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Comment for Proposed Rule 76 FR 4752

  • From: Alan R Dorr
    Organization(s):
    Dead River Company

    Comment No: 31592
    Date: 3/11/2011

    Comment Text:

    My name is Alan Dorr and I am the Director of Hedging and Procurement for Dead River Company, a large retailer of petroleum products in Maine, New Hampshire, Vermont, and Massachusetts. I am writing you make sure that you are aware of the devastating impact that petroleum commodities volatility and high prices have on our industry. Not only does this market condition do serious harm to the profitability of Dead River Company, it is disastrous for our customers who need to drive to work and heat their homes.

    Escalating energy costs are impossible to avoid. If coffee or cheese or orange juice futures go crazy, the consumer can choose to avoid those products until the market corrects. The same is not true for energy. People must drive to work, heat their homes, and buy food that now costs extra to transport to market.

    Simply put, the energy markets are broken. They have detached from the fundamentals of supply and demand. It is the ultimate reallocation of wealth when relatively few speculative investors can drive up product costs for virtually every person in the world. These speculators need to be driven out of the energy markets so that companies like Dead River Company, who is trading for legitimate reasons, can provide reliable, reasonably priced energy for its residential customers and to fuel commercial interests that stimulate the economy.

    Too many times major investment houses have come out with their predictions on the future price of petroleum prices only to have the market fulfill their directive and surge upward. These "opinions" essentially have the result of driving up costs for all of us. Giving price guidance on energy prices is not the same as giving your opinion of a particular stock price: if the price of Microsoft surges because of your prediction it does not have devasting impact to the common man and the economy as a whole.

    As a petroleum marketer and retailer, I am writing to voice my support for immediate adoption of proposed rule (RIN 3038–AD15 and 3038–AD16 Position Limits for Derivatives).

    As I am responsible for both the hedging activities as well as product procurement for my company, I experience the daily (and sometimes hourly) angst of this market volatility and I urge you to help curb the rampant speculation that currently exists in the energy sector.

    I am available any time for any particular questions or inquiries on this topic. Thank you for your time.

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