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Biography
Publications
Personal Interests

Dr. Ledgerwood is an expert in market competitiveness with an emphasis on the economic analysis of potential market manipulation claims in commodities and securities markets. He specializes in the analysis of competitive matters within and across physical and financial markets; issues pertinent to economic regulation, ratemaking, and resource planning; asset valuations; and analyses pursuant to matters in tort, contracts, or involving fraud. His twenty-three years of experience as an economist and an attorney allow him to provide clients with unique insights into matters involving potential litigation, especially as they relate to meeting burdens of proof under statutory requirements.

As a former economist and attorney for the Office of Enforcement for the Federal Energy Regulatory Commission (FERC), he evaluated manipulative behavior within and across wholesale electricity and natural gas markets. This experience led him to develop a framework for detecting and analyzing manipulative behavior. The framework separates actions that cause the manipulation from those that benefit from its effect, simplifying the proof (or disproof) of the manipulation. This logic is particularly useful in assisting clients in maintaining compliance and for supporting or defending enforcement actions brought under the anti-manipulation rules in place in the U.S. and EU.

Dr. Ledgerwood has testified as an expert witness before state utility commissions and in federal court. He previously taught graduate courses in microeconomic theory, regulation, law and economics, antitrust and remedies at the University of Oklahoma and was an Affiliated Faculty member at the Georgetown University Public Policy Institute.

Representative Engagements
Presentation
January 26, 2017
Presented at the Electric Utility Consultants, Inc. (EUCI) conference, “Financial Transmission Rights (FTRs/CRRs/TCRs)”
Article
January 14, 2016
Published in Risk.net
Article
December 9, 2015
Published in the ABA’s Securities Litigation Journal
Article
November 12, 2015
Published in Practice Points, a publication of the ABA’s Securities Litigation Committee
Book
Market Power and Market Manipulation in Energy Markets: From the California Crisis to the Present
April 2015
Gerald A. Taylor, Shaun D. Ledgerwood, Romkaew P. Broehm, and Peter S. Fox-Penner
Published by PUR Inc.
Presentation
Differentiating a Legitimate Hedge From a Target for Manipulation
February 19, 2015
Presented at the EUCI Conference on Integrating Energy Trading, Valuation, Market and Credit Risk Management, Denver, CO
Article
Market Manipulation Push is Widening the Compliance Gap
January 23, 2015
Published in Risk.net
Presentation
The Chasm between Following Market Rules and Fraud
December 4, 2014
Presented to the Stanford Program on Energy and Sustainable Development
Article
An Economic Evaluation of 'Funding' for Research Tax Credits
September 29, 2014
Published in Tax Notes
Presentation
Uneconomic Trading as Transactional Fraud: EU Compliance Lessons From the US
April 23, 2014
Presented to AIGET
Presentation
Market Manipulation and Antitrust: Complements or Substitutes?
February 25, 2014
Presented to the NYC Bar Association Antitrust & Trade Regulation Committee
Presentation
A Framework for Market Manipulation Compliance and Enforcement
January 2014
Presented to the Houston Chapter of the Energy Bar Association, Houston, TX
Article
Using Virtual Bids to Manipulate the Value of Financial Transmission Rights
November 2013
Published in The Electricity Journal, Vol. 26, Issue 9
Presentation
A Holistic Approach to Market Manipulation Compliance
August 2013
Presented to the energy trading and compliance staff of a multinational financial institution, New York, NY
Article
Uneconomic trading and market manipulation
July 2013
Published in Energy Risk
Presentation
Market Manipulation post Hunter vs. FERC: A Framework for Unified Analysis
June 2013
Panel presentation delivered at the Harvard Electricity Policy Group’s 71st Plenary Session, Calgary, AB
Presentation
A Unifying Approach to Market Manipulation Compliance
June 2013
Presented at the Platts European Gas and Power Trading Conference, London, UK
Presentation
A Perspective on Market Manipulation
May 2013
Presented at an anti-manipulation compliance seminar for the traders and compliance staff of a major U.S. electricity trading company
Presentation
A Holistic Approach to Market Manipulation Compliance
May 2013
Presented to the partners of an international law firm interested in applications to energy, commodities and securities trading, Brussels, Belgium
Presentation
A Case Study of an Alleged Market Manipulation: Deutsche Bank
April 3, 2013
Presented to the Energy Bar Association
Presentation
ISO/RTO Financial Products and Recent Trends in FERC Enforcement
April 2013
Panel presentation sponsored by the Energy Bar Association Electricity Regulation Committee and the Compliance and Enforcement Committee, Washington, DC
Presentation
A Holistic Approach to Market Manipulation Compliance
April 2013
Presented to the partners of a national law firm interested in applications to energy, commodities and securities trading, Washington, DC
Presentation
Uneconomic Trading in Energy Markets: A Framework of Market Manipulation
April 2013
Presented at the Penn State Faculty Colloquy, State College, PA
Presentation
A Holistic Approach to Compliance: REMIT and the MAD
April 2013
Presented at an anti-manipulation compliance seminar for the traders and compliance staff of a major European energy trading company
Presentation
Market Manipulation in Wholesale Electricity Markets
March 2013
Presented to the NP Market Council
Presentation
An Economic Approach to FERC Anti-Manipulation Compliance
March 2013
Presented at an anti-manipulation compliance seminar presented in separate sessions to the compliance staff and traders of a major commercial energy trading company
Presentation
Market Manipulation Cases in U.S. Wholesale Electricity and Natural Gas Markets
February 2013
Presented at the Bird & Bird Seminar on Market Abuse, London, UK
Presentation
Market Manipulation in Wholesale Electricity and Natural Gas Markets
January 2013
Presented for the West LegalEd CLE program (webinar)
Presentation
Recent Market Violations and Their Repercussions on Compliance and Counterparty Risk
November 2012
Panel Moderator and presenter at the EUCI Conference on Credit & Counterparty Risk, Baltimore, MD
Presentation
Meeting Cross-Border Requirements: Understanding Changing International Regulations and Ensuring Global Compliance
November 2012
Panelist and presenter at the ACI Energy Trading Compliance and Regulatory Enforcement Conference, Washington, DC
Presentation
An Economic Approach to FERC Anti-Manipulation Compliance
November 2012
Presented at an anti-manipulation compliance seminar, separate sessions to the gas and electricity trading groups of a major utility’s trading group
Presentation
Using Virtual Bids to Manipulate the Value of Financial Transmission Rights
November 2012
Presented at the USAEE/IAEE Annual Conference, Austin, TX
Article
A Framework for Analyzing Market Manipulation
September 2012
Published in Review of Law & Economics, Volume 8, No. 1
Presentation
FERC’s Anti-Market Manipulation Rule and the Impact on Physical and Virtual Market Participants
August 2012
Panel moderator and presenter at the EUCI FTR Conference, Houston, TX,
Article
A Comparison of Anti-Manipulation Rules in U.S. and EU Electricity and Natural Gas Markets: A Proposal for a Common Standard (Russian Translation)
April 2012
Published in Energy Law Journal
Presentation
An Analytical Framework for Anti-Manipulation Compliance, Monitoring, and Enforcement
April 2012
Presented at the Marcus Evans Conference on European Energy Market Integrity: REMIT & Regulatory Compliance, London, UK
Article
A Comparison of Anti-Manipulation Rules in U.S. and EU Electricity and Natural Gas Markets: A Proposal for a Common Standard
April 2012
Published in Energy Law Journal
Article
Rummaging through the Bottom of Pandora’s Box: Funding Predatory Pricing through Contemporaneous Recoupment
April 2012
Shaun D. Ledgerwood and Wesley Health
Published in Virginia Law and Business Review, Volume 6, Number 3
Presentation
Energy Trading Compliance and Enforcement Post Dodd-Frank: A Framework of Market Manipulation
2012
Presented at an anti-manipulation compliance seminar for law firms, Washington, DC (January and March 2012)
Article
Market Manipulation in Wholesale Electricity Markets
2012
Published by Energy Law Journal, Volume 33, Number 1, Cyrillic translation
Report
Completing the Puzzle: Defining Manipulation Under REMIT
January 2012
Published by The Brattle Group, Inc.
Presentation
The Search for a Uniform Definition of Market Manipulation: A Proposed Framework
October 2011
Presented at a Conclave Concerning the REMIT, London, UK
Presentation
Manipulation of FTR Markets
July 2011
Presented to EUCI’s Conference on Financial Transmission Rights, Houston, TX
Presentation
Triggers and Targets: A Framework for Analyzing Market Manipulation
July 2011
Presented to the American Gas Association, Washington, DC
Report
Protecting Market Integrity by Defining Market Manipulation
June 2011
Published by The Brattle Group, Inc.
Article
Market Manipulation Without Market Power
June 2011
Published in Law360
Presentation
A Framework for Defining Energy Market Manipulation
May 2011
Presented to the Bracewell & Giuliani LLP Energy Compliance Network , Houston, TX
Presentation
Market Manipulation
February 2011
Panel presentation at Skadden’s 6th Annual Enforcement and Compliance Conference with John Estes III and Joseph Kalt, Washington, DC
Report
Screens for the Detection of Manipulative Intent
December 2010
Available from Social Science Research Network (SSRN)
Presentation
The Impact of FERC’s Anti-Manipulation Statute on FTRs and Related Positions
July 2010
Presented at EUCI’s Conference on Financial Transmission Rights, Alexandria, VA
Article
Section 6: Natural Gas Capacity Release and Electricity Transmission Reassignment
August 2009
In 2008 State of the Markets Report, Published by the Division of Energy Market Oversight, Office of Enforcement, Federal Energy Regulatory Commission

Shaun is a native of Norman, Oklahoma, where he attended and taught law and economics classes at the University of Oklahoma from 1983-1986 and 1989-2008 and where he still has season football tickets for his beloved Sooners.

From 1997-2008, he worked as a consulting economist for C.H. Guernsey & Company in Oklahoma City. While there, he learned the “physical side” of the electric industry from his many engineer colleagues, as well as the regulatory processes associated with ratemaking and the rise of competitive electricity markets. Shaun’s teaching and consulting interests eventually coalesced into a practice focused on regulatory economics, competition-related analyses, and the evaluation of liability and damages claims for cases in contract and tort.

In 2008, he and his wife moved to downtown Washington, DC to pursue a career with the Federal Energy Regulatory Commission’s Office of Enforcement. While there, he worked on many of the major market manipulation enforcement cases brought by the agency, coming to know several of his colleagues at Brattle as a result. Shaun joined Brattle in January 2011 to build a practice area focused on market manipulation in securities and commodities markets.

Shaun has been a member of the Oklahoma Bar Association since 1990, and is presently a member of the American Bar Association, Federal Energy Bar Association, American Economic Association, the United States Association of Energy Economics, the International Association of Energy Economics, and Phi Beta Kappa.

His wife and he continue to live and prosper in DC, happily enjoying the many restaurants, theaters, and other activities the city and surrounding areas provide.