Comment for Proposed Rule 76 FR 4752

Comment Text:

As a small family owned petroleum marketer in upstate New York I am writing to voice my support for the adoption of proposed rule (RIN 3038-AD15 and 3038-ad16 Position Limits for Derivatives)

After years of highly volatile commodity prices, the CFTC is finally poised to impose position limits for physical commodities. I watch the energy market on a daily basis and see the volatility. I receive the inventory report every week from the EIA of DOE whereas the inventories are generally greater than the year before and exceed the 5 year average. It is my belief that the massive positions held by speculators has contributed to the volatility of the market, not supply and demand.

I, like many of my colleagues, use to hedge to protect our costs and take delivery of the product, which in turn, sell to my customers. In doing this transaction I had to protect the downside by purchasing a put and because of the volatility caused by excessive speculation `makes it to expensive.

Title VII of the Wall Street Reform Act reaffirms the importance of position limits by providing the Commission with new authorities to impose such limits on currently unregulated markets. As proposed in this rule, position limits will play a critical role in reestablishing market fundamental, theerfore, I urge the adoption of this rule.

Thank you for your consideration.

Sincerely,
Thomas E. Keen