                                                                    Exhibit 99.2

                            UNITED STATES OF AMERICA

                      FEDERAL ENERGY REGULATORY COMMISSION

FACT-FINDING INVESTIGATION OF POTENTIAL                    DOCKET NO. PA02-2-000
MANIPULATION OF ELECTRIC AND
NATURAL GAS PRICES

TO: DONALD J. GELINAS, ASSOCIATE DIRECTOR OF OFFICE OF MARKETS, TARIFFS, AND
RATES

                     RESPONSE OF THE PINNACLE WEST COMPANIES
                    TO COMMISSION'S MAY 21, 2002 DATA REQUEST

     The following  constitutes  the response of Arizona Public Service  Company
("APS") and its affiliates, Pinnacle West Capital Corporation ("PWCC"), Pinnacle
West  Energy  Corporation,  and APS  Energy  Services  Company,  Inc.  ("APSES")
(collectively  the "Pinnacle West Companies") to the  Commission's  Data Request
dated May 21, 2002,  addressed to those sellers of wholesale  electricity and/or
ancillary  services  in  the  United  States  Portion  of  the  Western  Systems
Coordinating Council during the years 2000-2001 (the "Data Requests").

     In  responding  to the  current  Data  Requests,  and as  described  in the
accompanying  affidavit of David A.  Hansen,  Vice  President  of Pinnacle  West
Marketing and Trading for Pinnacle West Capital  Corporation,  the Pinnacle West
Companies conducted a thorough investigation by outside counsel into the trading
activities of their  employees  and agents in the United  States  portion of the
WSCC during the years 2000 and 2001. This investigation  included  interviews of
trading and other  personnel  and a review of  available  documentation.  To the
extent that additional  documentation or information is discovered that warrants
supplementation  of  this  response,  the  Pinnacle  West  Companies  will do so
promptly.

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     The Request for Admission  and Request for  Production of Documents are set
forth below followed by the Pinnacle West Companies' responses.

     I.   REQUEST FOR ADMISSION

          A. ADMIT OR DENY:  THE COMPANY  ENGAGED IN  ACTIVITIES  REFERRED TO AS
     "WASH," "ROUND TRIP" OR "SELL/BUYBACK"  TRADING.  THIS TRADING INVOLVES THE
     SALE OF AN  ELECTRICITY  PRODUCT TO  ANOTHER  COMPANY  WITH A  SIMULTANEOUS
     PURCHASE OF THE SAME PRODUCT AT THE SAME PRICE.

     The  Pinnacle  West  Companies  deny  that  they  engaged  in the  activity
     described in A above.

          B. IF YOU SO ADMIT, PROVIDE TRANSACTION BY TRANSACTION DETAILS FOR ALL
     SUCH TRANSACTIONS  YOUR COMPANY ENGAGED IN, INCLUDING,  BUT NOT LIMITED TO,
     THE FOLLOWING:

               1. INDICATE THE METHODS AND RATIONALE USED TO ARRIVE AT THE VALUE
          OR COMPENSATION OF SUCH TRANSACTIONS.

               2.  INDICATE  WHETHER  ANY SUCH  TRANSACTIONS  WERE  REPORTED  TO
          PLATT'S,  BLOOMBERG,  OR ANY ORGANIZATION THAT MONITORS,  PUBLISHES OR
          REPORTS  TRADING  DATA  (INCLUDING  BID-AND-ASK  DATA) OR PUBLISHES OR
          REPORTS PRICES OR FORWARD INDICES.

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               3. IDENTIFY ALL SUCH TRANSACTIONS  REFERRED TO IN QUESTION 3 THAT
          WERE SO PUBLISHED OR REPORTED, OR WERE DISSEMINATED IN ANY MANNER.

               4. IDENTIFY ALL TRADERS THAT  PARTICIPATED IN SUCH  TRANSACTIONS,
          BY NAME AND POSITION  WITHIN YOUR  COMPANY,  IF EMPLOYED BY YOU, OR BY
          NAME AND AFFILIATION IF THEY WERE NOT OR ARE NOT PRESENTLY EMPLOYED BY
          YOUR COMPANY.

               5. IDENTIFY HOW SUCH TRANSACTIONS WERE EXECUTED (E.G., WHETHER AN
          ELECTRONIC  PLATFORM  WAS  USED TO  INITIATE  THE  SALE,  WITH THE BUY
          TRANSACTION SUBSEQUENTLY ARRANGED THROUGH A BROKER OR BY TELEPHONE).

               6. DESCRIBE ALL POLICIES AND  PROCEDURES  IMPLEMENTED  TO PREVENT
          FUTURE TRANSACTIONS OF THIS TYPE.

          Not applicable.

II.  REQUEST FOR PRODUCTION OF DOCUMENTS

TO THE EXTENT YOUR COMPANY  ENGAGED IN "WASH,"  "ROUND TRIP," OR  "SELL/BUYBACK"
TYPE TRANSACTIONS, PROVIDE THE FOLLOWING DOCUMENTS:

     A.   PROVIDE  COPIES OF ALL  COMMUNICATIONS  OR  CORRESPONDENCE,  INCLUDING
          E-MAIL MESSAGES,  INSTANT  MESSAGES,  OR TELEPHONE LOGS,  BETWEEN YOUR

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          COMPANY  AND  ANY  OTHER  COMPANY   (INCLUDING   YOUR   AFFILIATES  OR
          SUBSIDIARIES) THAT REFER OR RELATE TO THIS ACTIVITY.

               Not applicable.

     B.   PROVIDE COPIES OF ALL MATERIAL, INCLUDING, BUT NOT LIMITED TO, OPINION
          LETTERS,  MEMORANDA,  COMMUNICATIONS  (INCLUDING E-MAILS AND TELEPHONE
          LOGS),  OR REPORTS,  THAT ADDRESS OR DISCUSS YOUR COMPANY'S  KNOWLEDGE
          OF,  AWARENESS  OF,  UNDERSTANDING  OF, OR EMPLOYMENT OR USE OF ANY OF
          SUCH  TRANSACTIONS  IN THE U.S.  PORTION OF THE WSCC DURING THE PERIOD
          2000-2001.

               Not Applicable

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