Ice

June 21, 2023
VIA CFTC PORTAL

Assistant Secretary of the Commission

FOIA, Privacy and Sunshine Acts Compliance
U.S. Commodity Futures Trading Commission
Three Lafayette Centre

1155 21st Street NW

Washington, DC 20581

Re: Freedom of Information Act Confidential Treatment Request - Amendments to the
ICE NGX Canada Inc. (“ICE NGX”) Risk Management Framework

Dear Sir or Madam:

ICE NGX Canada Inc. (“ICE NGX”) today submitted, via the CFTC Portal, the self-certification,
pursuant to Section 5c(c)(1) of the Commodity Exchange Act (“CEA”) and Commission Regulation
40.6(a), of certain amendments (the “Amendments”) to the ICE NGX Risk Management
Framework (“RMF”), with the subject line Amendment to ICE NGX Canada Inc. Rules. ICE NGX
respectfully requests confidential treatment for the information attached to the submission as
further described below until further notice.

Under the Freedom of Information Act (“FOIA”), 5 USC Section 552, Section 809(g) of the Dodd-
Frank Wall Street Reform and Consumer Protection Act and pursuant to Commission Regulation
145.9(d)(5) and any other applicable regulations under or implementing FOIA, ICE NGX hereby
respectfully requests that confidential treatment be maintained until further notice for the
documents titled “Confidential Description of Amendments to ICE NGX Canada Inc. Risk
Management Framework”. As prescribed by 17 C.F.R. 145.9(d)(4), each page of the documents
included in this request bears the legend “Confidential Treatment Requested by ICE NGX Canada
Inc.”

The basis for this request is that these documents contain sensitive commercial and proprietary
information, public disclosure of which could have a material adverse effect on, and cause injury
to, the operations and competitive position of ICE NGX and/or to its Contracting Parties. In
addition, certain of this information could constitute material undisclosed information under
Canadian securities laws. We request that you do not provide this information to anyone else or
trade on this information until the information is no longer confidential. This request is not to be
construed as a waiver of any other protection from disclosure or confidential treatment accorded
by law, and ICE NGX will rely on and invoke any such confidentiality protection.

ICE NGX requests that it be notified in the event the Commission intends to disclose such
documents to any person, including to Congress or to any other governmental agency or unit
pursuant to Section 8 of the CEA or other applicable law. ICE NGX does not waive its notification
rights under Section 8(f) of the CEA or other applicable law with respect to any subpoena or
summons for such documents.

ICE NGX Canada Inc.

Suite 2610, 225 — 6" Avenue SW

Calgary, AB

Canada T2P 1N2

ngx.com

ice.com


Ice

In accordance with the foregoing regulations, kindly notify me (403-974-1740 or
martin.mcgregor@ice.com) or Greg Abbott, ICE NGX President & COO (403-974-1701 or
greg.abbott@ice.com) of any request under FOIA for access to such documents to enable ICE
NGxX to substantiate the grounds for confidential treatment, or if you have any questions regarding
this document.

Yours truly,

a

Martin McGregor
General Counsel & CCO

ICE NGX Canada Inc.
Suite 2610, 225 — 6" Avenue SW
Calgary, AB
Canada T2P 1N2
ngx.com
ice.com