Karen Morgan has more than 20 years of experience, specializing in utility rate and regulatory matters. Her work has focused on research of cost of equity capital for public utilities and pipeline transportation companies, capital market forecasting, financial statement analysis, and other utility issues; including investor-owned, crown, and municipal electric utilities, gas utilities, water utilities, and telecoms. Prior to consulting she worked for both private and public sector entities including British Telecom, Enbridge Gas Distribution, and Energy Mines and Resources Canada.
Ms. Morgan recently testified in two separate hearings before the Nova Scotia Utility and Review Board (NSUARB) (October 2019). The first heard testimony on Nova Scotia Power Inc.’s (NSPI) Base Cost of Fuel Application, which seeks to set customer rates for fuel and purchased power for 2020 through 2022. The second heard testimony on the application by NSP Maritime Link (NSPML) to recover $144.5 million in 2020 related to costs associated with the “Maritime Link,” a high-voltage, direct current transmission line delivering energy from Newfoundland and Labrador to Nova Scotia. She also filed testimony in NSPML’s recent application to recover costs of approximately $172 million in 2021.
In Mississippi, Ms. Morgan has also submitted testimony on behalf of the Mississippi Public Utilities Staff before the Mississippi Public Service Commission (Docket No. 2015-UN-049 (Atmos Mississippi)). Bates White provided an assessment of the utility’s rate rider as a tool to recover the costs, recommended enhancements and alternatives, and provided an assessment of the impact on the financial indicators of Atmos Mississippi of the rider as proposed and under various scenarios arising from the testimony on other witnesses.
In addition to the above, Ms. Morgan has worked on a wider variety of projects, including as advisor to the Nebraska Public Service Commission with respect to the Black Hills Nebraska natural gas general rate case; the review of utility transmission and distribution capital investment plans; project valuations; FERC market power filings; and issues related to transfer pricing. Other work includes energy and capacity auction monitoring for commissions in Illinois, New Jersey, and Ohio.
Before joining Bates White, Ms. Morgan supported the preparation of over 150 cost of capital studies and testimonies for presentation before public utility commissions in both the United States and Canada, including the generic rate of return cases in both Alberta and British Columbia. These testimonies incorporated the assessment of the impact of business risk factors (e.g., competition, rate design, contractual arrangements) on capital structure and equity return requirements. She also conducted research related to regulatory practice (e.g., weighted average cost of capital, performance-based return, capital cost recovery, deferral accounts, etc.).
Certified Rate of Return Analyst
Chartered Financial Analyst
MA, Economics, University of Western Ontario
BA, Economics, Queen’s University at Kingston
- In Elevolution–Engenharia, S.A. v. Mauritania, an international arbitration matter, quantified damages suffered by the claimant in a case involving a canceled contract to rebuild a highway in Mauritania.
- On behalf of the claimant in Mesa SpA v. Número Um-Reparação de automóveis SA and TOPCHALLENGE SGPS, S.A., an international arbitration matter under ICC rules, quantified claimed damages and responded to counterclaim damages. The claimant alleges violation of terms (including regarding non-competition) of the master franchise agreement for MIDAS automobile repair shops in Portugal.
- Supported the preparation of over 150 cost of capital studies and testimonies for presentation before public utility commissions in both the United States and Canada including the recent generic rate of return cases in both Alberta and British Columbia. Testimonies incorporated the assessment of the impact of business risk factors (e.g., competition, rate design, contractual arrangements) on capital structure and equity return requirements.
- Conducted research projects related to regulatory practice (e.g., weighted average cost of capital, performance-based return, capital cost recovery, deferral accounts, etc).
- Developed a spreadsheet-based cost of service model for a large Canadian vertically integrated utility. The final product aggregated a series of regional cost of service models and was designed to permit some modification of input assumptions to facilitate scenario testing.