Clearly, the CFTC is having difficulty fitting commercial hedging practices and the long-standing hedging exemption for grain markets into its proposed new regimen of position limits.Since "excessive speculation" (never defined) in derivative markets was fingered as a root cause of the 2008 commodity market crash, the financial market crisis and the ensuing Great Recession of 2009, the congressional composers of the massive Dodd-Frank financial market reform legislation of 2010 wanted to be seen as addressing this problem. Thus, language was included in Dodd-Frank that seemed to encourage, if not actually require, the Commodity Futures Trading Commission (CFTC) to establish limits on the size of positions that noncommercial speculators coul...