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

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Case 1:98-cv-00126-JFM Document 791-4

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C. Graves Principal
Frank

capacity for better planning~
bas.ic electrical

pricing, and regulatory policies.

The text covers the

engineering of power circuits. utility practices to exploit transmission

economies of scale, means of assuring system stability, economic dispatch subject to transmission constraints, and the estimation of marginal costs of transmission. The implications for a variety of policy issues are aIsodiscussed.
Fora major industrial gas user, he prepared a critique of the transportationbaIancing charges proposed by the local gas distribution company. Those charges were shown to be arbitrarily sensitive to the measur~ment period as well as to inconsistent attribution of storage versus replacement supply costs to imbalance volumes. The tariff design, a corilinodity charge on a per-cash-inlcash-out at spotmarketgas prices with penalties for very deep imbalances, or an incremental storage inventory and . withdrawal capacity used on-peak, were shown to be cheaper, more efficient, and less complex to administer. This analysis helped the parties reach a settlement based on the cash-in/cash-out design.
The . Clean Air

Act Amendment authoi"izes

electric utilities to trade emission

allowances (EAs) as part of, their approach to complying with S02 emissions
reductions targets. For the Electric Power Research Institute (EPRI), Mr. Graves has

developed multi-stage planning models to illustrate how the considerable uncertainty

surrounding future EA prices justifies waiting to invest in irreversible control
technologies, such as scrubbers , until the present value cost of such investments is significantly below that projected from relying on EAs.
Mr. Graves has contributed to the design and pricing of new, unbundled services on several natural gas pipelines. To identify attractive aIterIlatives , the marginal costs of possible changes in a pipeline s service mix were quantified, by simulating the least.r.cost operating practices subject to the network' s physical and contractual
constraints. Such analysis helped one pipeline to justify a zone-based rate design for

its firm transportation service. Another pipeline used this technique to demonstrate that unintended degradations of system perfonnaI\ce and increased costs could ensue from certain proposed unbundlings that were insensitive to system operations.

For several natural gas pipeline companies , Mr. Graves has evaluated the cost of equity c~pital in light of the requirements l)f FERC Order . 636 .to .u.'1bund!eand
0031

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Principal

FrankC. Graves

reprice pipeline services. In addition to traditional DCF and risk positioning studies~

implications of different degrees of financial leverage (debt capitalization), were modeled and quantified. Aspects of rate design and cost allocation between

the -risk

services that also affect pipeline risk were considered.
Mr. Graves has assisted in the coordination and leadership ofEPRI CataQlstplanning sessions, two-day seminars held with managers from several departments within the same utility to constructively brainstorm about the critical dimensions of a strategic problem and the options for dealing with it. He has supported both environmental

and transmission access seminars.
Foran electric utility with a troubled nuclear plant, Mr. Graves presented testimony
on the economic benefits likely to ensue from it proposed reorganization. The
plant

was to be spun off to ajointly-owned subsidiary that would sell available energy back to the original owner under a contract indexed to industry unit cost experience. This

proposal afforded a considerable reduction of risk to ratepayers in e"change for a reasonable , but highly wlcertain prospect of profits for new investors. Testimony compared the incentive benefits and potential conflicts under this arrangement to the outcomes foreseeable from more conventional incentive ratemaking arrangements.
For the World Bank and several investor-owned electric utilities , Mr. Graves has 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 nom fuel switching capability or small plant size) were emphasized. He has applied these methods in estimating the value of 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 (GIC) 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

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Frank C.

Graves

Principal

of demand scenarios. Theexpectedpresentv&ue of these costs provided a basis for the GIC tariff.
For an electric utility seeking to improve its plant maintenance program, Mr, Graves
directed a study on the incremental value of a percentage point decrease in the

expected forced outage rate at each plant owned and operated by the company. This defined an economic priority ladder for efforts to reduce outagetbatcouldbe used in lieu of engineering standards for each plant' s availability. The potential savings were compared to the costs of alternativ~scheduIesand contracting policies for preventive and reactive maintenance, in order to specify a cost reduction program.
Mr. Graves perfonned a review and critique of a state energy conun.ission

assessment of regional natural gas and electric power markets inordet to determine what kinds of pipeline expansion into the area was 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 pipe!ines 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. Since revenue requirements (the

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 analyses that compared the marginal operating costs of all power plants not needed to meet target reserves for

utilities. These cost curves were then overlaid on the corresponding curve for the client utility to identify which neighbors were
50 to 100 neighboring

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

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Frank C. Graves Principal

utility.

amount, duration, and differential cost of capacity that was displaceableby the client

Mr. Graves has specified algorithms for the enhancement ,of theEPRI EGEAS generation expansion optimization model, to capture the , flfSt-order, effects, of financial and regulatory constraints on the preferred genemtionmix.
For a major, electric power wholesaler, Mr. ' Graves developed a framework for

estimating bow pricing policies alter th~ attractiveness of capacity expansion alternatives. Traditional cost-recovery pricing rules can significantly distort the
choice between two otherwise equivalent capacity plans, if one includes a severe
front end load" while the other does not. Price-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 Research Institute:

For a large gas and electric utility, Mr. Graves participated in coordinating and
evaluating the design of a strategic and operational planning system. This included computer models of all aspects of utility operations, from demand forecasting through generation planning to financing and rate design. Efforts were splitbetween technical contributions to model design and attention to organizational priorities and behavioral norms with which the system had to be compatible.

For a major electronic 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.

, For an oil and gas exploration and production firm, Mr. Gra~es

developed a

framework for identifying what industry groups were most likely to be interested in natuml gas supply contracts featuring atypical risk-sharing provisions. 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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Case 1:98-cv-00126-JFM Document 791-4 Filed 04/16/2004 Page 5 of 15

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FrankC. Graves

Principal
For a natural gas distribution company, Mr. Graves estabIished procedures for redefining customer classes and, for repricing gas services according to cUstomers similarities in Joad shape, access to alternative gas supplies, expected growtli,and need for reliability. In this manner, natural gas service was effectively differentiated into several products, each with price and risk appropriate to a specificnwket.PC-

based, software was developed for balancing gas portfolios to customer group

demands.

proforma For a Midwestern electric utility, Mr. Gt:aves extended a regulatory financial model to capture the contractual and tax implications of canceling and writing off a nuclear power plant in mid-construction. This possibility was then
appraised relative to completion or substitution alternatives fromtheviewpoint$ of shareholders (market value of common equity) and ratepayers (present value of revenue requirements).
For a natural gas production and distribution company, he developed a strategic plan to integratetl1.e company s functional policies and to reposition its operations for the

next five years. Decision analysis concepts were combined with marginal cost simulation to identify attractive and resilient pro forma estimation and financial alternatives. Recommendations included target markets, supply sources, capital budget constraints, rate design, and a planning system. Atwo-dayplanning conference was conducted with the client' s executives- to refine 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 determine whether its future would support the purchase 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.UDcement wordin~ was recommend ed.

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Frank C. Graves Principal
For the New Mexico Public Service Commission, he analyzed the merits of a colporate reorganization of the maJor New Mexico gas production and distribution company. State ownership of the company as a large public utilitY was considered but rejected on concerns over efficiency and the burdening of perfonnancerisks onto state and local taxpayers.
Mr. Graves has analyzed the spatial and temporal patterns of marginal costs on gas and electric utility transmission networks using optimization models ofproduction costs and network flows. These results were used by one natural gastransnUssion company to design receipt-point~based transmission service tariffs, and by another to demonstrate the incremental costs and uneven distribution of impacts on customers that would res~lt form ' a proposed unbundling of services.

PROFESSIONAL MEMBERSHIPS
IEEE Power Engineering, Society Mathematical Association of America
American, Finance Association

International Association for Energy Economics Energy Modeling Forum (Stanford University)

EXPERT TESTIMONY
Prepared direct testimony before the Federal Energy Regulatory Commission on behalf of National Rural Utilities Cooperative Finance Colporation, Inc. Cities of Anaheim and Riverside, California v. Deseret Generation Transmission Cooperative Docket No. EL97- 57-001 , March 1999, regarding cost of service for rural cooperatives versus investor-owned utilities , and coal plant valuation.

.Expert report and oral examination before the Independent Assessment Team for industry

power purchase agreements.
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restructuring appointed by the Alberta Energy and Utilities Board on behalf of TransAlta Utilities Colporation, January 1999 , regarding the generation of cost of capital under long-term, indexed

Oral testimony before the Commonwealth of Massachusetts Appellate Tax Board on behalf of lrtdeck Energy Services of Turners Falls , Inc. Turners Fairs LImited Partnership, Appellant vs. Town of Montague, Board of Assessors, Appellee Docket Nos. 225191-225192, 233732-233733

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Case 1:98-cv-00126-JFM Document 791-4 Filed 04/16/2004

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Frank C. Graves Principal
" 240482-240483, April 1998, regarding market conditions and revenues assessment for property tax

basis valuation.
Direct and joint supplemental'

testimony before the Pennsylvania Public Utility Commission on behalf of Pennsylvania Electric Company and Metropolitan Edison Company, No. R.;.Q0974009, al., December 1997, regarding market clearing prices, inflation, fuel costs, and discountrates.

, Testimony before the' Public Utilities Commission of the State of California on behalf of the Southern California Edison Company, No. 96- 10-038, August 1997, regatdinganticompetitive 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 wholesalegeneration and transmission rates under the bankruptcy plan of reorganization.

Affidavit before the Federal Energy Regulation Commission on behalf of the Southern California
, Ed~son Company in Docket No. EC97 - 12-000, March28, 1997, filed as part of motion to intervene
, and protest the

proposed merger of Enova Corporation and Pacific Enterprises.

Direct, rebuttal, and supplemental rebutt~l testimony before the State of New Jersey Bo~rd of Public Utilities on behalf of GPO Energy, No. EO97070459, February 1997, regarding market clearing prices, inflation, fuel costs, and discount rates.
Oral directtestimony before the State of New York on behalf of Niagara MohawkCorporation in No. 71149, November 1996, regarding Philadelphia Corporation, et al., v. Niagara Mohawk, interpretation of low-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 LimitedParlnership 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.
Affidavit before the
Corporation

Big, Rivers Electric Kentucky Public Service Commission on behalf of in PSG Case No. 94- 032 , June 1995, regarding modifications to an environmental

surcharge mechanism.

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Frank C. Graves Principal
Rebuttal testimony on behaIfof utility in
Company,

Eastern Energy Corporation

v.

Commonwealth Electric

American Arbitration Association, No. 11. Y 198 00352 04, March 1995, regaiding lack

of net benefits expected from a terminated independent power project

Direct testimony before the Pennsylvariia Public Utility Commission on behalf of Pennsylvania CompanyinPennsylVtinia PublicUtility, Cornmission et al. - v. UGI Utilities, Inc., Power & Light Docket No. R-932927, March 1994, regarding inadequacies in the design and pricing ofUGI's proposed unbundling of gas

transportationservi~s.

Company,

Direct testimony before the Pennsylvania Public Utility Conurtission, onbehalfofInterstate Energy Application of Interstate, Energy Compo.ny lor Approval to Offer Services in the DocketNo. A- 140200;October 1993, and rebuttal testimony, March Transportation of Natura/Gas, 1994.

Direct testimonybefore the Pennsylvania Public Utility Commission, on behalf ofProcter& Gamble
Paper Products Company, Company,

Pennsylvania Public Utility Commission v. Pennsylvania Gas and Water

transportation balancing.

Docket No. It- 932655, September 1993, regarding PG&W's, proposed charges for

Oral rebuttal testimony before the American Arbitration Association , on behalf of Babcock and Wilcox, File No. 53- 199-00127- , 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. RP88-211-000, -March 1990, regarding network marginal

costs associated with the proposed unbundling of CNG. ,

Direct testimony before the Federal Energy Regulatory Commission, on behalf of Consumers Power et al. concerning the risk reduction for customers and the perfonnance inc~ntive benefits Company from the creation of Palisades Generating Company, DocketNo. 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 behalfof Consolidated Application of Empire State Pipeline for Certificate of Public Need Case No. 88- 132 , June 1989, and rebuttal !estimony, October, 1989.
Natural Gas Transmission Corporation

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 Service: A Hidden stranded COst" (with Paul Liu), Volume 1 1, Number , 1 0 Journal,

, December 1998.

The Electricity

(with Mechanisms for Evaluating the Role of Hydroelectric Generation in Ancillary Service Markets RP. Broehm, RL. Earle, T.1. Jenkin, andD.M. Murphy), Final Report, November 1998, TR-ll 1701
(palo Alto, CA: Electric Power Research Institute,
(with S. L.

1998).,
February 1998.

Energy Market Impacts of Electric Industry Restructuring: Understanding Wholesale ' Power

Institute, 1998).
Gulf Transmission Company, with their comments on Pipeline Industry,

Thumb , A. M. Schaal, L. S. Borucki, and R Broehm), Fina1 Report, March 1998, EPRI TR~ 108999, GRI-97/0289 (palo Alto , CA: Electric Power Res~ch
Transmission and Trading

Pipeline Pricing to Encourage Efficient Capacity Resource Decisions ( with PaulR Carpenter and Matthew P. O' Loughlin), filed on behalfofColumbia Gas Transmission Corporation and Columbia
Financial Outlook for the

Natural Gas

FERC Docket No. PL98- 000 ,

One-Part Markets for Electric Power: Ensuring the Benefits of Competition" (with E. Grant Read,
PhilipQ HailSer,
and Robert L. Earle), Power Systems Restructuring: Engineering and Economics,

M. me , F. Gatiana, and L. Fink, eds. (Boston: Kluwer Academic Publishers, 1998), '

243-280.

Railroad and Telecommunications Provide Prior Experience in ' Negotiated Rates '" (with Carlos

Lapuerta), Marketing and Rates Natural Gas

July 1997.

Considerations in the Design of ISO and Power Exchange Protocols: Procurement Bidding and Market Rules (with J.P. Pfeifenberger), presented at the Electric Utility Consultants Bulk Power Markets Conference, Vail, Colorado, June 3-4 , 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 B. Tye), Electric Natural Resources Journal Volume 37, No. I,Winter 1997. Industry Restructuring,
Capacity Prices ilJ. a Competitive Power Market" (with James A. Read),
Accounting, Technology' &
Competitive Aspects of the Emerging Industry,

The Virtual Utility: S. Awerbuch and A.

Preston, eds. (Boston: Kluwer Academic Publishers; 1997), pages 175- 192.

S~ded Cost Recovery and Competition on Equal Terms
Journal Volume 9, Number 10 , December 1996.

" (with William B. Tye),

Electricity

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

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Frank C. Graves

Principal

16 '

, Columbia Gas Transmission Corporation and Columbia Gulf Transmission Company, in its

Comments on Negotiated Rates and Terms of Service FERC Docket No. RM96~7, May 29, 1996.

"Premium Value for Hydro Power in a Deregulated Ii1dustry? Technical Opportunities and Market' EP RI Hydro Steering Committee Conference, Chattanooga, StructUre Effects," presented to the
Tennessee, April 19, 1996, and to the

Louisiana, May 22, 1996.

EPRI Energy Storage Benefits Workshop,

NewOrlearis,

"Distributed Generation Technology in a Newly Competitive Electric Power industry" (with
JohannesP. Pfeifenberger, Paul R. Ammann, and GaryA. Taylor), presented at the

Conference Illinois Institute of Technology, April 10,

19.96.

American Power

Lester H. Fink, AlbertM. DiCaprio),

A Framework for Operations in the CoII1petitive Open Access Environment" (with MarijaD. Ilie Electricity Journal Volume 9, Number 3; April 1996.

"Prices and Procedures of anI SO in Supporting a Competitive

(r"

presented at the

1995.

Power Market" (with Marija Ilie), Restructuring Electric Transmission Conference Denver, Colorado September ~7,

"PotentialImpacts of Electric Restructuring on Fuel Use 1995.
. &C

EPRl

Fuel Insigh~s,

Issue 2 , September

Optimal Use of Ancillary Generation Under Open Access and its Possible Implementation" (with LEES ML T. Laboratory for Electromagnetic and Electronic Systems Technical Report, TR-95-006, August 1995.
Maria Ilie),

Estimating the Social Costs ofPUHCA Regulation" (with Paul R. Carpenter), submitted to the Security and Exchange Commission Request for Comments on Modernization of the Regulation of Public Utility Holding Companies SEC File No. S7-32-93, February 6, 1995.
A Primer on Electric' Power Flow for Economists and Utility Planners TR- IO4604 , The Electric Power Research Institute , EPRI ProjectRP2123- , January 1995.

"Impacts of Electric Industry Restructuring on Distributed Utility Technology,"
CoIporation Conference on Distributed Generation,

presented to the

Electric Power Research InstitutelNational Renewable Energy Lab~ratorylFloridaPower
Orlando, Florida, August 24; 1994.
Pricing Transmission and Power in the Era of Retail Competition" (with Johannes P.

Pfeifenberger), presented at the Electric Utility Consultants Retail Wheeling Conference Beaver Creek, Colorado , June 21 , 1994.

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Case 1:98-cv-00126-JFM Document 791-4 Filed 04/16/2004 Page 11 of 15

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Frank C. Graves Principal
"Pricing of Electricity Network Services to Preserve Network Security and QuaJity of Frequency Under Transmissio~ Access" (with Dr. Marija me, Paul R. Carpenter, and AssefZobian), Response Notice o/Technical and Reply comments to the Federal Energy Regulatory Commission in is Docket No. RM-93- 19-000, November 1993 and January Conftrenceon Transmission Pricing,

EPRlWorkshop on Evaluating and UsingCAAA Compliance Cost Forecasts," presented at the , Virginia,November 19, 1992. C/eanAir Response StLouis; Missouri, November 17 and Arlington
Beyond V aluation~rgaIiizational and
Strategic Considerations in Capital Budgeting

1994.

, Utilities," presented atEP 10. 1992.

RI Capital Budgeting Notebook W.orkshop,

Electric New Orleans , Louisiana, April
for

"Unbundling, Pricing, and Comparability of Service on Natural Gas Pipeline Networks" (with Paul Carpenter), as appendix to Comments on FERC Order 636 filed by Interstate Natural Gas ASsociation of America, November 1991.

Estimating the Cost of Switching Rights on Natural Gas Pipelines" (with James A~ Read, Jr. and Energy Policy Researc)1, " Workshop on New for PaulR. Carpenter), presented at the M.I.T. Center The EnergyJournal Volume " March 2- , 1988; and in l\1ethods for Project and Co:ltnlct Evaluation . Number 4, October 19&9~
Demand-Charge GICs Differ from Deficiency- Charge GICs" (with Paul R. Carpenter),
Nat!1ral

Gas

August 1989.
P. R.
Carpenter),

"what Price Unbundling?" (with

Natural Gas

June 1989.

Price-Demand Feedback," presented at March2- 1989.

EPRI Capital Budgeting Seminar San Diego , California,

Applications of Finance to Electric Power Planning," presented at the World Bank, October 13 , 1988. and Uncertainty in Power System Planning,

Seminar on Risk

Planning for Electric Utilities: The Value of Service" (with James A. Read, Jr.), in Moving Toward Electric Power Research Institute, 1988. Integrated Value-Based Planning,
"Valuation of Standby Charges

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

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Case 1:98-cv-00126-JFM Document 791-4 Filed 04/16/2004 Page 12 of 15

i'

Exhibit 4
FRANK C. GRA YES

Rule 26(a)(2)(BrDisclosure of Depositionffestimony During the Last FourYean
Case:
File No. Client:
N OPR: Request for Comments on the ModemizationofRegulation

of Public Utility Holding Companies
S7-32..94 Central and Southwest Corporation

Forum: Topics: Date: Type:
Case: File No. Client: Forum: Topics:
Date~

2/95
Comments

Securities and Exchange Commission

Economic benefitsofPUHCA repeal, utility mergers

Eastern Energy Corporation v. Commonwealth Electric Corporation

Type:
Case:

Commonwealth Electric Corporation American Arbitration Association IPP contract cancellation, damages 3/95 Oral Direct

11 Y 1980035294

Application of Big Rivers Electric Corporation to Assess a Surcharge

under KRS 278. 183 to Recover Costs of Compliance with
Case No. Client: Forum: Topics: Date: Type:
Case:

Environmental Requirements of the Clean Air Act 94- 032 Big Rivers Electric Corporation Kentucky Public Service Commission CAAA compliance costs , environmental cost recovery mechanisms 6/95 Affidavit

NOPR: Promoting Wholesale Competition Through Open Access
Non-Discriminatory Transmission Services by Public Utilities; and Recovery of Stranded Costs by Public Utilities and Transmitting Utilities RM95- 000 and RM95- 001 NA(unsolicited filing by FCG and Marija Ilic, MIl) Federal Energy Regulatory Commission Ancillary service pricing, electric power opportunity costs
Reply Comments

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

10/95

0042

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

During the Last Four Years
Case :

Docket Nos. Client: Forom: Topics: Date: Type:
Case:

Continued Public Hearings concerning Electric Industry Restructuring 96Eastern Utilities Associates Massachusetts Department of Public Utilities Retail access~ electric restructurlngpolicies 7/96 Oral Direct

100 and 2320

Black River Limited Partnership v. Niagara Mohawk Power
Corporation 94- 1125 Niagara Mohawk Corporation State of New York Supreme Court NUG contract compliance over-generat~6n payments defmition of

t:""

Index No. Client: Forom: Topics:
Date: Type:
Case:

plant capacity
7/96 Deposition and Oral Direct

Philadelphia Corporation, Moose River Corporation, Stevens &
Thompson Paper Company, Inc. , Union Falls Hydropowel'Limited

Partnership, Battenkill 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, Sissonville Limited Partnership, Middle Falls Limited Partnership, Diana-Dolgeville Corporation, VictOl)' Mills Hydro Co., Inc. , Lachute Hydro Co., and NewportHydro Associates v. Niagara

Mohawk Power Corporation

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

71149 Niagara Mohawk Power Corporation State of New York Supreme Court NUG hydro contract compliance, over-generation
11196

Oral Direct

GPU Energy Stranded Cost Petition EO97070459 GPU Energy State of New Jersey Board of Public Utitilities

0043

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Case 1:98-cv-00126-JFM

Document 791-4

Exhibit 4 FRANK C. GRAVES
Rule 26(a)(2)(B)-Disclosure of Depositionlfestimony

During the Last Four Years
Topics: Date: Type:
Case: Docket No. Client: Forum: Topics: Date: Type: Case:
" Case No.

" Direct, Rebuttal , and Supplemental Rebuttal

2/97

Market clearing prices, inflation, fuel costs, discount rates

Proposed MergerofENOV A Corporation and Pacific Enterprises EC97- 12Southern California Edison Company
Fcderal Energy Rcgu!~tory Commission

000

Vertical market power, gas-fired generation dominance 3/97 Affidavit
Bankruptcy 97Big Rivers Electric Corporation Kentucky Public Service Commission

204

Client: Forum: Topics:

Rural electric coop bankruptcy settlement, cost of service, transmission'

tariff
Date: Type:
Case:
6/97
Direct: Rebuttal ,

and Deposition
al.,

Application of Pacific Enterprises, Enova Corporation, et

for

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

A pproval of a Plan of Merger 96- 10- 038

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

Southern California Edison Company Public Utilities Commission of the State of California Vertical market power, gas-fired generation dominance 8/97 Direct

Stranded Cost Petition
OO974009, et al.

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

Direct and Joint Supplemental

Contains protected materials; .rcd~cted version availaMa

0044

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Exhibit 4 FRANK C. GRA VES
Rule 26( a )(2) (B)-D isclosureof Deposino off estimony

. During the Last Four Yean

Case:
Docket Nos.

Client: Forum: Topics:
Date:
Type: ,

Turners Falls Limited Partnership vs. Town of Montague, Board of Assessors 233732-233733, 240482-240483 2~S191-22S192, Indeck Energy Services of Turners Falls, Inc.

4/98
1/99

Commonwealth of Massachusetts Appellate Tax Board Turners Falls valuation report: market conditions and revenues

assessment for property tax basis valuation

Expert Report and Oral Testimony

Case: Docket No. Client: Forum:

Powcr ~urchase Arrangements

TransAlta Utilities Corporation
Independent Assessment Team for industry restructuring appointed by the Alberta Energy and Utilities Board Generation cost of capital under long-term indexed restructuring power purchase arrangements
Expert Report and oral examination by IAT
Cities of Anaheim and Riverside, California v. Deseret Generation&
Transmission Cooperative

Topics:
Date: Type:
Case:

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

EL97-S7-001 National Rural Utilities Cooperative Finance Corporation Inc. Federal Energy Regulatory Commission Cost of service for rural cooperatives vs. investor-oWned utilities;

coal plant valuation
3/99 Prepared Direct Testimony

0045