HPC and trade[XYZ] filed a joint comment letter with the CFTC yesterday asking the Commission to open a regulated path for energy perpetual contracts. The setup: → A hedger holding WTI exposure has to close the expiring contract and open the next one, every single month → The roll spread is not a fixed cost, it moves hour to hour → CME closes over the weekend, so the window to actually do it is narrower than the calendar suggests → Large participants have to telegraph the trade, which moves the price against them inside that window What the chart shows: → Rolling a $10m position on Monday April 13 at 02:00 UTC cost roughly $945,000 → The identical roll on Friday April 17 at 20:00 UTC cost roughly $109,000 → Same mandatory trade, four days apart, $835,912 apart in cost → Crossing the spread either way cost about $2,500 So the timing of the roll was worth roughly three hundred times the execution of it. That cost never shows up in a fee schedule, never gets quoted as a spread, and is not something a hedger can plan around, because the number is only knowable after the fact. It is the cleanest empirical answer to the question of why anyone would want a contract that never expires: a perpetual position has no roll window to mistime.