Comment Text:
On behalf of The Commercial Energy Working Group (the “Working Group”), Sutherland Asbill & Brennan LLP hereby submits these comments in response to the proposed order issued by the Commodity Futures Trading Commission in response to a consolidated petition from certain regional transmission organizations (“RTOs”) and independent system operators (“ISOs”) exempting specified transactions from certain provisions of the Commodity Exchange Act (the “Act”) and Commission regulations (the “Proposed Order”). The Working Group appreciates the opportunity to provide the comments set forth herein and respectfully requests the Commission’s consideration of such comments.
Respectfully submitted,
David T. McIndoe
