• vcard
  • Education
    • J.D., Washburn University School of Law, 1983
    • B.A., Assumption College, 1980
  • Court Admissions
    • United States Supreme Court, 1987
    • U.S. Court of Appeals, Tenth Circuit, 1987
    • U.S. District Court, District of Kansas, 1983
    • U.S. Court of Appeals, District of Columbia Circuit, 1987

Frank Caro serves his energy, utility and telecommunications industry clients as a partner in meeting their legal challenges, as well as a trusted resource for strategies that are built on his vast experience in business, regulatory and government affairs.  

As chair of the firm’s national energy group, Frank has been representing clients in the electric, gas and telecommunications industries for more than 25 years, during which time he has assisted in structuring complex business, regulatory and legislative solutions to his clients’ most challenging legal problems.  

Frank supports clients that are involved in all facets of the energy industry from developers to end-use consumers. His energy clients have included energy producers, oil and gas gathering systems, pipelines, large public utility/energy industry organizations, renewable energy developers, rural electric cooperatives, energy marketers, and industrial and commercial users of utility services.  

His work has recently involved assisting a major electric utility in the completion of a multi-faceted infrastructure development and regulatory plan that encompasses a new $2 billion 850-MW super critical base-load coal plant, significant environmental upgrades, and wind power.  

Frank acts as general counsel to a renewable energy company currently developing wind energy resources in 12 states throughout the Midwest, and is involved in the development of one of the largest wind projects in the country.  

Frank also represents clients before the Missouri Public Service Commission and the Kansas Corporation Commission (KCC) on various matters involving certification proceedings, mergers and acquisitions, rate tariff applications, generic rulemaking proceedings and complaints.  He serves as general regulatory counsel for numerous public utilities.  

Prior to joining the firm, Frank served as general counsel for the KCC and acted as chief trial counsel in numerous hearings before the KCC, FERC and FCC.

  • Assist major electric utility in drafting, implementation and approval of comprehensive energy plan encompassing construction of a $2 billion 850-MW base-load super critical electric generating facility, environmental upgrades to existing plant, wind resource development, demand side management programs and rate stability programs. During the implementation phase, assisted with multiple rate case(s) and various other regulatory issues. 
  • Represent major energy company in oil and gas gathering facilities assessment. 
  • Represented major electric utility in evaluation and regulatory approvals for coal-fired electric generating facility retrofit. 
  • Represent major interstate gas pipeline company in major pipeline expansion from Wyoming to Western Missouri. 
  • Represent a natural gas company in its pipeline expansion into the fastest-growing area of Missouri. Services include real estate acquisitions, condemnation and construction contracts. 
  • Represented client in acquisition of rural natural gas gathering and distribution facilities from bankruptcy and formation of a non-profit public utility for major agricultural users in Western Kansas. 
  • Assisted public utilities with numerous types of tariff filings before state public utility commissions, including those addressing weatherization, low-income programs, parallel generation, actual cost adjustment (ACA) filings, energy efficiency riders, energy star programs, net metering, demand side management, peak load curtailment, and various other tariff filings. 
  • Assisted electric cooperatives with multiple rate cases and other regulatory issues, including purchase power agreements (PPAs), and construction of gas turbine generation facilities.
  • Assisted major electric cooperative with addressing rights and responsibilities under Notice to Construct (NTC) received by the Southwest Power Pool (SPP), and assisted with subsequent issues related to designating rights and responsibilities under the NTC to a large electric transmission company. 
  • Negotiated large generator interconnection agreements with major transmission companies and RTO. 
  • Act as general counsel for a major U.S. wind developer, and represent it in every aspect of development, construction, sale of power (such as purchase power agreements and asset sales), construction and finance issues, and other issues involved in the construction and operation of wind farm developments. 
  • Served as lead counsel in the development and construction of one of the largest wind farms in the Midwest. The total project size is approximately 250 MW. Polsinelli also negotiated leasehold agreements with more than 100 landowners that represent nearly 40,000 acres. 
  • Oversee leasing activities for over 30 wind energy projects in 12 states in the Midwest with a potential energy generating capacity of over 10,000 MW. 
  • Assisted wind developers with obtaining exemptions as a public utility under state statutes addressing independent power producers and negotiated transmission construction interconnects. 
  • Assisted solar energy developer with obtaining state approvals, governmental contracting issues, net metering and interconnection issues, and tax issues (such as the investment tax credit, production tax credit, MACRS depreciation, and other issues). 
  • Local counsel to major international renewable energy company on tax, construction, regulatory and litigation issues associated with operation of renewable energy facilities in the U.S. 
  • Represent rural gas users in the construction of multiple gas distribution systems, interstate pipeline interconnects and all regulatory and corporate proceedings. 
  • Represented major investor owned electric utility in all facets of due diligence in the acquisition and merger of a neighboring state’s major investor owned electric utility. 
  • Legislative counsel on major telecommunications regulatory and legislative changes.
  • Legislative counsel to wind industry on major facets or enactment and implementation of renewable energy standards in two Midwest states. 
  • Legislative counsel to public utilities on legislative changes involving gas supply and gas gathering access issues.
eAlerts Updates
April 2019
text icon Publications & Presentations
December 7, 2015
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The Cost of Clean Power
Missouri Business Magazine
May 2015
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Kansas Logistics Park: Emerging Friends in the Logistics Market
Harvey County Economic Development Council, Inc.

Frank Caro-Panelist

October 2012
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Emerging Energy Policy Issues: Missouri and Kansas
Kansas City Chamber of Commerce
Frank Caro-Speaker
October 2012
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Missouri Energy Policy Conference
Kansas and Missouri State Regulatory Panel Issues
Frank Caro-Moderator
October 2012
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Natural Gas Production in Missouri: An Overview of Fracking and Pipeline Developments
Missouri Energy Initiatives, Energy Perspectives

Co-Authors Alan Claus Anderson and Frank Caro

June 2012
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Presentation given by Polsinelli Energy Chair Frank Caro to the Green Energy Conference of the International Brotherhood of Electrical Workers
May 17, 2011
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Presentation by Polsinelli Energy Chair Frank Caro
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Presentation Given to The Kansas Bankers Association
April 2010