• 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 and utility 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 30 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, municipal power, energy marketers, and industrial and commercial users of utility services.  

Frank acts as general regulatory counsel to municipal utilities, electric cooperatives and renewable energy developers.

His most recent work involved the acquisition and regulatory approvals of a 780-mile 600 kV HVDC electric transmission line extending from Southwest Kansas and into Indiana.

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.

  • Represent major independent power producer in the acquisition, regulatory approvals and development of 780-mile 600 kV HVDC transmission line extending from southwest Kansas to Indiana.
  • Represented clients’ interests in Arizona’s Navajo Generating Station economic feasibility assessment.
  • Assisted TVA in evaluation of Watts Bar Nuclear Plant investigation.
  • Represented a major U.S. bank in the evaluation and termination of sale-lease-back arrangement at a multi-unit major coal generating facility.
  • Represent major Kansas municipal power entity in transmission asset acquisition and expansion.
  • Represent state municipal joint action agency as general legislative and regulatory counsel.
  • Represent Colorado municipality in wholesale power supply agreement negotiations and debt restructuring.
  • Represent largest U.S. retail facility in multiple states with power supply and energy efficiency contracts.
  • Assisted Canadian entity on state regulatory approvals involving acquisition of independent transmission facilities.
  • Assisted client on regulatory structure of a 10 MW solar facility on U.S. military facilities.
  • Represent the largest industrial consumer of electric power in Missouri in negotiations with legislative, regulatory and utility officials for competitive efficient power supply.
  • 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. 
  • Represented Southern Missouri Natural Gas, as general counsel and with its pipeline expansion into the fastest-growing area of Missouri. Services include real estate acquisitions, condemnation, construction contracts and regulatory approvals. 
  • 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. 
  • 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. 
  • Legislative counsel to wind industry on major facets or enactment and implementation of renewable energy standards in two Midwest states. 
eAlerts Updates
September 25, 2019
eAlerts Updates
April 2019
text icon Publications & Presentations
December 7, 2015
text icon Publications & Presentations
The Cost of Clean Power
Missouri Business Magazine
May 2015
text icon Publications & Presentations
Kansas Logistics Park: Emerging Friends in the Logistics Market
Harvey County Economic Development Council, Inc.

Frank Caro-Panelist

October 2012
text icon Publications & Presentations
Emerging Energy Policy Issues: Missouri and Kansas
Kansas City Chamber of Commerce
Frank Caro-Speaker
October 2012
text icon Publications & Presentations
Missouri Energy Policy Conference
Kansas and Missouri State Regulatory Panel Issues
Frank Caro-Moderator
October 2012
text icon Publications & Presentations
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
text icon Publications & Presentations
Presentation given by Polsinelli Energy Chair Frank Caro to the Green Energy Conference of the International Brotherhood of Electrical Workers
May 17, 2011
text icon Publications & Presentations
Presentation by Polsinelli Energy Chair Frank Caro