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Comment for Industry Filing 18-001

  • From: Joshua S. Ludvisgon
    Organization(s):
    Bellingham Farmers Elevator

    Comment No: 61705
    Date: 8/9/2018

    Comment Text:

    The lack of convergence penalizes all, but affects those who are unable to transfer or offset their risk in international markets the most. VSR solves the above problem, but a hybrid with one yearly observation period creates less complexity and uncertainty about what full carry is. We are in favor of using CZ/CH and SX/SF for annual observation periods as new crop value of storage would be known.

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