Mr. Sullivan joined the firm in September 2005. He was elected President of BWMQ in April 2006. Since joining BWMQ, Mr. Sullivan has been actively engaged as an expert witness in a number of energy market proceedings.  Mr. Sullivan, recently filed testimony on oil pipeline market power in the Mobil Pipe Line Company proceeding in Docket No. OR07-21.  Mr. Sullivan has filed testimony on short-term rates, depreciation, and the ROE proxy group in the PNGTS proceeding in Docket No. RP08-306.  In the El Paso proceeding in Docket No. RP08-426, Mr. Sullivan filed testimony on short-term value-based rates.  In addition, Mr. Sullivan has filed expert witness testimony on market power in the GTN proceeding in Docket No. RP06-407, an expert report in the USGen proceeding in Docket No. RP06-391, and oil pipeline ratemaking testimony in the TAPS proceeding in Docket No. IS05-82. Mr. Sullivan has also participated in a number of State regulatory proceedings during the past three years.  Mr. Sullivan has over 30 years of experience in the natural gas pipeline, oil pipeline and electric utility industries. His areas of expertise include formal market power analysis and all facets of natural gas, oil pipeline and electric utility ratemaking.

Mr. Sullivan was employed by the Federal Energy Regulatory Commission from March 1979 to September 2005.  He retired as a Supervisor in the Technical Analysis Division of the Office of Administrative Litigation.  Mr. Sullivan was a technical expert for the entire 26 years he was at the Commission and provided testimony in many formal proceedings.  The areas of his expertise included: formal market power analysis, market based rates, cost allocation and rate design, oil pipeline regulation, electric utility regulation, depreciation, Mcf/mileage studies, refunctionalization studies, offshore regulation, negotiated rates, discount studies, and other regulatory issues. Mr. Sullivan has applied his expertise relating to natural gas pipeline, oil pipeline and electric utility issues in a wide range of formal proceedings at the Commission.  He has developed many creative and innovative approaches to deal with these and related issues in administrative proceedings at the Commission.

As a Supervisor in the Office of Administrative Litigation, Mr. Sullivan supervised, initiated, directed and coordinated the preparation and presentation of the Commission’s technical Trial Staff’s settlement and testimony position on all matters set for formal hearing in natural gas pipeline, oil pipeline and electric utility proceedings.  These issues include formal market power analysis, market based rates, rate design; seasonal rates; distance based rates; separation of services (unbundling); discounting; capacity release; capacity assignments; interruptible transportation rates; storage rate design; refunctionalization studies; stranded costs; restructuring issues; incremental versus rolled-in rates; depreciation and negative salvage; cost of service and rate base issues; oil pipeline rates; tariffs and operational issues; and the resolution of contract disputes.

Mr. Sullivan has testified as an expert witness on market power and market based rates, cost classification, allocation and rate design, billing determinants, depreciation, and other rate related issues in numerous natural gas rate proceedings, oil pipeline proceedings and electric proceedings.  He has been responsible for various presentations to FERC Commissioners on such topics as Offshore Gathering Policy, Negotiated Rates and Discounting, Enron and Manipulation of the Western Energy Markets in 2000-2001, and Section 5 rate case proceedings.

Mr. Sullivan has a BA with Honors in Economics from the University of Massachusetts at Boston, and attended one year of graduate Economics at the University of York, England.

• Testimony Summary