E3 supported KCP&L Greater Missouri Operations Company (GMO) in its successful opposition to a $14 million disallowance proposed by the regulatory staff of the Missouri Public Service Commission (MPSC). GMO had purchased NYMEX natural gas futures to hedge against possible wholesale electricity price increases, but the spot and futures prices for natural gas plummeted, resulting in a $14 million loss to GMO. The MPSC staff contended that GMO’s hedge amounted to placing a bet in the stock market and should be disallowed. E3 founding partner C. K. Woo provided direct and surrebuttal testimony to the MPSC, explaining the role of cross-hedging in managing electricity spot-price risk and countering claims that GMO had misused natural gas futures. The MPSC denied its regulatory staff’s imprudence allegation, allowing GMO to fully recover its costs.