Comment Text:
The current delivery system has caused too much non convergence. The CME contract review process is taking 3 years to affect change from beginning of problem to change.
I support a hybrid alternative with 1 yearly observation period instead of VSR. A hybrid creates less uncertainty about what full carry is.
I suggest utilizing current VSR measures of 80% of full carry to provide a monthly deliverable storage increase of 5c, and 50% of full carry to provide a monthly deliverable storage decrease of 5c (not to decrease below the 8c monthly base rate).
I suggest using CZ/CH and SX/SF for annual observation periods as new crop value of storage would be known.
