202-898;1164 '• American Bakers Assoc 02:41:12 p,m, 12-14-2007 2 /3 

American Bakers Association 

Seruing the Baking lndustly Since 1897 

Lee Sanders, Senior Vice President, G011eT11ment Relations & Public Affairs lsanders~merica 11bakers. org ....., '··~) 

Mr. David Stawick 

Secretary 

Commodity Futures Trading Commission 

Three Lafayette Centre, 1155 21 51 St., NW 

Washington, D.C. 20581 

December 14, 2007 

COMMENT 

REQUEST FOR EXTENSION OF COMMENT PERIOD 

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~~~ The undersigned submits tllis request on behalf of the American Bakers Association ("ABA") to ~~ fJ. ~ extend the comment period for the following matter. 0 Q., 

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sa A. Rulemaking Involved 

ABA requests an extension of the comment period for the proposed ''Revision of Federal Speculative 

Position Limits", Federal Register, November 21, 2007; Page 65483. 

B. Action Requested 

ABA requests that Commodity Futures Trading Commission ("CFTC") extend the comment period in 

this matter by 30 days from Friday, December 21, 2007. 

C Statement ofGroundr 

For over 100 years, ABA has represented the interests ofthe wholesale baking industry and its 

suppliers-- companies that work to provide over 80 percent of the wholesome and nutritious bakery 

products purchased by American consumers, including enriched and whole grain products. ABA 

appreciates the opportunity to provide comments to CFTC on this important issue. ABA members have 

substantial experience and expertise regarding speculative position limits and we expect to submit 

detailed comments to share with CFTC insights gained from its members' real-world purchase and 

dealings in the grain futures market. However, the currently-proposed December 21, 2007, deadline for 

comments greatly hampers the ability of ABA and other stakeholders to provide the commission with 

valuable comments. 

ABA generally coordinates and organizes comments among its member companies in order to provide 

CFTC with a consolidated and well-organized document that efficiently conveys the input of the baking 

industry as a whole. Because the current comment period is for a short period (30 days), however, it 

will be challenging to effectively coordinate industry comments before the December 21 deadline. 
202-898-1164 American Bakers Assoc. 

American Bakers Association 

Request to Extend Comment Period 

Page2 

02:41:27p.m. 12-14-2007 

Moreover, given the breadth and depth of the possible impact to the futures markets, and by extension 

the wholesale baking industry, a 30-day comment period is too short for interested stakeholders to digest 

then gather and prepare for submission the data and information they may have to respond to CFTC's 

proposed rule. The need for meaningful stakeholder comment is particularly important in this context as 

CFTC considers potential revisions to its approach of futures limits. 

ABA recognizes the importance of providing stakeholder comments at this stage of CFTC rule 

formation. Given the breadth and importance of this issue, ABA requests that CFTC extend the 

conunent period by 30 days so that the Commission may benefit from well-developed and considered 

comments of interested stakeholders with relevant expertise before taking further steps in the 

rulemaking process. · 

ABA asks further that CFTC consider this request for an extension promptly, and announce an 

extension decision in advance of the currently-proposed deadline, so that interested stakeholders have 

adequate time to formulate comments that will be most valuable to the Commission. 

Respectfully submitted, 

of-!d~ Lee Sanders 

Senior Vice President 

Govenm1ent Relations & Public Affairs 

Corporate Secretary 

American Bakers Association 

1300 I Street, N.W. 

Suite 700 West 

Washington, D.C. 20005-3314 

Phone: 202-789-0300 

1300 I Street, NW, Suite 700 West • Washington, DC 20005 

Phone 202-789-0300 • Fax 202-898-1164 • lsanders@americanbakers.org 

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