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| Antonia Frost, Partner |
Toni, a partner in BGM, has worked in the energy field for over fifteen years, including four years of electric energy experience at FERC. She has focused her practice on helping clients implement and maintain robust compliance programs concerning all aspects of FERC regulation. In particular, she has conducted numerous audits and training programs concerning standards of conduct, affiliate restrictions, anti-market manipulation requirements, and market behavioral rules. In addition, using her extensive cost of service experience, she has prepared and conducted numerous rate cases concerning formula and stated transmission rates, transmission incentive rates for new transmission projects, and formula and stated power sales rates. On a day-to-day basis, she drafts and negotiates power sales contracts, including: full and partial requirements sales; base, intermediate and peaking sales; unit sales; tolling agreements; and the EEI Master Power Purchase & Sale Agreement. Her practice also includes market-based rates and market power analyses, affiliate power sales transactions, asset acquisitions and divestitures and corporate restructurings, and OATT transmission issues.
Before joining the firm, Toni was a trial attorney in FERC's Office of Hydroelectric and Electric Litigation from 1996 through 1998. She litigated cases involving the restructuring of California utilities and energy markets, mergers, OATT transmission tariffs, stranded costs and market-based rates for generation. From 1995 through 1996, she served as a public utility specialist for the trial staff of FERC's Office of Electric Power Regulation where she wrote testimony, testified in merger and OATT cases, developed discovery questions, and performed cost-based rate analyses. Prior to assisting FERC’s Trial Staff, she served as a public utility specialist for the advisory staff of the FERC's Office of Electric Power Regulation where she analyzed rate applications, performed cost of service analyses, and drafted rate filing deficiency letters.
Toni holds a B.A. in Economics with highest distinction from George Mason University. She was a recipient of the four-year George Mason Presidential Merit Scholarship and was awarded the Weber H. Peterson Award, given to the graduating economics major with the highest academic average. She graduated with a J.D. and a concentration in corporate and tax law from George Mason University School of Law. She is a member of the Energy Bar Association and the American Bar Association’s Section of Public Utility, Communications and Transportation Law. She is admitted to practice in the District of Columbia and the Commonwealth of Pennsylvania.
Bar Admissions • District of Columbia • Pennsylvania (Inactive)
Education • George Mason University School of Law, J.D. (1993) • George Mason University, B.A. in economics with highest distinction (1990)
Professional Associations and Memberships • Energy Bar Association • American Bar Association - Member of Section Public Utility, Communications and Transportation Law • Women’s Council on Energy and the Environment
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