EI Principal John R. Morris submits comments to the Commodity Futures Trading Commission.

On October 9, 20, and 22, 2009 the Commodity Futures Trading Commission (CFTC) issued Notices of Intent to determine whether 15 natural gas financial basis contracts traded on the Intercontinental Exchange (ICE) are Significant Price Discovery Contracts (SPDCs). On October 26, 2009, EI Principal John R. Morris filed comments with the CFTC based upon his 20 years studying the natural gas industry and his extensive experience studying natural gas transaction data from ICE. Dr. Morris showed that actual transaction data indicate that the contracts do not meet CFTC standards for SPDCs.