55 East 52nd Street

New York, New York 10055

Submission No. 23-102

June 22, 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: New Washington Carbon Allowance Vintage 2025 Future and Related Amendments (1 of 2)

Submission Pursuant to Section 5c(c)(1) of the Act and Regulation 40.2 

Dear Mr. Kirkpatrick:

Pursuant to Section 5c(c)(1) of the Commodity Exchange Act, as amended (the “CEA”), and Commission 

Regulations 40.2, ICE Futures U.S., Inc. (“Exchange”) submits, by written certification, amendments to 

Exchange Rule 18.D.068 and Resolutions 1 and 2 of Chapters 18. The amendments provide for two new 

futures contracts, which will be listed on or about July 10, 2023, or such other date as the Exchange shall 

determine which shall be no sooner than the second business day following the business day on which this 

submission is received by the Commission.

Physical Environmental Futures Contracts

a. Washington Carbon Allowance Vintage 2024 and 2025 Futures

Washington Carbon Allowance (“WCA”) futures contracts are physically-delivered carbon emission 

allowance futures contracts. The Exchange currently lists WCA futures contracts for the 2023 and 2024 

vintage-years. The term “vintage” identifies the compliance year for which an allowance is designated. The 

contracts call for delivery of WCAs, which are issued by the Washington Department of Ecology and 

represent one metric ton of CO2 equivalent under Chapter 173-446 WAC of the Climate Commitment Act 

and its associated regulations, rules, and amendments, all together known as the “Washington Cap and 

Invest Program.” The deliverable instruments for the new futures contracts are WCA equal to the contract 

size issued as a limited authorization to emit up to one metric ton of CO2 or CO2-equivalent in the 

Washington Cap and Invest Program and have a vintage corresponding to the calendar year of the expiring 

contract or allowances having a vintage of any year prior to the calendar year of the expiring contract. The 

contract specifications of the new Vintage 2025 (WCC) and Vintage 2026 (WCD) futures contracts will be 

identical to the WCA Vintage 2024 (WCB) futures currently listed by the Exchange, which prescribe that 

the contract will cease trading three business days prior to the last business day of the delivery month, at 

which time the contract will settle based on physical delivery of the underlying allowances through the 

Washington Compliance Instrument Tracking System Services (“CITSS”) Registry. If the specified vintage 

year allowances do not exist in Washington CITSS Registry at contract expiry, allowances of any prior 

vintage year or allowances of the earliest vintage year available in the Washington CITSS Registry shall be 

delivered. The last weekend of December is not considered a business day, unless otherwise specified by 

the Exchange. Amendments to Exchange Rule 18.D.068 add the 2025 and 2026 vintage-years to the suite 

of existing WCA futures.
The contract sizes, minimum price fluctuations, Interval Price Limits (IPLs) and IPL recalculation times, 

where applicable, No-Cancellation Ranges (NCRs), spot month position limits and single and all month 

accountability levels are provided in relevant documents attached as Exhibit A. All relevant terms of the 

aforementioned Physical Environmental futures contracts are similar to other Physical Environmental 

futures contracts listed by the Exchange. The listing cycle and other relevant specifications are provided in 

the contract specifications in Exhibit A. Each of the new contracts are block eligible. The minimum block 

trade sizes have been set consistent with existing Physical Environmental contracts. Amendments to 

Exchange Rule 18.D.068 list the 2025 and 2026 vintage-years of the new futures contracts. The Exchange

has set spot month position limits and single and all-months-combined accountability levels for WCC and 

WCD at levels identical to those of existing WCA contracts currently listed by the Exchange. Additionally, 

it is the Exchange’s good faith belief that none of the contracts meet the definition of referenced contract

as prescribed in CFTC §150.1.1

Certifications

The rules and amendments establishing the new futures contracts’ terms and conditions are to become 

effective on the second business day following the business day on which this submission is received by 

the Commission. The Exchange is not aware of any substantive opposing views to the new futures contracts. 

The Exchange certifies that the rule amendments comply with the requirements of the Act and the rules and 

regulations promulgated thereunder. The Exchange has reviewed the designated contract market core 

principles ("Core Principles") as set forth in the Act and has determined that the listing of the contracts 

complies with the following relevant Core Principles: 

COMPLIANCE WITH RULES

The terms and conditions of the new futures contracts are set forth in amendments to Rule 18.D.068

and amendments to Resolutions 1 and 2 of Chapter 18, and will be enforced by the Exchange. In 

addition, trading of the contracts is subject to all relevant Exchange rules which are enforced by 

the Market Regulation Department. 

CONTRACTS NOT READILY SUBJECT TO MANIPULATION

The new futures contracts are not readily subject to manipulation as they are based on established 

and liquid underlying cash markets. In addition, trading of the new contracts will be monitored by 

the Market Regulation Department. 

POSITION LIMITS OR ACCOUNTABILITY

Positions in the new futures contracts will be subject to position limits and accountability levels set 

by the Exchange. As described above, such position limits are based upon existing levels set for 

substantially similar products at the Exchange or another designated contract market.

FINANCIAL INTEGRITY OF CONTRACTS

The new futures contracts will 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 is not aware of any opposing views expressed by members or others regarding the listing of 

the new futures contracts and the adoption of related amendments. The Exchange further certifies that 

concurrent with this filing a copy of this submission was posted on the Exchange’s website, which may be 

accessed at: (https://www.theice.com/futures-us/regulation#rule-filings).

If you have any questions or need further information, please contact the undersigned at 

patrick.swartzer@theice.com. 

1 17 C.F.R. § 150.1 (October 15, 2020) (providing for referenced contract definition).
Sincerely,

Patrick Swartzer

Director

Market Regulation

Enc.

cc: Division of Market Oversight

New York Regional Office
EXHIBIT A

Rule Contract Name 

Commodity 

Code

Contract 

Size

Unit of 

Trading

Minimum 

Tick [1]

IPL 

Amount

IPL 

Recalc 

Time 

(Seconds)

IPL Hold 

Period 

(Seconds) NCR

18.D.068 Washington Carbon Allowance Vintage 2025 Future WCC 1,000 Allowances 0.01 2.50 3 5 0.25

18.D.068 Washington Carbon Allowance Vintage 2026 Future WCD 1,000 Allowances 0.01 2.50 3 5 0.25

[1] The minimum fluctuation for the above futures contracts may differ depending on trade type and market.
Resolution No. 1 - Minimum Price Fluctuation Table

The following minimum price fluctuations shall be applicable to Energy Contracts.

Rule Number Product

Minimum Price 

Fluctuations

Screen

Blocks and 

other trades 

outside the 

central limit 

order book

* * *

18.D.068 Washington Carbon Allowance Vintage 2025 Future 0.01 0.01

18.D.068 Washington Carbon Allowance Vintage 2026 Future 0.01 0.01

* * *
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

CFTC 

Referenced 

Contract

18.D.068 Washington Carbon Allowance Vintage 2025 Future WCC 1,000 Allowances 10,000 10,000 10,000 WCC 25 N

18.D.068 Washington Carbon Allowance Vintage 2026 Future WCD 1,000 Allowances 10,000 10,000 10,000 WCD 25 N
7

Subchapter 18D – Physical Environmental

Futures Contracts

Rule Subject

* * *

18.D.068 Washington Carbon Allowance Future Vintage 2024 [Future] and After

* * *
8

18.D.068 Washington Carbon Allowance Future Vintage 2024 [Future] and After

Contract Description: Physically delivered greenhouse gas emissions allowances where each is an allowance 

issued by the Washington Department of Ecology (“Washington Carbon Allowance”) representing one metric ton of 

CO2 equivalent under Chapter 173-446 WAC of the Climate Commitment Act and its associated regulations, rules 

and amendments, all together known as the "Washington Cap and Invest Program".

Contract Symbol: WCB: Vintage 2024; WCC: Vintage 2025; WCD: Vintage 2026

Settlement Method: Physical Delivery

Contract Size: 1,000 Washington Carbon Allowances

Currency: USD

Minimum Price Fluctuation: The price quotation convention shall be One cent ($0.01) per Allowance; minimum 

price fluctuation may vary by trade type. Please see Table in Resolution 1 to this Chapter 18.

Listing Cycle: 1. The Exchange may list monthly contracts in the Standard Cycle or any other calendar month it 

determines for the current year and forward for up to ten years.

2. The Standard Cycle is: January, February, March, April, May, June, July, August, September, 

October, November and December

Last Trading Day: Three Business Days prior to the last Business Day of the delivery month. The last weekday of 

December is not considered a Business Day, unless otherwise specified by the Exchange.

Deliverable Instruments: The deliverable instruments are Washington Carbon Allowances equal to the contract 

size delivered through the Compliance Instrument Tracking System Service (“CITSS”). 

Washington Carbon Allowances acceptable for delivery are those issued as a limited authorization to emit up to one 

metric ton of CO2 or CO2 equivalent in the Washington Cap and Invest Program having a vintage corresponding to 

the calendar year of the expiring contract and allowances having a vintage of any year prior to the calendar year of 

the expiring contract. If the specified vintage year allowances do not exist in the Washington CITSS Registry at 

contract expiry, allowances of any prior vintage year or allowances of the earliest vintage year available in the 

Washington CITSS Registry shall be delivered.

MIC Code: IFED

Clearing Venue: ICEU

Registry: Washington CITSS Registry

[REMAINDER OF RULEBOOK UNCHANGED]