Comment on CFTC-2026-0331, CFTC-2026-0331-0001, JohnPaul, Sleiman

I am JohnPaul Sleiman, a PhD candidate in Geophysics at the University of Rochester. I study how climate drives landscape change, including permafrost deformation, solifluction, and terrain evolution, using remote sensing, numerical modeling, and laboratory experiments. I submit this comment in response to Question 10 of the Commission's Advance Notice of Proposed Rulemaking on Prediction Markets (RIN 3038-AF65). The Commission asks what role event contracts play in discovering prices and disseminating pricing information under CEA 3(a). I want to put a practical case in front of the Commission that may not come up in many other comments. I can very well use prediction markets to help figure out where to point my research. My work runs on timelines measured in years. I have to decide now which environmental processes to model, which datasets to build, and which hazard scenarios to prioritize, while the climate, the policy landscape, and the funding environment around me are all moving. Prediction markets that pull together informed judgment about future outcomes, whether that is Arctic permafrost conditions, federal science funding levels, or the probability of specific policy actions, give me something I cannot get anywhere else. They give me a structured, continuously updated read on how things might play out. That is not abstract. When I am deciding whether to spend the next six months building a new dataset or pivot to a question where conditions look more favorable, those signals matter. I also work as an AGU Local Science Partner. I have sat in congressional offices and advocating for science funding. That work taught me how much uncertainty the research community operates under when it comes to the policy side of our jobs. Better probabilistic information about legislative and appropriations outcomes would be a planning tool for researchers, not a trading instrument. The "disseminating pricing information" function in 3(a) should cover that kind of informational value, not just commercial price signals tied to commodity markets. The Commission should recognize that commercial prediction platforms and nonprofit research markets do different things. The value I am describing depends on markets built to maximize forecast accuracy and public access, not trading volume. A single regulatory framework that does not distinguish between these two categories risks breaking the research utility that nonprofit markets are built to provide.