank C. Graves Principal

, 13

basis v8Iuation.

240482-240483, April 1998, regarding market conditions and revenu~ assessment for property tax .

, Direct and joint supplementaltestiri1ony before the ' PennSylvwa Public Utility Comnlission ()n behalf ofPeImsylvania Electric Company and Metropoli~ Edison Company, No. R';'oO974009, al., December.1997" regarding market clearing prices, inflation, fuel costs, and discounttatCs. '

Testimony before the' Public Utiliti~s CoIIUt1iS~ion of the State of California On behalf of the ' Southern California Edison Company, No. 96- 10-038, August 1997, regatdinganticompetitlve , implications of the proposed Pacific EnterpriseslENOV A. mergers.
, Direct testimony before the Kentucky Public Service Commission on behalf of Big Rivers Electric, Corporation, No. 97-204, June 1997, regarding wholesale generation and transmission rates under the bankrUptcy plan of

reorg~zation.

Affidavit before the Federal Energy Regulation Commission on behalf of the Southern California ~$on Company in Docket No~ EC97- 12-000 , March 28 , 1997, fUed as part of motion to intervene
. and protest the

proposed merger of Enova Corporation and Pacific Enterprises.

Direct; rebuttal, and supplemental rebuttal testimony before the State of New Jersey Board of Public Utilities on behalf ofGPU Energy, No. EO97070459, February 1997, regarding market clearing prices , inflation, fuel costs, and discount rates.
Qral direct ' testimony before the State of New York on, behalf of Niagara Mohawk Corporation in
P~i1adelphia Corporation, et al., v. Niagara Mohawk, No. 71149, November 1996, regarding interpretation oflow-head hydro IPP contract quantity limits.

, Oral direct testimony before the State of New York on behalf of Niagara Mohawk Corporation in v. Niagara Mohawk Power Corporation No. 94';1125 , July 1996 Black River Limited Partnership regarding interpretation ofIPP contract language specifying estimated energy and capacity purchase quantities.
, Oral direct testimony on behalfof
Eastern Utilities Associates

before the Massachusetts Department

of Public Utilities, No. 96- 100

and 2320 , July 1996 , regarding issues in restructuring of

Massachusetts electric industry for retail access.

Kentucky Public Service Commission on behalf of Big Rivers Electric in PSG Case No. 94-032, June 1995 , regarding rttodificationsto an environmental surcharge mechanism.
Affidavit before the
Corporation

00059

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Frank C. Graves Plincipal
Eastern Energy Corpora/ion v.' CommonWealth PleWic American Arbitration Association; No. Il Y 198 0035204, MarCh 1995, regaIding lack Company, of net benefits expected nom atenninated independent power project
Rebuttal testimony o~ bebaIf:of utility in

, Power

Direct testitnony before, the PennsylvaIiia Public, Utility Coriunissioil onbeJudf of Pennsylvania & Light Company,inPennsylwinia Public. Utility. Commission tt al~ , v. UGI Utilities; Inc.. Docket No. R-932927, March 1994, regardingjnadequacies in the design and pricing ofuOrs

proposed unbundling of gas transportationservi~~

Direct testimony before the PeIU1S)'lvania Public UtilityComnUssion, onbehaIfoffuterstate Energy Company, Application of Intcrstat~ , Energy Compa,ny for Approval to Offer, Servir;u in the Tra~portat;on olNqturalGas Docket No. A- 140200;October '1993, andtebuttaI testiinony, March

1994.

Paper Products Company,

Direct testimony before the Pennsylvania Public Utility Commission, on behalf ofPtocter, & Ganlble Pennsylvania Public Utility Commission v. Pennsylvania Gas and Water Company, Docket No. It-932655, September 1993, regarding PG&W's proposed charges for

transportation balancing.
Oral rebu~l testimony

before the: American Arbitration Association, on beb~f of Babcock and Wilcox, File No. 53- 1 99-0Ql 27-92, May 1993, regarding the economics of an incentive clause in

a cogeneration operations and maintenance contract.
Answering testimony before the Federal Energy Regulatory Commission, on behalf of CNG Transmission Corporation, Docket No; RP88-21 1-000, March 1990, regaiding~etwork marginal
costs associated with the proposed Unbundling

ofCNG.

Direct testimony before thePederal Energy Regulatory Commission, on behalf of Consumers, Power ' Company et ai" conCerning the risk reduction for customers and perfonnance inc~ntive benefits from the creation of Palisades Generating Company, Docket No. ER89-256-000, October 1989, 'and rebuttal testimony, Docket No. ER90-333- 000

, November 1990.

Direct testimony before the New York Public Service Commission, on beb"alfof Consolidated
NatuCal Gas Transmission Corporation,

Public Need

Application of Empire State Pipeline for

Certificate (Jf

Case No. 88-

132 , June 1989, and rebuttal !estimony, October, 1989.

PUBLICATIONS AND PRESENTATIONS
Opportunities for Electricity Storage in Deregulating Markets" (with Thomas Jenkin and Dean

Murphy), forthcoming.

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Frank C. Graves Principal
"Price Caps for Standard Offer -S~rvice: A HiddenSitanded Cost" (with Paul Liu)~ The Volume 1 1, Number lO, December 1998. Journal,

Electricity

(with Mechanismsfor Evaluating the Role of Hydroelectric Generation inAncillarylkrvice Markets: TR-ll i 701 R.P. Broehm,R.L~ Earle, T J. lenkin,andD.M. Mwphy), FbWReport,November 1998

(palo Alto, CA: Electric Power Research Institute, 1998).
Energy Market Impact$ of Electric Industry R"estruciUrhig: Understanding Whoi~~le Powe
Transmission and Trading

(with S.

Th~b, A.M. Schaal, L. S~ BOrUcki,andR. J3rpebm), FUud

Repon, March 1998, EPRI TR,- 108999, GRI-97/0289 (palo Alto, CA:El~tricPowerReSe3tch

Institute 1998).
Pipeline Pricing to Encourage Efficient Capacity Resource Decisions ( with PaulR. Catpentet and Matthew P. O' Loughlin), filed on behalfofColumbia Gas TransrilissionCorporationand Co.umbia

Financial Dutlookfor ihe Natural Gas Gulf Transmission Company, with their coII1lI1entson FERC DocketNo; PL98- 000 , February 1998 Pipeline Industry,
Oile-P8ct Markets for Electric Power: Ensuring the Benefits of Competition" (with E. Grant Read, PowerSystems Restructuring: Engineering and Economics, Philip, Q Hanser, and Robert L Eade), M. me, F. Gatiana, and L. Fink, eds, (Boston: Kluwer Acadeinic Publishers, 1998), 'pp. 243-280: '

Railroad and Telecommunications Provide PriorExperiencein ' Negotiated Rates '" (with Carlos Lapuerta), Marketing and Rates Natural Gas, luly
Considerations in ,the Design of ISO and Power Exchange Protocols: Procurement Bidding and Market Rules (withJ.P. Pfeifenberger), presented at the Electric Utility Consultants Bulk Power Markets Conference, Vail, Colorad~, lune 3-4, 1997.
, c

1997.

'The Economics of Negative BarrierS to Entry: How to Recover Stranded Costs and Achieve Competition on Equal Terms in the Electric Utility , Industry" (with William 13. Tye), Electric Volume 37, No. I,Winter 1997. Natural Resources Journal, Industry Restructuring,
Capacity Prices it:l a ' Competitive Power
Accounting, Technology' &
Market" (with James A. Read),

Competitive Aspects of the Emerging I~dustry,

Preston, eds. (Boston: Kluwer Academic Publishers: 1997), pages 17S-

I?2.

The Virtual Utility: S. Awerbuch and A.

S~ded Cost Recovery and Competition on Equal Terms
Journal,

" (with William B. Tye),

Electricity

Volume 9, Number 10 ,

December 1996.

Basic and Enhanced Services for Recourse and Negotiated Rates in the Natural Gas Pipeline Industry" (with Paul R. Carpenter, Carlos Lapuerta, and Matthew P. O' Loughlin), filed on behalf of

00061
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Frank C. Graves

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16 . '
Transmission CQmpany, in. its FBRC Docket No. RM96- 7, May 29; 1996.

, Columbia Gas Transmission'

ColpO,mtionand Columbia Gulf

Comments on Negotiated Rates and Terms of Service,

,

"Premium Value for Hydro Power in a DeregUlated Iildustry? Technical OpportunitieS and Market' StnictUreEffects, presented , to the EPRI Hy% Steering Committee Conference, Chattanoog~ and to the EPRl Energy Storage Benefits Workshop~'N.ew Orleans, :Tennessee, April 19, 1996. : J,.o~iana, May 22,

1996. '
Electricity.Journal

ccDistrlbuted Generation Technology in a-Newly Co~petiti~e ' Blectric Pow~r In4t1StrY" (with Taylor),pr~sentedattheAmericanPower' JobarihesP. Pfeifenberger, Paul R. Ammann, and GaryA. Illinois Institute of Technology, AprillO, Col1ftrence,

1296.

, " 44

A Framework for Operations in the Competitive OpenAcce~s Environment" (with Marija D. , Ilie,
Volume 9, Number 3; Aprll1996.

, , Lester H. Fink, Al~ert' M. DiCaprio),

t~'

"Prices and Procedures of anI SO in Supporting a Competitive Power Market" (with, Marija me), presented at the Restructuring Electric Transmission Conference Denver, Colora~o SepteInber ~7 ,

"PotentialImpacts of Electric Restructuring on Fuel Use

1995.

1995.

EPRI

Fuel Insigh(s;

Issue2 , Septe.rtber

" cc

Maria Ilie)~

Optimal Use of Ancillary Generation Uitder Open Access and its Possible Implementation" (with ML T. Laboratory forElectromagnetic ~nd ElectronicSystemsTechnical Report, LEES

11t-95~OO6.. August 1995.
Estimating the Social Costs ofPUHCA RegUlation" (with Paul R. Carpenter), submitted to the Security and Exchai1.geCommission' Request for Comments on Modernization of the .Regulation of Public UtilityHolding Companies SEC File No. S7-32-93, February6

, 1995.

.If Primer on Electric Power Flow for Economists and UtilityPlanners, Power Research InStitute , EPRI ProjectRP2123- , January 1995.

TR- IO4604, The Electric

"Impacts of Electric Industry Restructuring on Distributed UtilityTechnology, pr~sented to the
. ~lectdc Power Research
CoIporation

InstitutelNational Renewable Energy Lab~ratorylFloridaPower
Orlando, Florida, August 24; 1994.

Conference on Distributed Generation,

Pricing Transmission and Power in the Era of Retail Competition" (with Johannes P.

Pfeifenberger), presented at the Electric Utility Consultants' Cree~ Colorado , June 21 , 1994.

Retail Wheeling Conference Beaver

00062

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Case 1:98-cv-00126-JFM

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Frank C. Graves

, Principal
of Electricity :NetWork Services to Preserve NetwOl'kSecurity end Qualiiy of Frequency , Under Transmissio!1 Access" (with Dr. Marija me, Paul R. Carpenter, and AssefZobian), R.e$ponse and Reply comments to the Federal Energy Regulatory Commission in ' is Notice. of TechniCal, Docket No. RM-93- 19-O00, November 1993 andlanuary , Coriference on Transmission Pricing,

, "Pricing

1994.
EPRIWorkshop on 'EValuating and UsingCAAA Compliance Cost Forecasts, " presented atthe Missouri, November 17 andArlin~o~ VugiDia;Noveinbei" 19,1992. StLouis, CietinAir Response,

Be)rond Valilation...:-orgaIiizationai and strategic Considerations in Capital Budgeting for Electric New Odeans, Louisiana, April RI Capital Budgeti~g Notebook W.orkshop, Utilities~" presented atEP

10, 1992.

"UnbUndling" Pdcing, and Comparability of Service on Natural Gas Pipeline Networks" (with Paul,
R. Carpenter), as appendix to

Comments on FERC Order 636 filed by Interstate Natural Gas

ASsociation of Anierica, November 1991.
).1

Estimating the Cost of Switching Rights on Natural Gas Pipelines" (with James A: Read, Jr~and Paul R. Carpenter), presented ~t the M. LT. Center for Energy Policy Research, " Workshop on New The Energy Journal Volume J\1ethods for Project and Co:1tract Evaluation " March 2-4, 1988; and in 10, Number 4, October

19&9~
(with P. R.
Carpenter), NaturalGas,

Demand- Charge GICsDiffer from Deficiency-Charge GICs" (with Paul R. Carpenter),

NatJlral

Gas

August 1989.

, " "what PricetJl1bundlirig?"
March 2-

Price:-Demand Feedback " presented at

3, 1989.
00063
1 '7

June 1989.

EPRI Capital Budgeting Seminar San Diego, California,'

Applications of Finance to Electric Power Planning," presented at the W odd Bank, and Uncertainty in Power System Planning,

October 13, 1988.

Seminar on Risk

Integrated Value-Based

Planning for ElectricUtUities:The Value of Service" (with James A. Read, Jr.), in Moving Toward Planning, Electric Power Research Institute, 1988.

CCValtlation of

Standby Charges for Natural Gas Pipelines" (with James A. Read, Jr. and Paul R. Carpenter), presented toMJ.T. Center for Energy Policy Research, October, 1987.

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Exhibit 4 FRANK C. GRA YES
Rule 26(a)(2)(B~Disclosure of Depositionlfe$timony During the L~tFourYeal'S '
Case:
File No. Client:

NOPR: Requestfor Comments on the Mo:demization of Regulation

of Public Utility Holding Compames ,
S7-32..94 ,
Central and SouthweSt ,Corporation

Forum: , Topics:

Date: . Type:

2/95 ,

Securities and EXchange Commission EConomic benefitSofPUHCA repeat, utility mergers ,

" , Comments
, Eastern Energy

C~e:
File No. ,Client: Forum: Topics;
Date~

11 Y 1980035294

Corporation v. Commonwealth Electric Corporation

~r.',

Type:
Case:

Commonwealth Electric Corporation Atherican Arbitration Association IPP contract cancellation, damages 3/95 Oral Direct
Application of.J3ig Rivers Electric Corporation to Assess a Surcharge , under, KRS 278. 183 to Recover Costs ofCompHance with

Case No. Client: Forum: , .Topics: Date:
. Type:

Environmental Requirements of the Clean Air Aet 94Big Rivers Electric Corporation .. Kentucky Public Service Commission CAAAcompliance costs , environmental cost recovery mechanisms

032

Affidavit

6/95
10/95

Case:

NOPR: Promoting Wholesale Competition Through Open' Access Non-Discriminatory Transmission Services by Public Utilities; and Recovery of Stranded Costs by Public Utilities and Transmitting
RM95- 000 and RM95- 001 NA(unsolicited filing by FCG and Marija Ilic, MIl)
FederatEnergy Regulatory Commission

Docket Nos. Client: ' Forum: Topics: Date: Type:

Utilities
00064

Ancillary service pricing, electric power opportunity costs

Reply Comments

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Exhibit 4 FRANK C. GRA VES

Rule 26(a)(2)(B~Disclosure ofUepositionlrestimony
During the Last FourYean
Case:
. Docke~ Nos.
, Cli~nt:

Continued Public Hearings concerning Electric Industry Restructuring
96400 and 2320.

Forum; , Topics:

Eastern Utilities Associates, Massachusetts Department of Public Utilities Retail access: electric restructuring policies

Date:
, Typ~:

7/96 Oral Direct
Corporation

Case:

Black River Limited Partnership v. Niagara Mohawk Power
94- 1125
Niagara Mohawk Corporation State of New Yark Supreme Court NUG contract conipliance ovet-generat~on payments detinition of

Index No.

Client:
Forum: Topics:
:E)

Date:

plant capacity "
7/96 Deposition and Oral Direct

Type:
Case:

Philadelphia Corporation, Moose River Corporation, Stevens& Thompson Paper Company, Inc., Union Falls HydropowetLi~ted Partnership; BattenkiU Hydro Associates, Empire Hydro Partners
Limited Partnership~ West End Dam Associates. Raquette Hydro Power Limited , Adirondack Hydro Development Corporation, \Varrensburg Hydro Power Limited Partnership, NYSD Limited Partnership, SissonviUe Limited Partnership, Middle Falls Limited Partnership, Diana-PolgevilleCorporation, Victory Mills Hydro Co. Inc. , Lachute Hydro Co. , and Newport Hydro Associates v. Niagara

Molmwk Power Corporation

Index No. Client: , Forum: Topics: Date: Type:
Case: Docket No. Client: Forum:

71149 '

Niagara Mohawk Power Corporation State of New Yark Supreme Court NUG hydro contract compliance, over-generation 11/96 Oral Direct

GPUEnergy Stranded Cost Petition EO97070459 GPUEnergy State of New Jersey Board of Public Utitilities

00065

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Exhibit 4 FRANK C. GRAVES
Rule 26(a)(2)(B~Disclosure ofDepositionlTestimony

During the Last Four Years
Topics:
Market clearing priccs" inflation,
fuel costs, (iiscO11Dt rates

pate:
Type:
Case: Docket No,
, Client:

2/97 , Direct, Rebuttal , and ' ~upplemental

Rebuttal

Proposed MergerofENOV A Corporation and Pacifi~Enterprises. EC97- 12-O00 ' Southern Ctili(ornia Edison Company,
cdcralEnergy Rcguktory, Commission' , Vertical market power, gaS-fired generation dominance

oruni: . , Topics:
, F

, Date:

Type: ,

3/97
Affidavit

Case:
, Case No.

Client:
Fo11II1l:

Bankruptcy 97Big Rivers Electric Corporation

204

Kentucky Public Service Commission'
Rural electrlccoopbankruptcy settlement, cost of

Topics:

serVice, transmission'

tariff
Date: Type:
Case:,
6/97 Direct . Rebuttal , and Deposition
Application Approval of Pacific Enterprises, Enova Corporation" et al.,

for

Application No. , Client: Forum: Topics:
. Date:

a Plan of Merger of 96- 10Southern California Edison Company Public UtilitiesCo~ission of the State of California , Vertical market power, gas-fired generation dominance

038 .

Type:
Case: Docket No. Client: Forum: Topics: Date: Type:

Direct

8/97
00974009, et ale

Stranded Cost Petition

Pennsylvania Electric Company and Metropolitan Edison Company Pennsylvariia Public Utility Commission Market clearing electric prices , inflation, fuel costs , discount rates
12/97

Direct and Joint Supplemental

Contains protected materials; - rcd~cted

version Qvaiia1

00066

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Case 1:98-cv-00126-JFM

Document 792-6

Filed 04/16/2004

Page 14 of 14

Exhibit 4 FRANK C. GRAVES
Rule , 2(j(a)(2)(B~Disclosure ,of DepositionJTestimony
, During the Last Four

Years'

, Case:
Docket Nos. '

Turners Falls Limited PartneC$hip vs.

Assessors

TownofMoIitague~ Board of

Client: Fonim: Topics:
Date: Type:

, 2Z5191-22S192, 233732-233733, 240482-240483 Incleck Energy Services of Tumers Falls, Inc~

Commonwealth of MassachqSetts Appellate, TaJC Turners Falls valuation report: market, conditions and, revenues

4/9&

Board"

assessment for property tax basis valuation

Expert Report and Oral Testimony

~e:
Docket No. '

Powcr ~urchase An'angements

Client:
Topics:
Date: Type:

TransAlta Utilities Corporation
Independent Assessment T cain for industry restructuring appointed

Forum:

by the Alberta Energy and Utilities Board '
Generation cost of capital under long-term indexed restructuring power purchase arrangements

.J/99,
Expert Report and oral examination by IAT
Cities of Anaheim and Riverside, California v. Deseret Generation&
Trans~ission Cooperative

Case:
" DocketNo. Client: Forum: Topics:

EL97- 57.,OOl. National Rural Utilities Cooperative Finance Corporation, Inc.

Federal Energy Regulatory Commission '
3/99 Prepared Direct Testimony

Date: Type:

coal plant valuation

Cost of service for rural cooperatives vs. investor-oWned utilities;

00067