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Comment for Proposed Rule 76 FR 4752

  • From: Milton S Dillon III
    Organization(s):
    Milton S Dillon III

    Comment No: 33974
    Date: 3/29/2011

    Comment Text:

    I am Milton Dillon. I am a retired Coast Guard officer. My expertise is in the marine safety field, including oil pollution prevention, regulation and enforcement, both domestically and internationally.

    I urge you to curb excessive gambling in commodities markets like food and oil.

    While many factors contribute to today’s highly volatile commodity prices, it is clear that excessive speculation is partially responsible, as shown in dozens of studies by respected institutions such as Princeton, MIT, Petersen Institute, University of London, Yale, the United Nations and the U.S. Senate.

    Speculation thus imposes financial hardships on families around the country. Sudden rises in gas and food prices force us to make difficult decisions and sacrifices. Especially right now, with so many families struggling, and unemployment barely beginning to decrease, we cannot allow speculators to unduly affect our food and gas prices.

    There are other far reaching issues that these financial hardships effect. Starting with the mistaken belief that exploration and production of oil and gas (and coal) within the US and nearby offshore areas will improve fuel prices, the public is driven by fear to support big oil (and coal) in its dismissive attitude toward environmental concerns.

    Because of my professional expertise, I was deeply troubled by the Deepwater Horizon incident last year. In light of recent findings, I am even more troubled by the decision to move forward on permits for more deep water drilling permits. This concern is not driven by a love of nature, but a stark understanding of the cause and effect of oil pollution on the marine environment and the diminishing marine food chain upon which the world relies. Further, the use of fossil fuels is a major contributor to Climate Change which is already causing significant negative global impacts.

    In short, irresponsible gambling in the commodities market leads to wild fluctuations in the price of fuels; this leads to financial fears on the part of the public; this leads to irresponsible decisions regarding the need for oil over environmental considerations; this puts our marine food chain (in particular) at high risk; this also makes it more difficult to shift from fossil fuels to renewable energy, which makes addressing climate change even more difficult and costly.

    Please put in place effective position limits rules, and do not allow them to be undermined by exemptions or exceptions, or allow Wall Street gamblers to escape them.

    Please remember that the recent financial crisis was a direct result of insufficient regulation of Wall Street, of its gambling with other people's money for their profit, and irrespective of the profit of their investors.

    Learn from that knowledge, don't repeat the mistake of insufficient effective regulation.

    Thank you for your consideration.

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