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Comment for Proposed Rule 75 FR 4143

  • From: Dan Averill
    Organization(s):
    Reisner Distributor Inc

    Comment No: 11706
    Date: 4/13/2010

    Comment Text:

    O, F. T. O.
    OFFIOE'OF THE SEORETARIAT
    10-002
    COMMENT
    CL-02706
    April 13, 2010
    David.Stawick, Secretary
    U.S. Commodity Futures Trading Commission
    Three Lafayette Centre
    1155 21
    St
    Street, NW
    Washington, D.C. 20581
    COtVtlVIENT
    Subject:
    Comments on Proposed Speculative Position Limits for Energy (File #10-002)
    Dear Mr. Stawick:
    My name is Dan Averill and I am vice president of Reisner Distributor, a "family-owned" petroleum
    marketer serving northwest Washington since 1968.
    I am writing today to endorsecomments submitted by the Petroleum Marketers Association of
    America and the New England Fuel Institute submitted on April 9, 2010 on the proposed rule to
    implement speculative position limits for futures and options contracts for natural gas, crude oil,
    heating oil and gasoline. I am also writing to add my own thoughts on this matter to the public
    record.
    Futures markets were designed as a tool for
    bona fide
    commercial businesses and end-users to
    manage risk and "discover" prices for energy based on supply and demand economics.
    Businesses and consumers .rely on these markets and are harmed when they become excessively
    volatile or subject to extreme price shocks, as we saw with the 2007-2008 energy bubble. In the
    past ten years, such events-have become common and federal regulators failed to take assertive.
    action to address the causes and to restore confidence in the energy futures markets.
    .By strengthening and passing this proposed rulemaking, the Commission has an opportunity to take
    an important @tep in this regard. It will be addressing the main cause of recent market instability -
    excessive speculation.
    Financial investors, including banks, hedge funds and index funds,
    speculate in the energy commodities markets for profit, rather than commodity-related businesses
    and users, whodo so to protect themselves from volatility and risk. Speculators take on the dsk
    that hedgers seek to shed, however speculation should not dominate the markets. Moreover, one '
    speculator or class of speculator should not be allowed to take a large, controlling position in any a
    single commodity..
    The Commission has a statutory obligation, if not a Compelling moral obligation, to establish hard
    limits on .the
    size
    of positions that speculators can take in these markets, and to bar them from any
    exemptions, The rule that has been proposed is not perfect, and again, I strongly urge the technical
    improvements suggested by the comments I have written to endorse.
    310 Commercial Avenue ¯ Anacortes, WA 98221
    (360) 293-2197 PHONE
    "
    (360) 293-4108 FAX
    Serving Western Washington Since 1998
    1922 Front Street o Lynden, WA 98264
    (360) 354-2169 PHONE o (360) 354-4768 FAX
    www.reisnerdistributor.com
    500 Kentucky Street ° Bellingham, WA 98225
    (360) 734-8800 PHONE ~ (360) 676-6250 FAX10-002
    COMMENT
    CL-02706
    remember the attect tr]at excessive speculation has on businesses like m~ne, my consumers and
    the broader economy. It should establish restrictive speculative position limits, and implement them
    expeditiously, before we see a repeat of the 2007-2008energy bubble and another major Shock to
    a country still recovering from recession.
    Thank you for your consideration.
    Sincerely,
    Dan Averill
    Vice President
    Reisner Distributor, Inc.
    310 Commercial Avenue
    PO BOX 409
    ~nacortes. WA 98221
    (360) 293-2197 PHONE
    (360) 293-4108 FAX