55 East 52nd Street

New York, NY 10055

BY ELECTRONIC TRANSMISSION

Submission No. 23-133

October 5, 2023

Mr. Christopher J. Kirkpatrick

Secretary of the Commission

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

Re: Amendments to Resolution No. 2 of Chapter 18 and Related Amendments -

Submission Pursuant to Section 5c(c)(1) of the Act and Regulation 40.6(a)

Dear Mr. Kirkpatrick:

Pursuant to Commodity Futures Trading Commission (“CFTC” or “Commission”) 

Regulation 40.6(a), ICE Futures U.S., Inc. (“Exchange”) hereby certifies amendments to 

Resolution No. 2 of Chapter 18 of the Exchange’s Rulebook, as set forth in Exhibit A.

The amendments to Resolution No. 2 of Chapter 18 increase spot month position limits for 

four Financial Power futures contracts, NYISO Zone C Day-Ahead LBMP Off-Peak Daily Fixed 

Price Future (“NCO”), NYISO Zone C Day-Ahead Off-Peak Fixed Price Future (“ZCD”), NYISO 

Zone C Day-Ahead LBMP Peak Daily Fixed Price Future (“NCP”), and the NYISO Zone C DayAhead Peak Fixed Price Future (“ZCB”), based on revised estimates of deliverable supply at the 

pricing zone. The applicable contracts are not referenced contracts as that term is defined in CFTC 

Regulation 150.1. The amended spot month position limits will be increased to levels consistent

with CFTC Regulation 150.5(b), which allows for exchange-set spot month position limits for 

derivative contracts not subject to CFTC Regulation 150.2 at levels no greater than 25 percent of 

the estimated spot month deliverable supply. The revised levels are consistent with such 

requirement and are based on the deliverable supply of electricity in the NYISO Zone C pricing 

zone. The contracts and amended levels are listed in Exhibit A. An analysis describing the 

methodology used to derive the revised spot month position limits is provided as Exhibit B.
Corresponding amendments increase the single and all-months-combined accountability 

levels for the four Financial Power products. The amended levels are equivalent to the revised spot 

month position limit for the applicable product, consistent with CFTC Regulation 150.5(b)(2).

The Exchange will implement the spot month position limit, and single and all-monthscombined accountability amendments effective for the November 2023 spot month position limit 

period, beginning November 1, 2023. The amendments will be effective for all expiration months, 

including those with open interest.

Certifications

The Exchange certifies that the amendments to the spot month position limits and single 

and all-months-combined accountability levels comply with the requirements of the Act and the 

rules and regulations promulgated thereunder. The Exchange is not aware of any opposing views 

with respect to the spot month position limit or and single and all-months-combined accountability 

levels increases. The Exchange has reviewed the designated contract market core principles 

("Core Principles") as set forth in the Act and has determined that the amendments comply with 

the following relevant Core Principles:

COMPLIANCE WITH RULES

The amended spot month position limits and single and all-months-combined 

accountability levels for the four Financial Power futures contracts are set forth in 

Resolution No. 2 of Chapter 18 and will be enforced by the Exchange. In addition, trading 

of these contractsis subject to all relevant Exchange rules which are enforced by the Market 

Regulation Department.

CONTRACTS NOT READILY SUBJECT TO MANIPULATION

The Exchange’s Financial Power futures contracts are not readily subject to manipulation 

as they are based on established and liquid underlying cash markets and derivative 

contracts traded at other designated contract markets. In addition, trading of the contracts

will be monitored by the Market Regulation Department.

POSITION LIMITS OR ACCOUNTABILITY

Positions in the four Financial Power futures contracts will continue to be subject to 

position limits and accountability levels set by the Exchange. Such position limits are 

based upon the deliverable supply at the pricing zone.

FINANCIAL INTEGRITY OF CONTRACTS

The four Financial Power futures contracts contract will continue to be cleared by ICE 

Clear Europe, a registered derivatives clearing organization subject to Commission 

regulation, and carried by registered futures commission merchants qualified to handle 

customer business.

The Exchange further certifies that, concurrent with this filing, a copy of this submission 

was posted on the Exchange’s website. It may be accessed at: https://www.theice.com/futuresus/regulation. If you have any questions or need further information, please contact the 

undersigned at 312-836-6745 or at . 
Sincerely,

Patrick Swartzer

Director

Market Regulation

Enc.

cc: Division of Market Oversight

New York Regional Office
EXHIBIT A

Resolution No. 2 – Position Limit/Accountability Table

Rule Contract Name Commodity 

Code

Contract 

Size

Unit of 

Trading

Spot Month 

Limit

Single Month 

Accountability 

Level

All Month 

Accountability 

Level

Aggregate 1 

(Positive 

Correlation)

Aggregate 2 

(Negative 

Correlation)

Exchange 

Reportable 

Level

18.B.199

NYISO Zone C Day-Ahead 

LBMP Off-Peak Daily Fixed 

Price Future

NCO 50 MWh [4,500] 14,040 [7,500] 14,040 [10,500] 14,040 ZCD 1

18.B.091 NYISO Zone C Day-Ahead 

Off-Peak Fixed Price Future ZCD 1 MW [589] 1,800 [962] 1,800 [1,282] 1,800 ZCD 1

18.B.198

NYISO Zone C Day-Ahead 

LBMP Peak Daily Fixed Price 

Future

NCP 800 MWh [330] 756 [500] 756 [700] 756 ZCB 1

18.B.033 NYISO Zone C Day-Ahead 

Peak Fixed Price Future ZCB 1 MW [786] 1,800 [1,190] 1,800 [1,667] 1,800 ZCB 1
EXHIBIT B

[REDACTED]