Comment Text:
10-002
COMMENT
CL-02503
From:
Sent:
To:
Subject:
kallen@midstateenergy, com
Thursday, April 15, 2010
8:48 PM
secretary
Speculative Position Limits in Energy Futures Contracts
Ken Allen
1130 N. Scenic Hwy
Lake Wales, FL 33853-3249
April 15, 2010
David Stawick
U.S. Commodity Futures Trading Commission
1155 21st Street, NW
Washington, DC 20581
Dear David Stawick:
I am writing today to endorse comments submitted by the Petroleum
Marketers Association of America and the New England Fuel Institute
submitted on April 9, 2010 on the proposed rule to implement speculative
position limits for futures and options contracts for natural gas, crude
oil, heating oil and gasoline. Futures markets were designed as a tool
for bona fide commercial businesses and end-users to manage risk and
"discover" prices for energy based on supply and demand economics.
Businesses and consumers rely on these markets and are harmed when they
become excessively volatile or subject to extreme price shocks, as we saw
with the 2007-2008 energy bubble. In the past ten years, such events have
become common and federal regulators failed to take assertive action to
address the causes and to restore confidence in the energy futures markets.
By strengthening and passing this proposed rulemaking, the Commission has
an opportunity to take an important step in this regard. It will be
addressing the main cause of recent market instability - excessive
speculation. Financial investors, including banks, hedge funds and index
funds, speculate in the energy commodities markets for profit, rather than
commodity-related businesses and users, who do so to protect themselves
from volatility and risk. Speculators take on the risk that hedgers seek
to shed, however speculation should not dominate the markets. Moreover,
one speculator or class of speculator should not be allowed to take a
large, controlling position in any a single commodity.
The Commission has a statutory obligation, if not a compelling moral
obligation, to establish hard limits on the size of positions that
speculators can take in these markets, and to bar them from any
exemptions. The rule that has been proposed is not perfect, and again, I
strongly urge the technical improvements suggested by the comments I have
written to endorse.
In considering the rule, Commissioners must look past opposition by the
financial community and remember the affect that excessive speculation has10-002
COMMENT
CL-02503
on businesses like mine, my consumers and the broader economy. It should
establish restrictive speculative position limits, and implement them
expeditiously, before ~ve see a repeat of the 2007-2008 energy bubble and
another major shock to a country still recovering from recession.
Thank you for your consideration.
Sincerely,
Ken Allen
863-676-3910
