SUBMISSION COVER SHEET

IMPORTANT: Check box if Confidential Treatment is requested 

Registered Entity Identifier Code (optional): 23-270

Organization: New York Mercantile Exchange, Inc. ("NYMEX")

Filing as a: DCM SEF DCO SDR 

Please note - only ONE choice allowed.

Filing Date (mm/dd/yy: 12/21/23 Filing Description: Initial Listing of the NY Harbor ITT 

Ethanol (Platts) Futures Contract

SPECIFY FILING TYPE 

Please note only ONE choice allowed per Submission.

Organization Rules and Rule Amendments

Certification § 40.6(a)

Approval § 40.5(a)

Notification § 40.6(d)

Advance Notice of SIDCO Rule Change § 40.10(a)

SIDCO Emergency Rule Change § 40.10(h)

Rule Numbers: 

New Product Please note only ONE product per Submission.

Certification § 40.2(a) 

Certification Security Futures § 41.23(a)

Certification Swap Class § 40.2(d)

Approval § 40.3(a)

Approval Security Futures § 41.23(b)

Novel Derivative Product Notification § 40.12(a)

Swap Submission § 39.5

Product Terms and Conditions (product related Rules and Rule Amendments)

Certification § 40.6(a) 

Certification Made Available to Trade Determination § 40.6(a)

Certification Security Futures § 41.24(a)

Delisting (No Open Interest) § 40.6(a) 

Approval § 40.5(a)

Approval Made Available to Trade Determination § 40.5(a)

Approval Security Futures § 41.24(c)

Approval Amendments to enumerated agricultural products § 40.4(a), § 40.5(a)

“Non-Material Agricultural Rule Change” § 40.4(b)(5)

Notification § 40.6(d)

Official Name(s) of Product(s) Affected: See filing.

Rule Numbers: See filing.
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

1

Timothy Elliott

Managing Director and Chief Regulatory Counsel

Legal Department

December 21, 2023

VIA ELECTRONIC PORTAL

Mr. Christopher J. Kirkpatrick

Office of the Secretariat

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, N.W.

Washington, DC 20581

Re: CFTC Regulation 40.2(a) Certification. Initial Listing of the NY Harbor ITT Ethanol 

(Platts) Futures Contract.

NYMEX Submission No. 23-270

Dear Mr. Kirkpatrick:

New York Mercantile Exchange, Inc. (“NYMEX” or “Exchange”) is certifying to the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) the initial listing of the NY Harbor ITT Ethanol (Platts) 

Futures contract (the “Contract”) for trading on the CME Globex electronic trading platform and for 

submission for clearing via CME ClearPort effective Sunday, January 7, 2024, for trade date Monday, 

January 8, 2024.

Contract Title NY Harbor ITT Ethanol (Platts) Futures

CME Globex and

CME ClearPort Code NIE

Rulebook Chapter 570

Contract Size 42,000 gallons

Price Quotation U.S. dollars and cents per gallon

Minimum Price Fluctuation $0.0001 per gallon

Value per Tick $4.20 

Settlement Type Financial

Listing Schedule Monthly contracts listed for thirty-six (36) consecutive months

Initial Listing January 2024

Termination of Trading Trading terminates on the last business day of the contract month.

Block Trade Minimum Threshold 

and Reporting Window 5 contracts - subject to a 15-minute reporting window

CME Globex Match Algorithm FIFO

Trading and Clearing Hours

CME Globex Pre-open: Sunday 4:00 p.m. - 5:00 p.m. Central 

Time/CT Monday – Thursday 4:45 p.m. - 5:00 p.m. CT

CME Globex: Sunday 5:00 p.m. - Friday 4:00 p.m. CT with a daily 

maintenance period from 4:00 p.m. - 5:00 p.m. CT

CME ClearPort: Sunday 5:00 p.m. - Friday 4:00 p.m. CT with no 

reporting Monday - Thursday from 4:00 p.m. - 5:00 p.m. CT
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

2

The Exchange reviewed the designated contracts market core principles (“Core Principles”) as set forth in 

the Commodity Exchange Act (“CEA” or “Act”) and identified that the Contract may have some bearing on 

the following Core Principles:

• Availability of General Information: The Exchange will publish information on the Contract’s

specification on its website, together with daily trading volume, open interest and price information.

• Contracts Not Readily Subject to Manipulation: The Contract is based on a cash price series 

that is reflective of the underlying cash market and is commonly relied on and used as a reference 

price by cash market brokers and commercial market participants.

• Compliance with Rules: Trading in this Contract will be subject to Chapter 4 of the Exchange 

rules which includes prohibitions against fraudulent, non-competitive, unfair and abusive practices 

and will be subject to extensive monitoring and surveillance by the Exchange’s Market Regulation 

Department. The Market Regulation Department may use its investigatory and enforcement power 

where potential rule violations are identified during its regular surveillance reviews.

• Prevention of Market Disruption: Trading in the Contract will be subject to the Rules of NYMEX

which include prohibitions on manipulation, price distortion, and disruption to the cash settlement 

process. As with any new product listed for trading on a CME Group designated contract market, 

trading activity in the Contract proposed herein will be subject to monitoring and surveillance by the 

Exchange’s Market Regulation Department.

• Position Limitations or Accountability: The speculative position limits for the Contract as 

demonstrated in this submission are consistent with the Commission’s guidance.

• Financial Integrity of Contracts: The Contract will be cleared by the CME Clearing House which 

is a registered derivatives clearing organisation with the Commission and is subject to all 

Commission regulations related thereto.

• Execution of Transactions: The Contract will be listed for trading on the CME Globex electronic 

trading and for clearing through CME ClearPort. The CME Globex electronic trading venue provides 

for competitive and open execution of transactions. CME Globex affords the benefits of reliability 

and global connectivity.

• Trade Information: All requisite trade information for the Contract will be included in the audit trail 

and is sufficient for the Market Regulation Department to monitor for market abuse.

• Protection of Market Participants: NYMEX Rulebook Chapters 4 and 5 contain multiple 

prohibitions precluding intermediaries from disadvantaging their customers. These rules apply to 

trading on all of the Exchange’s competitive venues and will be applicable to transactions in this

Contract.

• Disciplinary Procedures: Chapter 4 of the Rulebook contains provisions that allow the Exchange 

to discipline, suspend or expel members or market participants that violate the Rulebook. Trading 

in the Contract will be subject to Chapter 4, and the Market Regulation Department has the authority 

to exercise its enforcement power in the event rule violations in this Contract are identified.

• Dispute Resolution: Disputes with respect to trading in the Contract will be subject to the 

arbitration provisions set forth in Chapter 6 of the Rulebook. Chapter 6 allows all non-members to 

submit a claim for financial losses resulting from transactions on the Exchange to arbitration. A 

member named as a respondent in a claim submitted by a non-member is required to participate 
20 S Wacker Dr Chicago, IL 60606 T 312 466 7478 tim.elliott@cmegroup.com cmegroup.com

3

in the arbitration pursuant to Chapter 6. Additionally, the Exchange requires that members resolve 

all disputes concerning transactions on the Exchange via arbitration.

• Daily Publication of Trading Information: The Exchange will publish information regarding 

trading volume, open interest and price information daily on its website and through quote vendors 

for the Contract.

Pursuant to Section 5c(c) of the Act and CFTC Regulation 40.2(a), the Exchange certifies that the Contract 

complies with the Act, including regulations under the Act. There were no substantive opposing views to 

this proposal.

The Exchange certifies that this submission has been concurrently posted on the CME Group website at 

http://www.cmegroup.com/market-regulation/rule-filings.html.

Should you have any questions concerning the above, please contact the undersigned at (312) 466-7478

or via e-mail at CMEGSubmissionInquiry@cmegroup.com.

Sincerely, 

/s/ Timothy Elliott

Managing Director and Chief Regulatory Counsel

Attachments: Exhibit A: NYMEX Rulebook Chapter 570

Exhibit B: Position Limit, Position Accountability, and Reportable Level Table in Chapter 5

 of the NYMEX Rulebook (attached under separate cover) 

Exhibit C: Exchange Fees

Exhibit D: NYMEX Rule 588.H. – (“Globex Non-Reviewable Trading Ranges”) Table

Exhibit E: Cash Market Overview and Analysis of Deliverable Supply 
4

Exhibit A

NYMEX Rulebook

Chapter 570

NY Harbor ITT Ethanol (Platts) Futures

570100. SCOPE OF CHAPTER

The provisions of these rules shall apply to all contracts bought or sold on the Exchange for cash 

settlement based on the Floating Price. The procedures for trading, clearing and cash settlement of 

this contract, and any other matters not specifically covered herein shall be governed by the general 

rules of the Exchange

570101. CONTRACT SPECIFICATIONS

The Floating Price for each contract month is equal to the arithmetic average of the high and low 

quotations from Platts for “New York Harbor Intertank Transfer (ITT) Sewaren terminal” for each 

business day that it is determined during the contract month.

570102. TRADING SPECIFICATIONS

The number of months open for trading at a given time shall be determined by the Exchange.

570102.A. Trading Schedule

The hours for trading for this contract shall be determined by the Exchange.

570102.B. Trading Unit

The contract quantity shall be 42,000 gallons. Each contract shall be valued as the contract

quantity (42,000) multiplied by the settlement price.

570102.C. Price Increments 

Prices shall be quoted in U.S. dollars and cents per gallon. The minimum price fluctuation shall be 

$0.0001 per gallon. 

570102.D. Position Limits, Exemptions, Position Accountability and Reportable Levels

The applicable position limits and/or accountability levels, in addition to the reportable levels, are set 

forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations 

& Special Notices Section of Chapter 5. A Person seeking an exemption from position limits for bona 

fide commercial purposes shall apply to the Market Regulation Department on forms provided by the 

Exchange, and the Market Regulation Department may grant qualified exemptions in its sole 

discretion. Refer to Rule 559 for requirements concerning the aggregation of positions and allowable 

exemptions from the specified position limits.

570102.E. Termination of Trading

Trading shall cease on the last business day of the contract month.

570103. FINAL SETTLEMENT

Final settlement under the contract shall be by cash settlement. The final settlement price will be the 

Floating Price calculated for each contract month.

570104. DISCLAIMER

See NYMEX/COMEX Chapter iv. (“DISCLAIMERS”) incorporated herein by reference.
5

Exhibit B

NYMEX Rulebook

Chapter 5

(“Trading Qualifications and Practices”)

Position Limits, Position Accountability and Reportable Level Table

(attached under separate cover)

 
6

Exhibit C

Exchange Fees

Member Non-Member

International 

Incentive 

Programs 

(IIP/IVIP)

CME Globex $0.85 $1.35 $1.10

EFP $0.85 $1.35

Block $0.85 $1.35

EFR/EOO $0.85 $1.35

Processing Fees Member Non-Member

Cash Settlement $0.50 $0.50

Facilitation Fee $0.60

Give-Up Surcharge $0.05

Position 

Adjustment/Position 

Transfer

$0.10
7

Exhibit D

NYMEX Rulebook

Chapter 5

 (“Trading Qualifications and Practices”)

NYMEX Rule 588.H. – (“Globex Non-Reviewable Trading Ranges”) Table

(additions underscored)

Outrights Spreads

Instrument Globex 

Symbol

Globex Non-Reviewable 

Ranges (NRR)

NRR: 

Globex 

Format

NRR:Minimum 

Ticks

NRR: 

Globex 

Format

NRR: 

Outright 

Minimum 

Ticks

NY Harbor ITT Ethanol (Platts) 

Futures NIE $0.0025 per gallon 250 250 63 63
8

Exhibit E

Cash Market Overview and Analysis of Deliverable Supply

New York Mercantile Exchange, Inc. (“NYMEX” or “Exchange”) is certifying to the Commodity Futures 

Trading Commission (“CFTC” or “Commission”) the initial listing of the NY Harbor ITT Ethanol (Platts) 

Futures contract (the “Contract”) for trading on the CME Globex electronic trading platform (“CME Globex”) 

and for submission for clearing via CME ClearPort. The Exchange conducted a review of the underlying 

cash market of ethanol and determined the key components in estimating deliverable supply to be 

inventories and inbound capacity at the Sewaren terminal that could reasonably be considered readily 

available for delivery.

Contract Title

CME Globex

and

CME ClearPort 

Code

Rulebook Chapter

NY Harbor ITT Ethanol (Platts) Futures NIE 570

METHODOLOGY & DATA SOURCES

The Exchange considered two (2) components in estimating deliverable supply:

A. Ethanol inventories at Sewaren terminal; and

B. Inbound ethanol capacity at the Sewaren terminal.

The Sewaren terminal is the sole delivery point for the Contract. The terminal has approximately 1,000,000 

barrels or 42.0 million gallons of ethanol storage capacity. However, Sewaren terminal inventories are not 

publicly available and therefore the Exchange is using the national utilization rate of U.S. PADD 1 ethanol 

storage capacity as a proxy for estimating Sewaren inventories. 

The Exchange included the Sewaren inbound capacity in the estimation of deliverable supply. Inbound 

capacity at the Sewaren terminal is non-public information and therefore was acquired through 

conversations with industry sources. Sewaren Terminal has the ability each day of the week to unload 

approximately 96 railcars per day with a capacity of 28,750 gallons/car. 

The Platts New York Harbor Intertank Transfer (ITT) methodology has a delivery period of 5-15 days 

forward.

1 Over the course of a 30-day monthly schedule, Sewaren terminal can offload 96 railcars per day 

for 30 days. The Exchange estimates that Sewaren terminal has an inbound capacity of 82.8 million gallons 

per month. Sewaren inbound capacity and inventories are utilized to derive the average monthly deliverable 

supply of ethanol.

The Exchange reached out to a cross-section of ethanol regular firms to determine if the amount of ethanol 

stocks and ethanol inbound capacity that are held under long term agreements will impact deliverable 

supply. As a result of this outreach, the Exchange determined that no long-term agreements impact the 

deliverable supply of the Contract.

1 https://www.spglobal.com/commodityinsights/PlattsContent/_assets/_files/en/our-methodology/methodologyspecifications/global_biofuels.pdf
9

The Energy Information Administration (“EIA”)

The EIA collects, analyzes, and disseminates independent and impartial energy information to promote 

sound policymaking, efficient markets, and public understanding of energy and its interaction with the 

economy and the environment.

Platts, (a division of S&P Global) (“Platts”)2

Platts is a leading global provider of energy, freight, petrochemicals, metals and agriculture information, 

and a premier source of benchmark price assessments for those commodity markets. Since 1909, Platts 

has provided information and insights that help customers make sound trading and business decisions and 

enable the markets to perform with greater transparency and efficiency

Industry Sources

The Exchange also consulted with sources to acquire business intelligence. These sources are wellestablished and reputable market participants, with whom the Exchange has had longstanding 

relationships.

ETHANOL MARKET BACKGROUND

Ethanol is a biodegradable, high-octane motor fuel derived from the sugars, starches, and cellulosic matter 

found in plants and is used by the oil industry to formulate finished gasoline products and as an oxygenate 

to reduce tailpipe emissions. 

In the United States, ethanol is primarily used as a blending component in the production of motor gasoline 

(mainly blended in volumes up to 10% ethanol, also known as E10). Corn is the primary feedstock of ethanol 

in the United States, and large corn harvests have contributed to increased ethanol production.

3

Fuel ethanol makes up for a growing fraction of overall fuel consumption in most countries. Investments 

have accelerated dramatically over the last decade, particularly in Brazil, the United States and Europe, as 

governments in these regions introduced ambitious policies and mandatory targets for renewable fuels. 

Today, the United States and Brazil together represent approximately 82% of the ethanol produced and 

consumed in the world. In the United States, the largest ethanol producer globally, ethanol accounts for 

approximately10% of the gasoline market and consumption.

45

INVENTORIES

According to EIA data, during the period of November 2020 through October 2023, U.S. PADD 1 had an 

average total ethanol working storage capacity of 531.0 million gallons. Average monthly ethanol 

inventories were at 298.9 million gallons over the same time period, representing a 56.30% utilization rate 

on average. The Sewaren terminal located in Sewaren, NJ has a total ethanol storage capacity of 42.0

million gallons. 

2 S&P Global Platts - https://www.spglobal.com/platts/en

3 https://www.eia.gov/energyexplained/biofuels/ethanol.php

4https://ethanolrfa.org/markets-and-statistics/annual-ethanol-production

5 https://www.eia.gov/tools/faqs/faq.php?id=27&t=4
10

Tables 1 and 2 below illustrate the average monthly U.S. PADD 1 ethanol storage capacity utilization rate 

and total estimated Sewaren inventories, respectively. The U.S. PADD 1 storage capacity utilization rate 

has been applied to monthly storage capacity at the Sewaren terminal. 

Table 1. U.S. PADD 1 Storage Capacity Utilization Rate6 7

(thousand gallons)

Date Monthly Stocks Working Storage 

Capacity

Utilization 

Rate

2020 Nov 267,761 535,248 50.03%

Dec 302,883 535,248 56.59%

2021

Jan 329,003 535,248 61.47%

Feb 328,577 535,248 61.39%

Mar 315,137 526,344 59.87%

Apr 296,579 526,344 56.35%

May 266,658 526,344 50.66%

Jun 275,699 526,344 52.38%

Jul 287,944 526,344 54.71%

Aug 292,950 526,344 55.66%

Sep 280,140 526,344 53.22%

Oct 252,697 526,344 48.01%

Nov 231,735 526,344 44.03%

Dec 246,893 526,344 46.91%

2022

Jan 293,685 526,344 55.80%

Feb 315,798 526,344 60.00%

Mar 336,977 534,618 63.03%

Apr 337,588 534,618 63.15%

May 307,188 534,618 57.46%

Jun 291,900 534,618 54.60%

Jul 313,656 534,618 58.67%

Aug 317,951 534,618 59.47%

Sep 304,223 534,618 56.90%

Oct 304,742 534,618 57.00%

Nov 288,824 534,618 54.02%

Dec 305,592 534,618 57.16%

2023

Jan 308,700 534,618 57.74%

Feb 336,641 534,618 62.97%

Mar 349,104 530,586 65.80%

Apr 315,116 530,586 59.39%

May 306,527 530,586 57.77%

Jun 291,934 530,586 55.02%

Jul 300,405 530,586 56.62%

Aug 296,100 530,586 55.81%

6 https://www.eia.gov/petroleum/storagecapacity/

7 https://www.eia.gov/dnav/pet/pet_sum_sndw_a_EPOOXE_sae_mbbl_w.htm 
11

Sep 287,708 530,586 54.22%

Oct 276,990 530,586 52.96%

3-year average 298,944 531,034 56.30%

Table 2. Estimated Sewaren Inventories

(gallons)

Date Sewaren Storage 

Capacity

Utilization 

Rate

Estimated Sewaren 

Inventories

2020

Nov 42,000,000 50.03% 21,010,711

Dec 42,000,000 56.59% 23,766,714

2021

Jan 42,000,000 61.47% 25,816,290

Feb 42,000,000 61.39% 25,782,839

Mar 42,000,000 59.87% 25,146,545

Apr 42,000,000 56.35% 23,665,720

May 42,000,000 50.66% 21,278,168

Jun 42,000,000 52.38% 21,999,561

Jul 42,000,000 54.71% 22,976,668

Aug 42,000,000 55.66% 23,376,157

Sep 42,000,000 53.22% 22,353,974

Oct 42,000,000 48.01% 20,164,156

Nov 42,000,000 44.03% 18,491,462

Dec 42,000,000 46.91% 19,700,989

2022

Jan 42,000,000 55.80% 23,434,807

Feb 42,000,000 60.00% 25,199,330

Mar 42,000,000 63.03% 26,473,132

Apr 42,000,000 63.15% 26,521,141

May 42,000,000 57.46% 24,132,925

Jun 42,000,000 54.60% 22,931,888

Jul 42,000,000 58.67% 24,641,056

Aug 42,000,000 59.47% 24,978,435

Sep 42,000,000 56.90% 23,899,976

Oct 42,000,000 57.00% 23,940,726

Nov 42,000,000 54.02% 22,690,196

Dec 42,000,000 57.16% 24,007,542

2023

Jan 42,000,000 57.74% 24,251,709

Feb 42,000,000 62.97% 26,446,736

Mar 42,000,000 65.80% 27,634,291

Apr 42,000,000 59.39% 24,943,838

May 42,000,000 57.77% 24,263,952
12

Jun 42,000,000 55.02% 23,108,810

Jul 42,000,000 56.62% 23,779,387

Aug 42,000,000 55.81% 23,438,613

Sep 42,000,000 54.22% 22,774,353

Oct 42,000,000 52.96% 22,245,072

3-year average 42,000,000 56.30% 23,646,330

INBOUND CAPACITY

Currently there are no dedicated pipelines for ethanol in the United States. Most ethanol leaves the 

production plant on trains. Rail shipment is most efficient when a train of approximately 100 cars, known as

a “unit train,” is loaded entirely with ethanol and sent to a single destination. The Sewaren terminal has the 

ability to offload approximately 96 railcars per day with ethanol capacities of 28,750 gallons per railcar and 

2,760,000 gallons per unit train, respectively. Inbound rail capabilities are available daily throughout the 

month. Over the course of a 30-day month, Sewaren terminal has the capacity to offloads a total of 

82,800,000 million gallons by rail. 

The Exchange applied a 20% reduction to the Sewaren thirty (30)-day inbound capacity resulting in 16.56 

million gallons of ethanol that can be considered readily available for delivery each month. Table 3 

combines total ethanol inventories with a 20% reduction in ethanol inbound capacity to arrive at an average 

monthly deliverable supply of 89.89 million gallons.

Table 3. Inventories and Inbound Capacity

(gallons)

Date Total Ethanol 

Inventories

Total Ethanol 

Inbound Capacity

20% Reduction

Ethanol Inbound 

Capacity

Monthly Deliverable 

Supply

2020

Nov 21,010,711 82,800,000 66,240,000 87,250,711

Dec 23,766,714 82,800,000 66,240,000 90,006,714

2021

Jan 25,816,290 82,800,000 66,240,000 92,056,290

Feb 25,782,839 82,800,000 66,240,000 92,022,839

Mar 25,146,545 82,800,000 66,240,000 91,386,545

Apr 23,665,720 82,800,000 66,240,000 89,905,720

May 21,278,168 82,800,000 66,240,000 87,518,168

Jun 21,999,561 82,800,000 66,240,000 88,239,561

Jul 22,976,668 82,800,000 66,240,000 89,216,668

Aug 23,376,157 82,800,000 66,240,000 89,616,157

Sep 22,353,974 82,800,000 66,240,000 88,593,974

Oct 20,164,156 82,800,000 66,240,000 86,404,156

Nov 18,491,462 82,800,000 66,240,000 84,731,462

Dec 19,700,989 82,800,000 66,240,000 85,940,989

2022

Jan 23,434,807 82,800,000 66,240,000 89,674,807

Feb 25,199,330 82,800,000 66,240,000 91,439,330

Mar 26,473,132 82,800,000 66,240,000 92,713,132

Apr 26,521,141 82,800,000 66,240,000 92,761,141

May 24,132,925 82,800,000 66,240,000 90,372,925
13

Jun 22,931,888 82,800,000 66,240,000 89,171,888

Jul 24,641,056 82,800,000 66,240,000 90,881,056

Aug 24,978,435 82,800,000 66,240,000 91,218,435

Sep 23,899,976 82,800,000 66,240,000 90,139,976

Oct 23,940,726 82,800,000 66,240,000 90,180,726

Nov 22,690,196 82,800,000 66,240,000 88,930,196

Dec 24,007,542 82,800,000 66,240,000 90,247,542

2023

Jan 24,251,709 82,800,000 66,240,000 90,491,709

Feb 26,446,736 82,800,000 66,240,000 92,686,736

Mar 27,634,291 82,800,000 66,240,000 93,874,291

Apr 24,943,838 82,800,000 66,240,000 91,183,838

May 24,263,952 82,800,000 66,240,000 90,503,952

Jun 23,108,810 82,800,000 66,240,000 89,348,810

Jul 23,779,387 82,800,000 66,240,000 90,019,387

Aug 23,438,613 82,800,000 66,240,000 89,678,613

Sep 22,774,353 82,800,000 66,240,000 89,014,353

Oct 22,245,072 82,800,000 66,240,000 88,485,072

3-year 

average

23,646,330 82,800,000 66,240,000 89,886,330
14

ANALYSIS OF DELIVERABLE SUPPLY

Appendix C to part 38 of the Commission’s regulations defines deliverable supply as “the quantity of the 

commodity meeting the contract’s delivery specifications that can reasonably be expected to be readily 

available to short traders and saleable by long traders at its market value in normal cash marketing channels 

at the derivative contract’s delivery points during the specified delivery period, barring abnormal movement 

in interstate commerce.”

In estimating deliverable supply and calculating position limits, the Exchange relied on inventories and 

inbound capacity at the Sewaren Terminal. The deliverable supply is calculated as the sum of these two 

figures. Based on the above analysis, it is estimated that the deliverable supply for the Contract is 

89,886,330 gallons per month utilizing the most recent three (3)-year monthly average from November 

2020 through October 2023, which is equivalent to 2,140 contracts. Therefore, the spot month position limit 

for the Contract of 400 contracts reflects 18.69% of the estimated deliverable supply.

Monthly Deliverable Supply Contract 

Equivalent

Spot Month 

Position Limit

Percentage of 

Deliverable 

Supply

89,886,330 2,140 400 18.69%