Comment Text:
10-002
COIMMENT
CL-02676
The Service Oompany
7116 Park Avenue
~ P.O.
Box 1327
¯ Pennsauken, NJ 08109
April 20, 2010
David Stawick~ Secretary
U.S. Commodity Futures Trading Commission
Three Lafayette Centre
1155 21
st
Street, NW
Washington, D,C. 20581
(856) 665-4545 or (800) ~2~-49.~
COMMENT
Subject:
Comments on Proposed Speculative Position Limits for Energy
(File#10-002)
Dear Mr. Stawick;
McAllister is a firm that distributes Heating Oil to Residential, Commercial, and
Industrial customers in the Seven County Area of Southern New Jersey. (Burlington
County and South,) We also install and service Central Air Conditioning and Central
Heating systems of all types plus Domestic Hot Water Heating and other types of Home
comfort equipment in the same geographical area.
;,. ,,.;:;~., , .;,"o,,.~,.~.:,,..,.
The Petroleum..Marketers Association of America and the New England Institute
submitted comments on April 9, 2010;t~giarding the proposed,rule, to implement
speculatiye position limits for futures anddpti0ns.for natural gas, crude.oiL_ heating oil
and gasoline, which I endorse.
":
~ '~
.... .. . ~... ~.: ~ .
Futures marketS weredesigned as a toolfor bona ifide ,c.~mm~r"Ciial bgSifi(s;s and end-
use}s tO manage risk and. d~scovery, .pric~s fo.r..ene,r.gy.base, d ongupply aiad demand
ecdnomics~ BUSinesses. an~. consumers.r.e.!y on these markets and are hai~med when they
be(0me
~
gX(~ively: volatile or subject.t£extrem
e
pric.e ~iaock,s, as we ~aw with the
2007-2008 energy bubble. Inthe past ten years, S'uct{ e;cents have become Common and
federa! regulators failed to take ~issertive action to address the causes and to restore
confidence in the energy, futures ..markets.
By.~sttengdieiii~gand.passin~ this propose.d rulemaking, the Commission has an
opportunity io }ake an important step in this regard. It will be addressing the main
cause of.recent,market instability-excessii)e SPeculation.. Financial inv, estors, including
banks, tiedge-funds and index funds, speculate in the erlgr'gy. C~min0di[i~s markets for
profit, rather ,than commodity-related businesses and users, ~ho a0 S6 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 cla~s.,£,.f ;p..e,culator should not be ~lloWed'to take 'alarge, controlling position in any
" gl "
"t'y '
~'''~'
'"'
'!''
-::":
',,' '
" ~. .... " " "
am e commodl .
, '- '."
, ~
., ..~ . ;,:...:,::: ,., ,:. :.,,.
.
: "- :,'~,
.'," ',',7 ':i," , , ......
~ -
SALES &.SERVICE '
' ' '" ' ........ *'
!iNSTAhLAT|ON
PETROLEUM PRODUCTS
Residential ~ ~n~ne}~i}~l
<~'
' ",! '::: , .' :::" . ,O.il.& G.as ~,e,atin@~. Hea~.Pumps:.., .; ,....
.,,
Heating Fuel
Maintenande~gr~errlent~ -<,-., ' . Cer!tral Air, C.onditionjng* .A.tti¢ Fans aAi# Pu¢ifidati0n ....... '":" ' '" OffR0'ad
Diesel
NJ Lic: 13VH01444000 ...... ::
.........
H,u,m~d~fi¢at!
0n ~
Energy Sawng Controls. '.-' .... , .: .... . .,: ;Kerosene
Find uson:the interriet: 'Www.mcservice.com.. E-,rnail ~s: [email protected]
COIMMENT
CL-02676
The Commission has a statutory obligation, if not compelling moral obligation to
establish hard limits on the size of positions that speculators can take in these markets,
and to bar them from exemptions. The rule that has been proposed is not perfect, and
again, I strongly urge the technical improvements suggested by my comments.
In considering the .rule, Commissioners must look past the opposition by the financial
community and remember the affect that excessive speculation has on businesses like
mine, my consumers and the broader economy. It should establish restrictive
speculative position limits, and implement them expeditiously, before we see a repeat of
the 2007-2008 energy bubble and another major shock to a country still recovering from
recession
Respectfully yours,
..The Service Company
Donald J. McAllister
President
Enc: 1
DJM/dv
