Comment Text:
As a petroleum marketer and retailer with 350 employees, I am writing to voice my support for immediate adoption of proposed rule (RIN 3038–AD15 and 3038–AD16 Position Limits for Derivatives).
After years of highly volatile commodity markets, the CFTC is finally poised to impose position limits for physical commodities. Dozens of studies by industry experts, economists, academics, and committees in Congress, as well as direct comments to CFTC thru prior rulemaking initiatives and working groups serve only to reinforce the need for meaningful position limits in the commodity markets and therefore adoption of this rule.
I am convinced that excessive speculation in the heating oil market is the number one cause of the number one problem for Maine heating oil dealers and our customers – high prices.
Title VII of the Wall Street Reform Act has acknowledged the potential harm of excessive speculation and has reaffirmed the importance of position limits by providing the Commission with new authorities to impose such limits on currently unregulated markets. I believe the Commission understands its responsibility under existing law to prevent excessive speculation as an undue and unnecessary burden on interstate commerce.
Commodities are vital resources to American industries, businesses and consumers. Well functioning markets are critical to commodity price discovery. Position limits, as proposed in this rule, will play a critical role in reestablishing market fundamentals. I urge adoption of this rule.
I thank you for your consideration,
Sincerely,
Doug Morrell
VP Energy
Downeast Energy
18 Spring St, Brunswick, ME 04011
