Orders Finding That the PJM WH Real Time Peak Contract and PJM WH Real Time Off-Peak Contract Offered for Trading on the IntercontinentalExchange, Inc., Perform a Significant Price Discovery Function, 42390-42399 [2010-17743]
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42390
Federal Register / Vol. 75, No. 139 / Wednesday, July 21, 2010 / Notices
Act, hereby determines that the SP–15
Financial Day-Ahead LMP Peak
contract, traded on the
IntercontinentalExchange, Inc., satisfies
the material price preference and
material liquidity criteria for significant
price discovery contracts. Consistent
with this determination, and effective
immediately, the
IntercontinentalExchange, Inc., must
comply with, with respect to the SP–15
Financial Day-Ahead LMP Peak
contract, the nine core principles
established by new section 2(h)(7)(C).
Additionally, the
IntercontinentalExchange, Inc., shall be
and is considered a registered entity 45
with respect to the SP–15 Financial
Day-Ahead LMP Peak contract and is
subject to all the provisions of the
Commodity Exchange Act applicable to
registered entities.
Further with respect to the SP–15
Financial Day-Ahead LMP Peak
contract, the obligations, requirements
and timetables prescribed in
Commission rule 36.3(c)(4) governing
core principle compliance by the
IntercontinentalExchange, Inc.,
commence with the issuance of this
Order.46
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b. Order Relating to the SP–15 Financial
Day-Ahead LMP Off-Peak Contract
After considering the complete record
in this matter, including the comment
letters received in response to its
request for comments, the Commission
has determined to issue the following
Order:
The Commission, pursuant to its
authority under section 2(h)(7) of the
Act, hereby determines that the SP–15
Financial Day-Ahead LMP Off-Peak
contract, traded on the
IntercontinentalExchange, Inc., satisfies
the statutory material price reference
and material liquidity criteria for
significant price discovery contracts.
Consistent with this determination, and
effective immediately, the
IntercontinentalExchange, Inc., must
comply with, with respect to the SP–15
Financial Day-Ahead LMP Off-Peak
contract, the nine core principles
established by new section 2(h)(7)(C).
Additionally, the
IntercontinentalExchange, Inc., shall be
and is considered a registered entity 47
with respect to the SP–15 Financial
45 7
U.S.C. 1a(29).
ICE already lists for trading a contract
(i.e., the Henry Financial LD1 Fixed Price contract)
that was previously declared by the Commission to
be a SPDC, ICE must submit a written
demonstration of compliance with the Core
Principles within 30 calendar days of the date of
this Order. 17 CFR 36.3(c)(4).
47 7 U.S.C. 1a(29).
46 Because
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Day-Ahead LMP Off-Peak contract and
is subject to all the provisions of the
Commodity Exchange Act applicable to
registered entities.
Further with respect to the SP–15
Financial Day-Ahead LMP Off-Peak
contract, the obligations, requirements
and timetables prescribed in
Commission rule 36.3(c)(4) governing
core principle compliance by the
IntercontinentalExchange, Inc.,
commence with the issuance of this
Order.48
Issued in Washington, DC, on July 9, 2010,
by the Commission.
David A. Stawick,
Secretary of the Commission.
[FR Doc. 2010–17747 Filed 7–20–10; 8:45 am]
BILLING CODE 6351–01–P
COMMODITY FUTURES TRADING
COMMISSION
Orders Finding That the PJM WH Real
Time Peak Contract and PJM WH Real
Time Off-Peak Contract Offered for
Trading on the
IntercontinentalExchange, Inc.,
Perform a Significant Price Discovery
Function
Commodity Futures Trading
Commission.
ACTION: Final orders.
AGENCY:
On October 26, 2009, the
Commodity Futures Trading
Commission (‘‘CFTC’’ or ‘‘Commission’’)
published for comment in the Federal
Register 1 a notice of its intent to
undertake a determination whether the
PJM 2 WH 3 Real Time Peak (‘‘PJM’’)
contract and PJM WH Real Time OffPeak (‘‘OPJ’’) contract,4 which are listed
for trading on the
IntercontinentalExchange, Inc. (‘‘ICE’’),
an exempt commercial market (‘‘ECM’’)
under sections 2(h)(3)–(5) of the
SUMMARY:
48 Because ICE already lists for trading a contract
(i.e., the Henry Financial LD1 Fixed Price contract)
that was previously declared by the Commission to
be a SPDC, ICE must submit a written
demonstration of compliance with the Core
Principles within 30 calendar days of the date of
this Order. 17 CFR 36.3(c)(4).
1 74 FR 54966 (October 26, 2009).
2 The acronym ‘‘PJM’’ stands for Pennsylvania
New Jersey Maryland Interconnection, LLC (‘‘PJM
Interconnection’’), and signifies the regional
electricity transmission organization (‘‘RTO’’) that
coordinates the generation and distribution of
electricity in all or parts of 13 states and the District
of Columbia.
3 The acronym ‘‘WH’’ signifies the PJM’s Western
Hub.
4 The Federal Register notice also requested
comment on the PJM WH Real Time Peak Daily
(‘‘PDP’’) contract, PJM WH Day Ahead LMP Peak
Daily (‘‘PDA’’) contract and PJM WH Real Time OffPeak Daily (‘‘ODP’’) contract. Those contracts will be
addressed in a separate Federal Register release.
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Commodity Exchange Act (‘‘CEA’’ or the
‘‘Act’’), perform a significant price
discovery function pursuant to section
2(h)(7) of the CEA. The Commission
undertook this review based upon an
initial evaluation of information and
data provided by ICE as well as other
available information. The Commission
has reviewed the entire record in this
matter, including all comments
received, and has determined to issue
orders finding that the PJM and OPJ
contracts perform a significant price
discovery function. Authority for this
action is found in section 2(h)(7) of the
CEA and Commission rule 36.3(c)
promulgated thereunder.
DATES: Effective Date: July 9, 2010.
FOR FURTHER INFORMATION CONTACT:
Gregory K. Price, Industry Economist,
Division of Market Oversight,
Commodity Futures Trading
Commission, Three Lafayette Centre,
1155 21st Street, NW., Washington, DC
20581. Telephone: (202) 418–5515. Email: gprice@cftc.gov; or Susan Nathan,
Senior Special Counsel, Division of
Market Oversight, same address.
Telephone: (202) 418–5133. E-mail:
snathan@cftc.gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
The CFTC Reauthorization Act of
2008 (‘‘Reauthorization Act’’) 5
significantly broadened the CFTC’s
regulatory authority with respect to
ECMs by creating, in section 2(h)(7) of
the CEA, a new regulatory category—
ECMs on which significant price
discovery contracts (‘‘SPDCs’’) are
traded—and treating ECMs in that
category as registered entities under the
CEA.6 The legislation authorizes the
CFTC to designate an agreement,
contract or transaction as a SPDC if the
Commission determines, under criteria
established in section 2(h)(7), that it
performs a significant price discovery
function. When the Commission makes
such a determination, the ECM on
which the SPDC is traded must assume,
with respect to that contract, all the
responsibilities and obligations of a
registered entity under the Act and
Commission regulations, and must
comply with nine core principles
established by new section 2(h)(7)(C).
On March 16, 2009, the CFTC
promulgated final rules implementing
the provisions of the Reauthorization
Act.7 As relevant here, rule 36.3
5 Incorporated as Title XIII of the Food,
Conservation and Energy Act of 2008, Public Law
No. 110–246, 122 Stat. 1624 (June 18, 2008).
6 7 U.S.C. 1a(29).
7 74 FR 12178 (Mar. 23, 2009); these rules became
effective on April 22, 2009.
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imposes increased information reporting
requirements on ECMs to assist the
Commission in making prompt
assessments whether particular ECM
contracts may be SPDCs. In addition to
filing quarterly reports of its contracts,
an ECM must notify the Commission
promptly concerning any contract
traded in reliance on the exemption in
section 2(h)(3) of the CEA that averaged
five trades per day or more over the
most recent calendar quarter, and for
which the exchange sells its price
information regarding the contract to
market participants or industry
publications, or whose daily closing or
settlement prices on 95 percent or more
of the days in the most recent quarter
were within 2.5 percent of the
contemporaneously determined closing,
settlement or other daily price of
another contract.
Commission rule 36.3(c)(3)
established the procedures by which the
Commission makes and announces its
determination whether a particular ECM
contract serves a significant price
discovery function. Under those
procedures, the Commission will
publish notice in the Federal Register
that it intends to undertake an
evaluation whether the specified
agreement, contract or transaction
performs a significant price discovery
function and to receive written views,
data and arguments relevant to its
determination from the ECM and other
interested persons. Upon the close of
the comment period, the Commission
will consider, among other things, all
relevant information regarding the
subject contract and issue an order
announcing and explaining its
determination whether or not the
contract is a SPDC. The issuance of an
affirmative order signals the
effectiveness of the Commission’s
regulatory authorities over an ECM with
respect to a SPDC; at that time such an
ECM becomes subject to all provisions
of the CEA applicable to registered
entities.8 The issuance of such an order
also triggers the obligations,
requirements and timetables prescribed
in Commission rule 36.3(c)(4).9
8 Public Law 110–246 at 13203; Joint Explanatory
Statement of the Committee of Conference, H.R.
Rep. No. 110–627, 110 Cong., 2d Sess. 978, 986
(Conference Committee Report). See also 73 FR
75888, 75894 (Dec. 12, 2008).
9 For an initial SPDC, ECMs have a grace period
of 90 calendar days from the issuance of a SPDC
determination order to submit a written
demonstration of compliance with the applicable
core principles. For subsequent SPDCs, ECMs have
a grace period of 30 calendar days to demonstrate
core principle compliance.
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II. Notice of Intent To Undertake SPDC
Determination
On October 26, 2009, the Commission
published in the Federal Register notice
of its intent to undertake a
determination whether the PJM and OPJ
contracts 10 perform a significant price
discovery function and requested
comment from interested parties.11
Comments were received from PJM
Interconnection, Federal Energy
Regulatory Commission (‘‘FERC’’),
Electric Power Supply Association
(‘‘EPSA’’), Financial Institutions Energy
Group (‘‘FIEG’’), Edison Electric Institute
(‘‘EEI’’), ICE and Public Utility
Commission of Texas (‘‘PUCT’’).12 The
comment letters from PJM
Interconnection,13 FERC14 and PUCT
10 As noted above, the Federal Register notice
also requested comment on the PJM WH Real Time
Peak Daily (‘‘PDP’’) contract, PJM WH Day Ahead
LMP Peak Daily (‘‘PDA’’) contract and PJM WH Real
Time Off-Peak Daily (‘‘ODP’’) contract. Those
contracts will be addressed in a separate Federal
Register release.
11 The Commission’s Part 36 rules establish,
among other things, procedures by which the
Commission makes and announces its
determination whether a specific ECM contract
serves a significant price discovery function. Under
those procedures, the Commission publishes a
notice in the Federal Register that it intends to
undertake a determination whether a specified
agreement, contract or transaction performs a
significant price discovery function and to receive
written data, views and arguments relevant to its
determination from the ECM and other interested
persons.
12 PJM Interconnection, as noted above, is the
RTO that coordinates the generation and
distribution of electricity in all or parts of 13 states
and the District of Columbia. FERC is an
independent federal regulatory agency that, among
other things, regulates the interstate transmission of
natural gas, oil and electricity. EPSA describes itself
as the ‘‘national trade association representing
competitive power suppliers, including generators
and marketers.’’ FIEG describes itself as an
association of investment and commercial banks
who are active participants in various sectors of the
natural gas markets, ‘‘including acting as marketers,
lenders, underwriters of debt and equity securities,
and proprietary investors.’’ EEI is the ‘‘association of
shareholder-owned electric companies,
international affiliates and industry associates
worldwide.’’ ICE is an ECM, as noted above. PUCT
is the independent organization that oversees the
Electric Reliability Council of Texas (‘‘ERCOT’’) to
‘‘ensure nondiscriminatory access to the
transmission and distribution systems, to ensure the
reliability and adequacy of the regional electrical
network, and to perform other essential market
functions.’’ The comment letters are available on the
Commission’s Web site: https://www.cftc.gov/
lawandregulation/federalregister/
federalregistercomments/2009/09–032.html.
13 PJM Interconnection stated that it ‘‘takes no
position as to whether the ICE [contracts] * * *
perform significant price discovery functions.’’
14 FERC expressed the opinion that a
determination by the Commission that any of the
subject contracts performs a significant price
discovery function ‘‘would not appear to conflict
with FERC’s exclusive jurisdiction under the
Federal Power Act (FPA) over the transmission or
sale for resale of electric energy in interstate
commerce or with its other regulatory
responsibilities under the FPA’’ and further that
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did not directly address the issue of
whether or not the subject contracts are
SPDCs. The remaining comment letters
raised substantive issues with respect to
the applicability of section 2(h)(7) to the
subject contracts and generally
expressed the opinion that the contracts
are not SPDCs because they do not meet
the material price reference or material
liquidity criteria for SPDC
determination. These comments are
more extensively discussed below, as
applicable.
III. Section 2(h)(7) of the CEA
The Commission is directed by
section 2(h)(7) of the CEA to consider
the following criteria in determining a
contract’s significant price discovery
function:
• Price Linkage—the extent to which
the agreement, contract or transaction
uses or otherwise relies on a daily or
final settlement price, or other major
price parameter, of a contract or
contracts listed for trading on or subject
to the rules of a designated contract
market (‘‘DCM’’) or derivatives
transaction execution facility (‘‘DTEF’’),
or a SPDC traded on an electronic
trading facility, to value a position,
transfer or convert a position, cash or
financially settle a position, or close out
a position.
• Arbitrage—the extent to which the
price for the agreement, contract or
transaction is sufficiently related to the
price of a contract or contracts listed for
trading on or subject to the rules of a
DCM or DTEF, or a SPDC traded on or
subject to the rules of an electronic
trading facility, so as to permit market
participants to effectively arbitrage
between the markets by simultaneously
maintaining positions or executing
trades in the contracts on a frequent and
recurring basis.
• Material price reference—the extent
to which, on a frequent and recurring
basis, bids, offers or transactions in a
commodity are directly based on, or are
determined by referencing or
consulting, the prices generated by
agreements, contracts or transactions
being traded or executed on the
electronic trading facility.
• Material liquidity—the extent to
which the volume of agreements,
contracts or transactions in a
commodity being traded on the
electronic trading facility is sufficient to
have a material effect on other
agreements, contracts or transactions
‘‘FERC staff will monitor proposed SPDC
determinations and advise the CFTC of any
potential conflicts with FERC’s exclusive
jurisdiction over RTOs, [(regional transmission
organizations)], ISOs [(independent system
operators)] or other jurisdictional entities.’’
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listed for trading on or subject to the
rules of a DCM, DTEF or electronic
trading facility operating in reliance on
the exemption in section 2(h)(3).
Not all criteria must be present to
support a determination that a
particular contract performs a
significant price discovery function, and
one or more criteria may be inapplicable
to a particular contract.15 Moreover, the
statutory language neither prioritizes the
criteria nor specifies the degree to
which a SPDC must conform to the
various criteria. In Guidance issued in
connection with the Part 36 rules
governing ECMs with SPDCs, the
Commission observed that these criteria
do not lend themselves to a mechanical
checklist or formulaic analysis.
Accordingly, the Commission has
indicated that in making its
determinations it will consider the
circumstances under which the
presence of a particular criterion, or
combination of criteria, would be
sufficient to support a SPDC
determination.16 For example, for
contracts that are linked to other
contracts or that may be arbitraged with
other contracts, the Commission will
consider whether the price of the
potential SPDC moves in such harmony
with the other contract that the two
markets essentially become
interchangeable. This co-movement of
prices would be an indication that
activity in the contract had reached a
level sufficient for the contract to
perform a significant price discovery
function. In evaluating a contract’s price
discovery role as a price reference, the
Commission the extent to which, on a
frequent and recurring basis, bids, offers
or transactions are directly based on, or
are determined by referencing, the
prices established for the contract.
IV. Findings and Conclusions
The Commission’s findings and
conclusions with respect to the PJM and
OPJ contracts are discussed separately
below.
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a. The PJM WH Real Time Peak (PJM)
Contract and the SPDC Indicia
The PJM contract is cash settled based
on the arithmetic average of peak-hour,
real-time locational marginal prices
(‘‘LMPs’’) 17 published by PJM
15 In its October 26, 2009, Federal Register
release, the Commission identified material price
reference and material liquidity as the possible
criteria for SPDC determination of the PJM and OPJ
contracts. Arbitrage and price linkage were not
identified as possible criteria. As a result, arbitrage
and price linkage will not be discussed further in
this document and the associated Orders.
16 17 CFR 36, Appendix A.
17 An LMP represents the additional cost
associated with producing an incremental amount
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Interconnection for its Western Hub for
all peak hours during the contract
month. The hourly LMPs are derived
from power trades that result in
physical delivery. The size of the PJM
contract is 800 megawatt hours
(‘‘MWh’’), and the PJM contract is listed
for 110 calendar months.
In general, electricity is bought and
sold in an auction setting on an hourly
basis at various point along the
electrical grid. An LMP associated with
a specific hour is calculated as the
volume-weighted average price of all of
the transactions where electricity is to
be supplied and consumed during that
hour.
Electricity is traded in a day-ahead
market as well as a real-time market.
The day-ahead market establishes prices
for electricity that is to be delivered
during the specified hour on the
following day. Day-ahead prices are
determined based on generation and
energy transaction quotes offered in
advance. Because the offers and bids are
dependent on estimates of supply and
demand, electricity needs usually are
not perfectly satisfied in the day-ahead
market. In this regard, on the day the
electricity is transmitted and used,
auction participants typically realize
that they bought or sold either too much
power or too little power. A real-time
auction is operated to alleviate this
problem by serving as a balancing
mechanism. Specifically, electricity
traders use the real-time market to sell
excess electricity and buy additional
power to meet demand.
PJM Interconnection is an RTO that
coordinates the movement of wholesale
electricity in all or parts of Delaware,
Illinois, Indiana, Kentucky, Maryland,
Michigan, New Jersey, North Carolina,
Ohio, Pennsylvania, Tennessee,
Virginia, West Virginia and the District
of Columbia. PJM Interconnection’s
transmission network is the largest
centrally-dispatched grid in North
America. PJM Interconnection
dispatches about 163,500 MW of
generating capacity over 56,350 miles of
transmission lines and serves more than
51 million customers. The RTO’s
members, totaling more than 500,
include power generators, transmission
owners, electricity distributors, power
marketers and large consumers.
PJM Interconnection is responsible for
operating a competitive wholesale
electricity market as well as maintaining
the reliability of the grid. The RTO acts
as a neutral, independent party, and its
activities are regulated by FERC. The
of electricity. LMPs account for generation costs,
congestion along the transmission lines, and
electricity loss.
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company coordinates the continuous
buying, selling and delivery of
wholesale electricity through robust,
open and competitive spot markets. In
operating the markets, PJM balances the
needs of suppliers, wholesale customers
and other market participants, and it
continuously monitors market behavior.
Electricity is priced at individual
points along the transmission network
called nodes. An electric grid has many
interconnections or buses. RTOs group
certain buses together to form hubs,
which do not necessarily follow along
state lines or geographic boundaries.
Power also is priced at the hub level and
serves as a basis for trading electricity.
PJM Interconnnection has 11 hubs,
including AEP GEN, AEP–Dayton,
Chicago GEN, Chicago, Dominion,
Eastern, Northern Illinois, New Jersey,
Ohio, West INT and Western Hub.18 The
Western Hub is basket of 109 buses that
stretch all the way from Erie, PA, to
Washington, DC.19
1. Material Price Reference Criterion
The Commission’s October 26, 2009,
Federal Register notice identified the
PJM contract as a potential SPDC based
on the material price reference and
material liquidity criteria. The
Commission considered the fact that ICE
sells its price data to market participants
in a number of different packages which
vary in terms of the hubs covered, time
periods, and whether the data are daily
only or historical. For example, ICE
offers the ‘‘East Power of Day’’ package
with access to all price data or just
current prices plus a selected number of
months (i.e., 12, 24, 36 or 48 months) of
historical data. This package includes
price data for the PJM contract.
The Commission also noted that its
October 2007 Report on the Oversight of
Trading on Regulated Futures
Exchanges and Exempt Commercial
Markets (‘‘ECM Study’’) found that in
general, market participants view ICE as
a price discovery market for certain
electricity contracts. The study did not
specify which markets performed this
function; nevertheless, the Commission
determined that the PJM contract, while
not mentioned by name in the ECM
Study, warranted further review.
The Commission explains in its
Guidance to the statutory criteria that in
evaluating a contract under the material
price reference criterion, it will rely on
one of two sources of evidence—direct
or indirect—to determine that the price
of a contract was being used as a
18 https://www.ferc.gov/market-oversight/mktelectric/pjm.asp.
19 https://www.ferc.gov/market-oversight/mktelectric/pjm/2010/05-2010-elec-pjm-archive.pdf.
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material price reference and therefore,
serving a significant price discovery
function.20 With respect to direct
evidence, the Commission will consider
the extent to which, on a frequent and
recurring basis, cash market bids, offers
or transactions are directly based on or
quoted at a differential to, the prices
generated on the ECM in question.
Direct evidence may be established
when cash market participants are
quoting bid or offer prices or entering
into transactions at prices that are set
either explicitly or implicitly at a
differential to prices established for the
contract in question. Cash market prices
are set explicitly at a differential to the
section 2(h)(3) contract when, for
instance, they are quoted in dollars and
cents above or below the reference
contract’s price. Cash market prices are
set implicitly at a differential to a
section 2(h)(3) contract when, for
instance, they are arrived at after adding
to, or subtracting from the section
2(h)(3) contract, but then quoted or
reported at a flat price. With respect to
indirect evidence, the Commission will
consider the extent to which the price
of the contract in question is being
routinely disseminated in widely
distributed industry publications—or
offered by the ECM itself for some form
of remuneration—and consulted on a
frequent and recurring basis by industry
participants in pricing cash market
transactions.
The PJM Western hub is a major
pricing center for electricity in the
eastern portion of the United States.
Traders, including producers, keep
abreast of the electricity prices at PJM’s
Western Hub when conducting cash
deals. These traders look to a
competitively determined price as an
indication of expected values of power
at the Western Hub when entering into
cash market transaction for electricity,
especially those trades providing for
physical delivery in the future.
Furthermore, power prices in other
neighboring markets, such as New York
ISO’s Zone A (Western New York), Zone
G (Hudson Valley region) and Zone J
(New York City) as well as Midwest
ISO’s Cinergy hub are typically based
implicitly relative to the prices reported
for PJM Interconnection’s Western hub.
Traders use the ICE PJM contract, as
well as other ICE power contracts, to
hedge cash market positions and
transactions—activities which enhance
the PJM contract’s price discovery
utility. The substantial volume of
trading and open interest in the PJM
contract appears to attest to its use for
this purpose. While the PJM contract’s
20 17
CFR 36, Appendix A.
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settlement prices may not be the only
factor influencing spot and forward
transactions, electricity traders consider
the ICE price to be a critical factor in
conducting OTC transactions.21 In these
circumstances, the PJM contract satisfies
the direct price reference test.
The fact that ICE’s PJM monthly
contract is used more widely as a source
of pricing information than the daily
contract (i.e., the ‘‘PDP’’ contract) 22
bolsters the argument that it serves as a
direct price reference. In this regard,
PJM contract prices power at the
Western hub up to almost ten years into
the future. Thus, market participants
can use the PJM contract to lock in
electricity prices far into the future.
Traders use monthly power contracts
like the PJM contract to price future
power electricity commitments, where
such commitments are based on longrange forecasts of power supply and
demand. In contrast, the PDP contract is
listed for a much shorter length of
time—up to 38 days in the future. As
generation and usage nears, market
participants have a better understanding
of actual power supply and needs. As a
result, they can modify previouslyestablished hedges with daily contracts,
like the PDP contract.
The Commission notes that the
Western hub is a major trading point for
electricity, and that the PJM contract’s
prices are well regarded in the industry
as indicative of the value of power at the
Western hub. Accordingly, the
Commission believes that it is
reasonable to conclude that market
participants purchase the data packages
that include the PJM contract’s prices in
substantial part because the PJM
contract’s prices have particular value to
them. Moreover, such prices are
consulted on a frequent and recurring
basis by industry participants in pricing
cash market transactions. In light of the
above, the PJM contract also meets the
indirect price reference test.
The New York Mercantile Exchange
(‘‘NYMEX’’) lists a futures contract on its
ClearPort platform— the PJM Western
Hub Peak Calendar-Month Real-Time
LMP Swap futures contract —that is
comparable to the ICE PJM contract.
21 In addition to referencing ICE prices, firms
participating in PJM’s Western hub power market
may rely on other cash market quotes as well as
industry publications and price indices that are
published by third-party price reporting firms in
entering into power transactions.
22 The PDP contract is cash settled based on the
arithmetic average of peak-hour, real-time LMPs
posted by PJM for the Western hub for all peak
hours on the day of generation. The LMPs are
derived from power trades that result in physical
delivery. The size of the SDP contract is 800 MWh,
and the PDP contract is listed for 38 consecutive
calendar days.
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42393
However, unlike the ICE contract, none
of the trades in the NYMEX version are
executed in NYMEX’s centralized
marketplace; instead, all of the
transactions originate as bilateral swaps
that are submitted to NYMEX for
clearing. The daily settlement prices of
NYMEX’s monthly, peak-hour Western
hub contract are influenced, in part, by
the daily settlement prices of the ICE
PJM contract. NYMEX determines the
daily settlement prices for its power
contracts through a survey of cash
market voice brokers. Voice brokers, in
turn, refer to the ICE PJM price, among
other information, as an important
indicator as to where the market is
trading. In this manner, the ICE PJM
price influences the settlement price for
the NYMEX monthly, peak-hour
Western hub power contract. This
conclusion is supported by an analysis
of the daily settlement prices for the
PJM contract and the NYMEX
equivalent which indicates that 81
percent of the daily settlement prices 23
for the NYMEX version of the contract
are within one standard deviation of the
PJM contract’s price settlement prices.
i. Federal Register Comments:
EPSA, FIEG, EEI and ICE stated that
no other contract directly references or
settles to the PJM contract’s price.
Moreover, the commenters argued that
the underlying cash price series against
which the PJM contract is settled 24 is
the authentic reference price and not the
ICE contract itself. Commission staff
believes that this interpretation of price
reference is too narrow and believes that
a cash-settled derivatives contract could
meet the price reference criterion if
market participants ‘‘consult [the
derivatives contract] on a frequent and
recurring basis’’ when pricing forward,
fixed-price commitments or other cashsettled derivatives that seek to ‘‘lock in’’
a fixed price for some future point in
time to hedge against adverse price
movements.
As noted above, PJM’s Western hub is
a major trading center for electricity in
the eastern United States. Traders,
including producers, keep abreast of the
prices of the PJM contract when
conducting cash deals. These traders
look to a competitively determined
price as an indication of expected
values of electricity at the Western hub
when entering into cash market
transaction for power, especially those
trades that provide for physical delivery
in the future. Traders use the ICE PJM
23 The price data covered the period December
2008 through December 2009.
24 In this case, the average of the real-time peakhour Western hub electricity prices over the
contract month, which are derived from cash
market transactions.
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contract to hedge cash market positions
and transactions, which enhances the
PJM contract’s price discovery utility.
While the PJM contract’s settlement
prices may not be the only factor
influencing spot and forward
transactions, natural gas traders
consider the ICE price to be a crucial
factor in conducting OTC transactions.
In addition, EPSA stated that the
publication of price data for the PJM
contract price is a weak justification for
material price reference because market
participants generally do not purchase
ICE data sets for one contract’s prices,
such as those for the PJM contract.
Instead, traders are interested in the
settlement prices, so the fact that ICE
sells the PJM prices as part of a broad
package is not conclusive evidence that
market participants are buying the ICE
data sets because they find the PJM
prices have substantial value. As noted
above, the Commission recognizes that
publication of the PJM contract’s prices
is indirect evidence of routine
dissemination. Thus, the Commission
has concluded that traders likely
purchase the ICE data packages
specifically for the PJM contract’s prices
and consult such prices on a frequent
and recurring basis in pricing cash
market transactions.
Lastly, ICE and EEI criticized the ECM
Study since it did not specifically
identify the PJM contract as a contract
that is referred to by market participants
on a frequent and recurring basis. In
response, the Commission notes that it
cited the ECM Study’s general finding
that some ICE electricity contracts
appear to be regarded as price discovery
markets merely as indication that an
investigation of certain ICE contracts
may be warranted. The ECM Study was
not intended to serve as the sole basis
for determining whether or not a
particular contract meets the material
price reference criterion.
ii. Conclusion Regarding Material
Price Reference:
The Commission finds that the ICE
PJM contract meets the material price
reference criterion because cash market
transactions are priced either explicitly
or implicitly on a frequent and recurring
basis at a differential to the PJM
contract’s price (direct evidence).
Moreover, the PJM contract’s price data
are sold to market participants, and
those individuals likely purchase the
ICE data packages specifically for the
PJM contract’s prices and consult such
prices on a frequent and recurring basis
in pricing cash market transactions
(indirect evidence).
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2. Material Liquidity Criterion
In its October 26, 2009, Federal
Register notice, the Commission
identified the PJM contract as a
potential SPDC based on the material
price reference and material liquidity
criteria. To assess whether a contract
meets the material liquidity criterion,
the Commission first examines trading
activity as a general measurement of the
contract’s size and potential importance.
If the Commission finds that the
contract in question meets a threshold
of trading activity that would render it
of potential importance, the
Commission will then perform a
statistical analysis to measure the effect
that changes to the subject-contract’s
prices potentially may have on prices
for other contracts listed on an ECM or
a DCM.
The Commission’s Guidance to the
statutory criteria (Appendix A to Part
36) notes that ‘‘[t]raditionally, objective
measures of trading such as volume or
open interest have been used as
measures of liquidity.’’ In this regard,
the total number of transactions
executed on ICE’s electronic platform in
the PJM contract was 7,990 in the
second quarter of 2009, resulting in a
daily average of 124.8 trades. During the
same period, the PJM contract had a
total trading volume of 268,489
contracts and an average daily trading
volume of 4,195.1 contracts. Moreover,
open interest as of June 30, 2009, was
318,788 contracts, which included
trades executed on ICE’s electronic
trading platform, as well as trades
executed off of ICE’s electronic trading
platform and then brought to ICE for
clearing. In this regard, ICE does not
differentiate between open interest
created by a transaction executed on its
trading platform and that created by a
transaction executed off its trading
platform.25
In a subsequent filing dated March 24,
2010, ICE reported that total trading
volume in the fourth quarter of 2009
was 371,885 contracts (or 5,721.3
contracts on a daily basis). In terms of
number of transactions, 9,913 trades
occurred in the fourth quarter of 2009
(152.5 trades per day). As of December
31, 2009, open interest in the PJM
contract was 344,754 contracts, which
included trades executed on ICE’s
electronic trading platform, as well as
trades executed off of ICE’s electronic
trading platform and then brought to
ICE for clearing.
The number of trades per day was
substantial during the period between
the second and fourth quarters of 2009.
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FR 54966 (October 26, 2009).
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In addition, trading activity in the PJM
contract, as characterized by total
quarterly volume, indicates that the PJM
contract experiences trading activity
that is greater than that of thinly-traded
futures markets.26 Thus, it is reasonable
to infer that the PJM contract could have
a material effect on other ECM contracts
or on DCM contracts.
To measure the effect that the PJM
contract potentially could have on
another ECM contract staff performed a
statistical analysis 27 using daily
settlement prices (between July 1, 2008
and December 31, 2009) for the ICE PJM
and OPJ contracts. The simulation
suggest that, on average over the sample
period, a one percent rise in the PJM
contract’s price elicited a 2.15 percent
increase in ICE OPJ contract’s price.
i. Federal Register Comments:
ICE stated that the PJM contract lacks
a sufficient number of trades to meet the
material liquidity criterion. Along with
EPSA and EEI, ICE argued that the PJM
contract cannot have a material effect on
DCM contracts or other ECM contracts
because these other contracts do not
cash settle to the PJM contract’s price.
Instead, the DCM contracts and the PJM
contract are both cash settled based on
physical transactions, which neither the
ECM or the DCM contracts can
influence. The Commission’s statistical
analysis shows that changes in the ICE
PJM contract’s price significantly
influences the prices of other ECM
contracts (namely, the OPJ contract). In
this regard, a one-percent rise in the
PJM contract’s price leads to a 2.15
percent rise in OPJ contract’s price.
26 Staff has advised the Commission that in its
experience, a thinly-traded contract is, generally,
one that has a quarterly trading volume of 100,000
contracts or less. In this regard, in the third quarter
of 2009, physical commodity futures contracts with
trading volume of 100,000 contracts or fewer
constituted less than one percent of total trading
volume of all physical commodity futures contracts.
27 Specifically, Commission staff econometrically
estimated a cointegrated vector autoregression
(CVAR) model using daily settlement prices. CVAR
methods permit a dichotomization of the data
relationships into long run equilibrium components
(called the cointegration space or cointegrating
relationships) and a short run component. A CVAR
model was chosen over the more traditional vector
autoregression model in levels because the
statistical properties of the data (lack of stationarity
and ergodicity) precluded the more traditional
modeling treatment. Moreover, the statistical
properties of the data necessitated the modeling of
the contracts’ prices as a CVAR model containing
both first differences (to handle stationarity) and an
error-correction term to capture long run
equilibrium relationships. The prices were treated
as a single reduced-form model in order to test
hypothesis that power prices in the same market
affect each other. The prices of ICE’s PJM and OPJ
contracts are positively related to each other in a
cointegrating relationship and display a high level
of statistical strength. On average during the sample
period, each percentage rise in PJM contract’s price
elicited a 2.15 percent rise in OPJ contract’s price.
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ICE noted that the Commission’s
Guidance had posited concepts of
liquidity that generally assumed a fairly
constant stream of prices throughout the
trading day, and noted that the
relatively low number of trades per day
in the PJM contract did not meet this
standard of liquidity. The Commission
observes that a continuous stream of
prices would indeed be an indication of
liquidity for certain markets but the
Guidance also notes that ‘‘quantifying
the levels of immediacy and price
concession that would define material
liquidity may differ from one market or
commodity to another.’’ 28
ICE opined that the Commission
‘‘seems to have adopted a five trade per
day test for material liquidity.’’ To the
contrary, the Commission adopted a five
trades-per-day threshold as a reporting
requirement to enable it to
‘‘independently be aware of ECM
contracts that may develop into
SPDCs’’ 29 rather than solely relying
upon an ECM on its own to identify any
such potential SPDCs to the
Commission. Thus, any contract that
meets this threshold may be subject to
scrutiny as a potential SPDC; however,
the contract will not be found to be a
SPDC merely because it met the
reporting threshold.
ICE argued that the statistics provided
by ICE were misinterpreted and
misapplied by the Commission. In
particular, ICE stated that the volume
figures used in the Commission’s
analysis (cited above) ‘‘include trades
made in all months’’ as well as in strips
of contract months. ICE suggested that a
more appropriate method of
determining liquidity is to examine the
activity in a single traded month of a
given contract.’’ 30 It is the Commission’s
28 Guidance,
supra.
FR 75892 (December 12, 2008).
30 In addition, ICE stated that the trades-per-day
statistics that it provided to the Commission in its
quarterly filing and which were cited in the
Commission’s October 26, 2009, Federal Register
notice includes 2(h)(1) transactions, which were not
completed on the electronic trading platform and
should not be considered in the SPDC
determination process. The Commission staff asked
ICE to review the data it sent in its quarterly filings;
ICE confirmed that the volume data it provided and
which the Commission cited includes only
transaction data executed on ICE’s electronic
trading platform. As noted above, supplemental
data supplied by ICE confirmed that block trades
are in addition to the trades that were conducted
on the electronic platform; block trades comprise
about 49 percent of all transactions in the PJM
contract (as of the fourth quarter of 2009).
Commission acknowledges that the open interest
information it provided in its October 26, 2009,
Federal Register notice includes transactions made
off the ICE platform. However, once open interest
is created, there is no way for ICE to differentiate
between ‘‘on-exchange’’ versus ‘‘off-exchange’’
created positions, and all such positions are
fungible with one another and may be offset in any
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opinion that liquidity, as it pertains to
the PJM contract, is typically a function
of trading activity in particular lead
months and, given sufficient liquidity in
such months, the ICE PJM contract itself
would be considered liquid. ICE’s
analysis of its own trade data confirms
this to be the case for the PJM contract,
and thus, the Commission believes that
it applied the statistical data cited above
in an appropriate manner for gauging
material liquidity.
ii. Conclusion Regarding Material
Liquidity:
For the reasons discussed above, the
Commission finds that the PJM contract
meets the material liquidity criterion.
Specifically, there is sufficient trading
activity in the PJM contract to have a
material effect on ‘‘other agreements,
contracts or transactions listed for
trading on or subject to the rules of a
designated contract market * * * or an
electronic trading facility operating in
reliance on the exemption in section
2(h)(3) of the Act’’ (that is, an ECM).
3. Overall Conclusion Regarding the
PJM Contract
After considering the entire record in
this matter, including the comments
received, the Commission has
determined that the ICE PJM contract
performs a significant price discovery
function under two of the four criteria
established in section 2(h)(7) of the
CEA. Specifically, the Commission has
determined that the PJM contract meets
the material price reference and material
liquidity criteria at this time.
Accordingly, the Commission is issuing
the attached Order declaring that the
PJM contract is a SPDC.
Issuance of this Order signals the
immediate effectiveness of the
Commission’s authorities with respect
to ICE as a registered entity in
connection with its PJM contract,31 and
triggers the obligations, requirements—
both procedural and substantive—and
timetables prescribed in Commission
rule 36.3(c)(4) for ECMs.
b. The PJM WH Real Time Off-Peak
(OPJ) Contract and the SPDC Indicia
The OPJ contract is cash settled based
on the arithmetic average of off-peak
hour, real-time LMPs published by PJM
Interconnection for its Western Hub for
all off-peak hours during the contract
month. The hourly LMPs are derived
from power trades that result in
physical delivery. The size of the OPJ
contract is 50 MWh, and the OPJ
way agreeable to the position holder regardless of
how the position was initially created.
31 See 73 FR 75888, 75893 (Dec. 12, 2008).
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42395
contract is listed for up to 86 calendar
months.
In general, electricity is bought and
sold in an auction setting on an hourly
basis at various points along the
electrical grid. An LMP associated with
a specific hour is calculated as the
volume-weighted average price of all of
the transactions where electricity is to
be supplied and consumed during that
hour.
Electricity is traded in a day-ahead
market as well as a real-time market.
The day-ahead market establishes prices
for electricity that is to be delivered
during the specified hour on the
following day. Day-ahead prices are
determined based on generation and
energy transaction quotes offered in
advance. Because the offers and bids are
dependent on estimates of supply and
demand, electricity needs usually are
not perfectly satisfied in the day-ahead
market. In this regard, on the day the
electricity is transmitted and used,
auction participants typically realize
that they bought or sold either too much
power or too little power. A real-time
auction is operated to alleviate this
problem by serving as a balancing
mechanism. Specifically, electricity
traders use the real-time market to sell
excess electricity and buy additional
power to meet demand.
PJM Interconnection is an RTO that
coordinates the movement of wholesale
electricity in all or parts of Delaware,
Illinois, Indiana, Kentucky, Maryland,
Michigan, New Jersey, North Carolina,
Ohio, Pennsylvania, Tennessee,
Virginia, West Virginia and the District
of Columbia. PJM Interconnection’s
transmission network is the largest
centrally dispatched grid in North
America. PJM Interconnection
dispatches about 163,500 MW of
generating capacity over 56,350 miles of
transmission lines and serves more than
51 million customers. The RTO’s
members, totaling more than 500,
include power generators, transmission
owners, electricity distributors, power
marketers and large consumers.
PJM Interconnection is responsible for
operating a competitive wholesale
electricity market as well as maintaining
the reliability of the grid. The RTO acts
as a neutral, independent party, and its
activities are monitored by FERC. The
company coordinates the continuous
buying, selling and delivery of
wholesale electricity through robust,
open and competitive spot markets. In
operating the markets, PJM balances the
needs of suppliers, wholesale customers
and other market participants, and it
continuously monitors market behavior.
Electricity is priced at individual
points along the transmission network
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called nodes. An electric grid has many
interconnections or buses. RTOs group
certain buses together to form hubs for
pricing and trading purposes, and these
hubs do not necessarily follow along
state lines or geographic boundaries.
Power also is priced at the hub level and
serves as a basis for trading electricity.
PJM Interconnnection has 11 hubs,
including AEP GEN, AEP–Dayton,
Chicago GEN, Chicago, Dominion,
Eastern, Northern Illinois, New Jersey,
Ohio, West INT and Western Hub.32 The
Western Hub is a basket of 109 buses
that stretch all the way from Erie, PA,
to Washington, DC.33
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1. Material Price Reference Criterion
The Commission’s October 26, 2009,
Federal Register notice identified the
OJP contract as a potential SPDC based
on the material price reference and
material liquidity criteria. The
Commission considered the fact that ICE
sells its price data to market participants
in a number of different packages which
vary in terms of the hubs covered, time
periods, and whether the data are daily
only or historical. For example, ICE
offers the ‘‘East Power of Day’’package
with access to all price data or just
current prices plus a selected number of
months (i.e., 12, 24, 36 or 48 months) of
historical data. This package includes
price data for the OPJ contract.
The Commission also noted that its
October 2007 ECM Study found that in
general, market participants view ICE as
a price discovery market for certain
electricity contracts. The study did not
specify which markets performed this
function; nevertheless, the Commission
determined that the OPJ contract, while
not mentioned by name in the ECM
Study, warranted further review.
The Commission explains in its
Guidance to the statutory criteria that in
evaluating a contract under the material
price reference criterion, it will rely on
one of two sources of evidence—direct
or indirect—to determine that the price
of a contract was being used as a
material price reference and therefore,
serving a significant price discovery
function.34 With respect to direct
evidence, the Commission will consider
the extent to which, on a frequent and
recurring basis, cash market bids, offers
or transactions are directly based on or
quoted at a differential to, the prices
generated on the ECM in question.
Direct evidence may be established
when cash market participants are
32 https://www.ferc.gov/market-oversight/mkt-
electric/pjm.asp.
33 https://www.ferc.gov/market-oversight/mktelectric/pjm/2010/05–2010-elec-pjm-archive.pdf.
34 17 CFR 36, Appendix A.
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quoting bid or offer prices or entering
into transactions at prices that are set
either explicitly or implicitly at a
differential to prices established for the
contract in question. Cash market prices
are set explicitly at a differential to the
section 2(h)(3) contract when, for
instance, they are quoted in dollars and
cents above or below the reference
contract’s price. Cash market prices are
set implicitly at a differential to a
section 2(h)(3) contract when, for
instance, they are arrived at after adding
to, or subtracting from the section
2(h)(3) contract, but then quoted or
reported at a flat price. With respect to
indirect evidence, the Commission will
consider the extent to which the price
of the contract in question is being
routinely disseminated in widely
distributed industry publications—or
offered by the ECM itself for some form
of remuneration—and consulted on a
frequent and recurring basis by industry
participants in pricing cash market
transactions.
PJM’s Western hub is a major pricing
center for electricity in the eastern
portion of the United States. Traders,
including producers, keep abreast of the
electricity prices at PJM’s Western hub
when conducting cash deals. These
traders look to a competitively
determined price as an indication of
expected values of power at the Western
hub when entering into cash market
transactions for electricity, especially
those trades providing for physical
delivery in the future. Furthermore,
power prices in other neighboring
markets, such as New York ISO’s Zone
A (Western New York), Zone G (Hudson
Valley region) and Zone J (New York
City) as well as Midwest ISO’s Cinergy
hub, are typically based implicitly
relative to the prices reported for PJM
Interconnection’s Western hub. Traders
use the ICE OPJ contract, as well as
other ICE power contracts, to hedge cash
market positions and transactions—
activities which enhance the OPJ
contract’s price discovery utility. The
substantial volume of trading and open
interest in the OPJ contract appears to
attest to its use for this purpose. While
the OPJ contract’s settlement prices may
not be the only factor influencing spot
and forward transactions, electricity
traders consider the ICE price to be a
critical factor in conducting OTC
transactions.35 As a result, the OPJ
35 In addition to referencing ICE prices, firms
participating in PJM’s Western hub power market
may rely on other cash market quotes as well as
industry publications and price indices that are
published by third-party price reporting firms in
entering into power transactions.
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contract satisfies the direct price
reference test.
The fact that ICE’s OPJ monthly
contract is used widely as a source of
pricing information is further evidence
of direct price reference. In this regard,
OPJ contract prices power at the
Western hub about seven years into the
future. Thus, market participants can
use the OPJ contract to lock-in
electricity prices far into the future.
Traders use monthly power contracts
like the OPJ contract to price future
power electricity commitments, where
such commitments are based on longrange forecasts of power supply and
demand.
The Commission notes that the
Western hub is a major trading point for
electricity, and the OPJ contract’s prices
are well regarded in the industry as
indicative of the value of off-peak power
at the Western hub. Accordingly, the
Commission believes that it is
reasonable to conclude that market
participants purchase the data packages
that include the OPJ contract’s prices in
substantial part because the OPJ
contract’s prices have particular value to
them. Moreover, such prices are
consulted on a frequent and recurring
basis by industry participants in pricing
cash market transactions. In light of the
above, the OPJ contract meets the
indirect price reference test.
NYMEX lists a futures contract that is
comparable to the ICE OPJ contract on
its ClearPort platform called the PJM
Western Hub Off-Peak Calendar-Month
Real-Time LMP Swap futures contract.
However, unlike the ICE contract, none
of the trades in the NYMEX version are
executed in NYMEX’s centralized
marketplace; instead, all of the
transactions originate as bilateral swaps
that are submitted to NYMEX for
clearing. The daily settlement prices of
NYMEX’s monthly, off-peak hour
Western hub contract are influenced, in
part, by the daily settlement prices of
the ICE OPJ contract. This is because
NYMEX determines the daily settlement
prices for its power contracts through a
survey of cash market voice brokers.
Voice brokers, in turn, refer to the ICE
OPJ price, among other information, as
an important indicator as to where the
market is trading. Therefore, the ICE OPJ
price influences the settlement price for
the NYMEX monthly, off-peak hour
Western hub power contract. This
conclusion is supported by an analysis
of the daily settlement prices for the OPJ
contract and the NYMEX equivalent
which demonstrates that 94 percent of
the daily settlement prices 36 for the
36 The price data covered the period December
2008 through December 2009.
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NYMEX version of the contract are
within one standard deviation of the
OPJ contract’s price settlement prices.
i. Federal Register Comments:
EPSA, FIEG, EEI and ICE stated that
no other contract directly references or
settles to the OPJ contract’s price.
Moreover, the commenters argued that
the underlying cash price series against
which the OPJ contract is settled (in this
case, the average of the real-time offpeak hour Western Hub electricity
prices over the contract month, which
are derived from cash market
transactions) is the authentic reference
price and not the ICE contract itself. The
Commission believes that this
interpretation of price reference is too
narrow and believes that a cash-settled
derivatives contract could meet the
price reference criterion if market
participants ‘‘consult on a frequent and
recurring basis’’ the derivatives contract
when pricing forward, fixed-price
commitments or other cash-settled
derivatives that seek to ‘‘lock in’’ a fixed
price for some future point in time to
hedge against adverse price movements.
PJM’s Western hub is a major trading
center for electricity in the eastern
United States. Traders, including
producers, keep abreast of the prices of
the OPJ contract when conducting cash
deals. These traders look to a
competitively determined price as an
indication of expected values of
electricity at the Western hub when
entering into cash market transaction for
power, especially those trades that
provide for physical delivery in the
future. Traders use the ICE OPJ contract
to hedge cash market positions and
transactions, which enhances the OPJ
contract’s price discovery utility. While
the OPJ contract’s settlement prices may
not be the only factor influencing spot
and forward transactions, power traders
consider the ICE price to be a crucial
factor in conducting OTC transactions.
In addition, EPSA stated that the
publication of price data for the OPJ
contract price is weak justification for
material price reference. Market
participants generally do not purchase
ICE data sets for one contract’s prices.
Instead, traders are interested in the
settlement prices, so the fact that ICE
sells the OPJ prices as part of a broad
package is not conclusive evidence that
market participants are buying the ICE
data sets because the OPJ prices have
substantial value to them. The
Commission notes that publication of
the OPJ contract’s prices is indirect
evidence of routine dissemination.
Thus, the Commission has concluded
that traders likely specifically purchase
the ICE data packages for the OPJ
contract’s prices and consult such prices
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on a frequent and recurring basis in
pricing cash market transactions.
Lastly, ICE and EEI criticized the
Commission’s reliance on the ECM
Study since it did not specifically
identify the OPJ contract as a contract
that is referred to by market participants
on a frequent and recurring basis. The
Commission notes that it cited the ECM
Study’s general finding that some ICE
electricity contracts appear to be
regarded as price discovery markets
merely as indication that an
investigation of certain ICE contracts
may be warranted. The ECM Study was
not intended to serve as the sole basis
for determining whether or not a
particular contract meets the material
price reference criterion.
ii. Conclusion Regarding Material
Price Reference:
The Commission finds that the ICE
OPJ contract meets the material price
reference criterion because cash market
transactions are priced either explicitly
or implicitly on a frequent and recurring
basis at a differential to the OPJ
contract’s price (direct evidence).
Moreover, the OPJ contract’s price data
are sold to market participants, and
those individuals likely purchase the
ICE data packages specifically for the
OPJ contract’s prices and consult such
prices on a frequent and recurring basis
in pricing cash market transactions
(indirect evidence).
2. Material Liquidity Criterion
As noted above, in its October 26,
2009, Federal Register notice, the
Commission identified the OJP contract
as a potential SPDC based on the
material price reference and material
liquidity criteria. To assess whether a
contract meets the material liquidity
criterion, the Commission first examines
trading activity as a general
measurement of the contract’s size and
potential importance. If the Commission
finds that the contract in question meets
a threshold of trading activity that
would render it of potential importance,
the Commission will then perform a
statistical analysis to measure the effect
that changes to the subject-contract’s
prices potentially may have on prices
for other contracts listed on an ECM or
a DCM.
The Commission’s Guidance
(Appendix A to Part 36) notes that
‘‘[t]raditionally, objective measures of
trading such as volume or open interest
have been used as measures of
liquidity.’’ in this regard, the total
number of transactions executed on
ICE’s electronic platform in the OPJ
contract was 437 in the second quarter
of 2009, resulting in a daily average of
6.8 trades. During the same period, the
PO 00000
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Fmt 4703
Sfmt 4703
42397
OPJ contract had a total trading volume
of 325,799 contracts and an average
daily trading volume of 5,090.6
contracts. Moreover, open interest as of
June 30, 2009, was 2,976,492 contracts,
which included trades executed on
ICE’s electronic trading platform, as
well as trades executed off of ICE’s
electronic trading platform and then
brought to ICE for clearing. In this
regard, ICE does not differentiate
between open interest created by a
transaction executed on its trading
platform and that created by a
transaction executed off its trading
platform.37
In a subsequent filing dated March 24,
2010, ICE reported that total trading
volume in the fourth quarter of 2009
was 622,984 contracts (or 9,584.4
contracts on a daily basis). In terms of
number of transactions, 456 trades
occurred in the fourth quarter of 2009
(7.0 trades per day). As of December 31,
2009, open interest in the OPJ contract
was 3,293,899 contracts, which
included trades executed on ICE’s
electronic trading platform, as well as
trades executed off of ICE’s electronic
trading platform and then brought to
ICE for clearing.
The number of trades per day was
substantial during the period between
the second and fourth quarters of 2009.
In addition, trading activity in the OPJ
contract, as characterized by total
quarterly volume, indicates that the OPJ
contract experiences trading activity
that is greater than that of thinly-traded
futures markets.38 Thus, it is reasonable
to infer that the OPJ contract could have
a material effect on other ECM contracts
or on DCM contracts.
To measure the effect that the PJM
contract could have on another ECM
contract staff performed a statistical
analysis 39 using daily settlement prices
37 74
FR 54966 (October 26, 2009).
has advised the Commission that in its
experience, a thinly-traded contract is, generally,
one that has a quarterly trading volume of 100,000
contracts or less. In this regard, in the third quarter
of 2009, physical commodity futures contracts with
trading volume of 100,000 contracts or fewer
constituted less than one percent of total trading
volume of all physical commodity futures contracts.
39 Specifically, Commission staff econometrically
estimated a cointegrated vector autoregression
(CVAR) model using daily settlement prices. CVAR
methods permit a dichotomization of the data
relationships into long run equilibrium components
(called the cointegration space or cointegrating
relationships) and a short run component. A CVAR
model was chosen over the more traditional vector
autoregression model in levels because the
statistical properties of the data (lack of stationarity
and ergodicity) precluded the more traditional
modeling treatment. Moreover, the statistical
properties of the data necessitated the modeling of
the contracts’ prices as a CVAR model containing
both first differences (to handle stationarity) and an
38 Staff
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erowe on DSKG8SOYB1PROD with NOTICES
(between July 1, 2008 and December 31,
2009) for the ICE PJM and OPJ contracts.
The simulation suggests that, on average
over the sample period, a one percent
rise in the OPJ contract’s price elicited
a 0.47 percent increase in ICE PJM
contract’s price.
i. Federal Register Comments:
ICE stated that the OPJ contract lacks
a sufficient number of trades to meet the
material liquidity criterion. Along with
EPSA and EEI, ICE argued that the OPJ
contract cannot have a material effect on
DCM contracts or other ECM contracts
because these other contracts do not
cash settle to the OPJ contract’s price.
Instead, the DCM contracts and the OPJ
contract are both cash settled based on
physical transactions, which neither the
ECM nor the DCM contracts can
influence. On the contrary, the
Commission’s statistical analysis shows
that changes in the ICE OPJ contract’s
price significantly influences the prices
of other ECM contracts (namely, the PJM
contract). In this regard, a one-percent
rise in the OPJ contract’s price leads to
a 0.47 percent rise in PJM contract’s
price.
ICE noted that the Commission’s
Guidance had posited concepts of
liquidity that generally assumed a fairly
constant stream of prices throughout the
trading day, and noted that the
relatively low number of trades per day
in the OPJ contract did not meet this
standard of liquidity. The Commission
observes that a continuous stream of
prices would indeed be an indication of
liquidity for certain markets but the
Guidance also notes that ‘‘quantifying
the levels of immediacy and price
concession that would define material
liquidity may differ from one market or
commodity to another.’’ 40
ICE opined that the Commission
‘‘seems to have adopted a five trade per
day test for material liquidity.’’ To the
contrary, the Commission adopted a five
trades-per-day threshold as a reporting
requirement to enable it to
‘‘independently be aware of ECM
contracts that may develop into
SPDCs’’ 41 rather than solely relying
upon an ECM on its own to identify any
such potential SPDCs to the
Commission. Thus, any contract that
meets this threshold may be subject to
error-correction term to capture long run
equilibrium relationships. The prices were treated
as a single reduced-form model in order to test
hypothesis that power prices in the same market
affect each other. The prices of ICE’s PJM and OPJ
contracts are positively related to each other in a
cointegrating relationship and display a high level
of statistical strength. On average during the sample
period, each percentage rise in OPJ contract’s price
elicited a 0.47 percent rise in PJM contract’s price.
40 Guidance, supra.
41 73 FR 75892 (December 12, 2008).
VerDate Mar<15>2010
15:19 Jul 20, 2010
Jkt 220001
scrutiny as a potential SPDC; however,
the contract will not be found to be a
SPDC merely because it met the
reporting threshold.
ICE also argued that the statistics
provided by ICE were misinterpreted
and misapplied by the Commission. In
particular, ICE stated that the volume
figures used in the Commission’s
analysis (cited above) ‘‘include trades
made in all months’’ as well as in strips
of contract months. ICE suggested that a
more appropriate method of
determining liquidity is to examine the
activity in a single traded month of a
given contract.’’ 42 It is the Commission’s
opinion that liquidity, as it pertains to
the OPJ contract, is typically a function
of trading activity in particular lead
months and, given sufficient liquidity in
such months, the ICE OPJ contract itself
would be considered liquid. ICE’s
analysis of its own trade data confirms
this to be the case for the OPJ contract,
and thus, the Commission believes that
it applied the statistical data cited above
in an appropriate manner for gauging
material liquidity.
ii. Conclusion Regarding Material
Liquidity:
For the reasons discussed above, the
Commission finds that the OPJ contract
satisfies the material liquidity criterion.
Specifically, there is sufficient trading
activity in the OPJ contract to have a
material effect on ‘‘other agreements,
contracts or transactions listed for
trading on or subject to the rules of a
designated contract market * * * or an
electronic trading facility operating in
reliance on the exemption in section
2(h)(3) of the Act’’ (that is, an ECM).
42 In addition, ICE stated that the trades-per-day
statistics that it provided to the Commission in its
quarterly filing and which were cited in the
Commission’s October 26, 2009, Federal Register
notice includes 2(h)(1) transactions, which were not
completed on the electronic trading platform and
should not be considered in the SPDC
determination process. The Commission staff asked
ICE to review the data it sent in its quarterly filings;
ICE confirmed that the volume data it provided and
which the Commission cited includes only
transaction data executed on ICE’s electronic
trading platform. As noted above, supplemental
data supplied by ICE confirmed that block trades
are in addition to the trades that were conducted
on the electronic platform; block trades comprise
about 72 percent of all transactions in the OPJ
contract (as of the fourth quarter of 2009).
Commission acknowledges that the open interest
information it provided in its October 26, 2009,
Federal Register notice includes transactions made
off the ICE platform. However, once open interest
is created, there is no way for ICE to differentiate
between ‘‘on-exchange’’ versus ‘‘off-exchange’’
created positions, and all such positions are
fungible with one another and may be offset in any
way agreeable to the position holder regardless of
how the position was initially created.
PO 00000
Frm 00025
Fmt 4703
Sfmt 4703
3. Overall Conclusion Regarding the OPJ
Contract
After considering the entire record in
this matter, including the comments
received, the Commission has
determined that the ICE OPJ contract
performs a significant price discovery
function under the two of the four
criteria established in section 2(h)(7) of
the CEA. Specifically, the Commission
has determined that the OPJ contract
meets the material price reference and
material liquidity criteria. Accordingly,
the Commission is issuing the attached
Order declaring that the PJM contract is
a SPDC.
Issuance of this Order signals the
immediate effectiveness of the
Commission’s authorities with respect
to ICE as a registered entity in
connection with its OPJ contract,43 and
triggers the obligations, requirements—
both procedural and substantive—and
timetables prescribed in Commission
rule 36.3(c)(4) for ECMs.
V. Related Matters
a. Paperwork Reduction Act
The Paperwork Reduction Act of 1995
(‘‘PRA’’) 44 imposes certain requirements
on Federal agencies, including the
Commission, in connection with their
conducting or sponsoring any collection
of information as defined by the PRA.
Certain provisions of Commission rule
36.3 impose new regulatory and
reporting requirements on ECMs,
resulting in information collection
requirements within the meaning of the
PRA. OMB previously has approved and
assigned OMB control number 3038–
0060 to this collection of information.
b. Cost-Benefit Analysis
Section 15(a) of the CEA 45 requires
the Commission to consider the costs
and benefits of its actions before issuing
an order under the Act. By its terms,
section 15(a) does not require the
Commission to quantify the costs and
benefits of an order or to determine
whether the benefits of the order
outweigh its costs; rather, it requires
that the Commission ‘‘consider’’ the
costs and benefits of its actions. Section
15(a) further specifies that the costs and
benefits shall be evaluated in light of
five broad areas of market and public
concern: (1) Protection of market
participants and the public; (2)
efficiency, competitiveness and
financial integrity of futures markets; (3)
price discovery; (4) sound risk
management practices; and (5) other
43 See
73 FR 75888, 75893 (Dec. 12, 2008).
U.S.C. 3507(d).
45 7 U.S.C. 19(a).
44 44
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Federal Register / Vol. 75, No. 139 / Wednesday, July 21, 2010 / Notices
public interest considerations. The
Commission may in its discretion give
greater weight to any one of the five
enumerated areas and could in its
discretion determine that,
notwithstanding its costs, a particular
order is necessary or appropriate to
protect the public interest or to
effectuate any of the provisions or
accomplish any of the purposes of the
Act.
When a futures contract begins to
serve a significant price discovery
function, that contract, and the ECM on
which it is traded, warrants increased
oversight to deter and prevent price
manipulation or other disruptions to
market integrity, both on the ECM itself
and in any related futures contracts
trading on DCMs. An Order finding that
a particular contract is a SPDC triggers
this increased oversight and imposes
obligations on the ECM calculated to
accomplish this goal. The increased
oversight engendered by the issue of a
SPDC Order increases transparency and
helps to ensure fair competition among
ECMs and DCMs trading similar
products and competing for the same
business. Moreover, the ECM on which
the SPDC is traded must assume, with
respect to that contract, all the
responsibilities and obligations of a
registered entity under the CEA and
Commission regulations. Additionally,
the ECM must comply with nine core
principles established by section 2(h)(7)
of the Act—including the obligation to
establish position limits and/or
accountability standards for the SPDC.
Section 4(i) of the CEA authorize the
Commission to require reports for
SPDCs listed on ECMs. These increased
responsibilities, along with the CFTC’s
increased regulatory authority, subject
the ECM’s risk management practices to
the Commission’s supervision and
oversight and generally enhance the
financial integrity of the markets.
erowe on DSKG8SOYB1PROD with NOTICES
c. Regulatory Flexibility Act
The Regulatory Flexibility Act
(‘‘RFA’’) 46 requires that agencies
consider the impact of their rules on
small businesses. The requirements of
CEA section 2(h)(7) and the Part 36
rules affect ECMs. The Commission
previously has determined that ECMs
are not small entities for purposes of the
RFA.47 Accordingly, the Chairman, on
behalf of the Commission, hereby
certifies pursuant to 5 U.S.C. 605(b) that
these Orders, taken in connection with
section 2(h)(7) of the Act and the Part
36 rules, will not have a significant
46 5
U.S.C. 601 et seq.
FR 42256, 42268 (Aug. 10, 2001).
47 66
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15:19 Jul 20, 2010
Jkt 220001
impact on a substantial number of small
entities.
VI. Orders
a. Order Relating to the PJM WH Real
Time Peak Contract
After considering the complete record
in this matter, including the comment
letters received in response to its
request for comments, the Commission
has determined to issue the following
Order:
The Commission, pursuant to its
authority under section 2(h)(7) of the
Act, hereby determines that the PJM WH
Real Time Peak contract, traded on the
IntercontinentalExchange, Inc., satisfies
the material price preference and
material liquidity criteria for significant
price discovery contracts. Consistent
with this determination, and effective
immediately, the
IntercontinentalExchange, Inc., must
comply with, with respect to the PJM
WH Real Time Peak contract, the nine
core principles established by new
section 2(h)(7)(C). Additionally, the
IntercontinentalExchange, Inc., shall be
and is considered a registered entity 48
with respect to the PJM WH Real Time
Peak contract and is subject to all the
provisions of the Commodity Exchange
Act applicable to registered entities.
Further with respect to the PJM WH
Real Time Peak contract, the
obligations, requirements and timetables
prescribed in Commission rule
36.3(c)(4) governing core principle
compliance by the
IntercontinentalExchange, Inc.,
commence with the issuance of this
Order.49
b. Order Relating to the PJM WH Real
Time Off-Peak Contract
After considering the complete record
in this matter, including the comment
letters received in response to its
request for comments, the Commission
has determined to issue the following
Order:
The Commission, pursuant to its
authority under section 2(h)(7) of the
Act, hereby determines that the PJM WH
Real Time Off-Peak contract, traded on
the IntercontinentalExchange, Inc.,
satisfies the statutory material price
reference and material liquidity criteria
for significant price discovery contracts.
Consistent with this determination, and
effective immediately, the
U.S.C. 1a(29).
ICE already lists for trading a contract
(i.e., the Henry Financial LD1 Fixed Price contract)
that was previously declared by the Commission to
be a SPDC, ICE must submit a written
demonstration of compliance with the Core
Principles within 30 calendar days of the date of
this Order. 17 CFR 36.3(c)(4).
PO 00000
48 7
49 Because
Frm 00026
Fmt 4703
Sfmt 4703
42399
IntercontinentalExchange, Inc., must
comply with, with respect to the PJM
WH Real Time Off-Peak contract, the
nine core principles established by new
section 2(h)(7)(C). Additionally, the
IntercontinentalExchange, Inc., shall be
and is considered a registered entity 50
with respect to the PJM WH Real Time
Off-Peak contract and is subject to all
the provisions of the Commodity
Exchange Act applicable to registered
entities.
Further with respect to the PJM WH
Real Time Off-Peak contract, the
obligations, requirements and timetables
prescribed in Commission rule
36.3(c)(4) governing core principle
compliance by the
IntercontinentalExchange, Inc.,
commence with the issuance of this
Order.51
Issued in Washington, DC, on July 9, 2010,
by the Commission.
David A. Stawick,
Secretary of the Commission.
[FR Doc. 2010–17743 Filed 7–20–10; 8:45 am]
BILLING CODE 6351–01–P
COMMODITY FUTURES TRADING
COMMISSION
Orders Finding That the PJM WH Real
Time Peak Daily Contract, PJM WH
Real Time Off-Peak Daily Contract and
PJM WH Day Ahead LMP Peak Daily
Contract Offered for Trading on the
IntercontinentalExchange, Inc., Do Not
Perform a Significant Price Discovery
Function
Commodity Futures Trading
Commission.
ACTION: Final orders.
AGENCY:
On October 26, 2009, the
Commodity Futures Trading
Commission (‘‘CFTC’’ or ‘‘Commission’’)
published for comment in the Federal
Register 1 a notice of its intent to
undertake a determination whether the
PJM 2 WH 3 Real Time Peak Daily
SUMMARY:
50 7
U.S.C. 1a(29).
ICE already lists for trading a contract
(i.e., the Henry Financial LD1 Fixed Price contract)
that was previously declared by the Commission to
be a SPDC, ICE must submit a written
demonstration of compliance with the Core
Principles within 30 calendar days of the date of
this Order. 17 CFR 36.3(c)(4).
1 74 FR 54966 (October 26, 2009).
2 The acronym ‘‘PJM’’ stands for Pennsylvania
New Jersey Maryland Interconnection, LLC (‘‘PJM
Interconnection’’), and signifies the regional
electricity transmission organization (‘‘RTO’’) that
coordinates the generation and distribution of
electricity in all or parts of 13 states and the District
of Columbia.
3 The acronym ‘‘WH’’ signifies the PJM
Interconnection’s Western Hub.
51 Because
E:\FR\FM\21JYN1.SGM
21JYN1
Agencies
[Federal Register Volume 75, Number 139 (Wednesday, July 21, 2010)]
[Notices]
[Pages 42390-42399]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-17743]
-----------------------------------------------------------------------
COMMODITY FUTURES TRADING COMMISSION
Orders Finding That the PJM WH Real Time Peak Contract and PJM WH
Real Time Off-Peak Contract Offered for Trading on the
IntercontinentalExchange, Inc., Perform a Significant Price Discovery
Function
AGENCY: Commodity Futures Trading Commission.
ACTION: Final orders.
-----------------------------------------------------------------------
SUMMARY: On October 26, 2009, the Commodity Futures Trading Commission
(``CFTC'' or ``Commission'') published for comment in the Federal
Register \1\ a notice of its intent to undertake a determination
whether the PJM \2\ WH \3\ Real Time Peak (``PJM'') contract and PJM WH
Real Time Off-Peak (``OPJ'') contract,\4\ which are listed for trading
on the IntercontinentalExchange, Inc. (``ICE''), an exempt commercial
market (``ECM'') under sections 2(h)(3)-(5) of the Commodity Exchange
Act (``CEA'' or the ``Act''), perform a significant price discovery
function pursuant to section 2(h)(7) of the CEA. The Commission
undertook this review based upon an initial evaluation of information
and data provided by ICE as well as other available information. The
Commission has reviewed the entire record in this matter, including all
comments received, and has determined to issue orders finding that the
PJM and OPJ contracts perform a significant price discovery function.
Authority for this action is found in section 2(h)(7) of the CEA and
Commission rule 36.3(c) promulgated thereunder.
---------------------------------------------------------------------------
\1\ 74 FR 54966 (October 26, 2009).
\2\ The acronym ``PJM'' stands for Pennsylvania New Jersey
Maryland Interconnection, LLC (``PJM Interconnection''), and
signifies the regional electricity transmission organization
(``RTO'') that coordinates the generation and distribution of
electricity in all or parts of 13 states and the District of
Columbia.
\3\ The acronym ``WH'' signifies the PJM's Western Hub.
\4\ The Federal Register notice also requested comment on the
PJM WH Real Time Peak Daily (``PDP'') contract, PJM WH Day Ahead LMP
Peak Daily (``PDA'') contract and PJM WH Real Time Off-Peak Daily
(``ODP'') contract. Those contracts will be addressed in a separate
Federal Register release.
---------------------------------------------------------------------------
DATES: Effective Date: July 9, 2010.
FOR FURTHER INFORMATION CONTACT: Gregory K. Price, Industry Economist,
Division of Market Oversight, Commodity Futures Trading Commission,
Three Lafayette Centre, 1155 21st Street, NW., Washington, DC 20581.
Telephone: (202) 418-5515. E-mail: gprice@cftc.gov; or Susan Nathan,
Senior Special Counsel, Division of Market Oversight, same address.
Telephone: (202) 418-5133. E-mail: snathan@cftc.gov.
SUPPLEMENTARY INFORMATION:
I. Introduction
The CFTC Reauthorization Act of 2008 (``Reauthorization Act'') \5\
significantly broadened the CFTC's regulatory authority with respect to
ECMs by creating, in section 2(h)(7) of the CEA, a new regulatory
category--ECMs on which significant price discovery contracts
(``SPDCs'') are traded--and treating ECMs in that category as
registered entities under the CEA.\6\ The legislation authorizes the
CFTC to designate an agreement, contract or transaction as a SPDC if
the Commission determines, under criteria established in section
2(h)(7), that it performs a significant price discovery function. When
the Commission makes such a determination, the ECM on which the SPDC is
traded must assume, with respect to that contract, all the
responsibilities and obligations of a registered entity under the Act
and Commission regulations, and must comply with nine core principles
established by new section 2(h)(7)(C).
---------------------------------------------------------------------------
\5\ Incorporated as Title XIII of the Food, Conservation and
Energy Act of 2008, Public Law No. 110-246, 122 Stat. 1624 (June 18,
2008).
\6\ 7 U.S.C. 1a(29).
---------------------------------------------------------------------------
On March 16, 2009, the CFTC promulgated final rules implementing
the provisions of the Reauthorization Act.\7\ As relevant here, rule
36.3
[[Page 42391]]
imposes increased information reporting requirements on ECMs to assist
the Commission in making prompt assessments whether particular ECM
contracts may be SPDCs. In addition to filing quarterly reports of its
contracts, an ECM must notify the Commission promptly concerning any
contract traded in reliance on the exemption in section 2(h)(3) of the
CEA that averaged five trades per day or more over the most recent
calendar quarter, and for which the exchange sells its price
information regarding the contract to market participants or industry
publications, or whose daily closing or settlement prices on 95 percent
or more of the days in the most recent quarter were within 2.5 percent
of the contemporaneously determined closing, settlement or other daily
price of another contract.
---------------------------------------------------------------------------
\7\ 74 FR 12178 (Mar. 23, 2009); these rules became effective on
April 22, 2009.
---------------------------------------------------------------------------
Commission rule 36.3(c)(3) established the procedures by which the
Commission makes and announces its determination whether a particular
ECM contract serves a significant price discovery function. Under those
procedures, the Commission will publish notice in the Federal Register
that it intends to undertake an evaluation whether the specified
agreement, contract or transaction performs a significant price
discovery function and to receive written views, data and arguments
relevant to its determination from the ECM and other interested
persons. Upon the close of the comment period, the Commission will
consider, among other things, all relevant information regarding the
subject contract and issue an order announcing and explaining its
determination whether or not the contract is a SPDC. The issuance of an
affirmative order signals the effectiveness of the Commission's
regulatory authorities over an ECM with respect to a SPDC; at that time
such an ECM becomes subject to all provisions of the CEA applicable to
registered entities.\8\ The issuance of such an order also triggers the
obligations, requirements and timetables prescribed in Commission rule
36.3(c)(4).\9\
---------------------------------------------------------------------------
\8\ Public Law 110-246 at 13203; Joint Explanatory Statement of
the Committee of Conference, H.R. Rep. No. 110-627, 110 Cong., 2d
Sess. 978, 986 (Conference Committee Report). See also 73 FR 75888,
75894 (Dec. 12, 2008).
\9\ For an initial SPDC, ECMs have a grace period of 90 calendar
days from the issuance of a SPDC determination order to submit a
written demonstration of compliance with the applicable core
principles. For subsequent SPDCs, ECMs have a grace period of 30
calendar days to demonstrate core principle compliance.
---------------------------------------------------------------------------
II. Notice of Intent To Undertake SPDC Determination
On October 26, 2009, the Commission published in the Federal
Register notice of its intent to undertake a determination whether the
PJM and OPJ contracts \10\ perform a significant price discovery
function and requested comment from interested parties.\11\ Comments
were received from PJM Interconnection, Federal Energy Regulatory
Commission (``FERC''), Electric Power Supply Association (``EPSA''),
Financial Institutions Energy Group (``FIEG''), Edison Electric
Institute (``EEI''), ICE and Public Utility Commission of Texas
(``PUCT'').\12\ The comment letters from PJM Interconnection,\13\
FERC\14\ and PUCT did not directly address the issue of whether or not
the subject contracts are SPDCs. The remaining comment letters raised
substantive issues with respect to the applicability of section 2(h)(7)
to the subject contracts and generally expressed the opinion that the
contracts are not SPDCs because they do not meet the material price
reference or material liquidity criteria for SPDC determination. These
comments are more extensively discussed below, as applicable.
---------------------------------------------------------------------------
\10\ As noted above, the Federal Register notice also requested
comment on the PJM WH Real Time Peak Daily (``PDP'') contract, PJM
WH Day Ahead LMP Peak Daily (``PDA'') contract and PJM WH Real Time
Off-Peak Daily (``ODP'') contract. Those contracts will be addressed
in a separate Federal Register release.
\11\ The Commission's Part 36 rules establish, among other
things, procedures by which the Commission makes and announces its
determination whether a specific ECM contract serves a significant
price discovery function. Under those procedures, the Commission
publishes a notice in the Federal Register that it intends to
undertake a determination whether a specified agreement, contract or
transaction performs a significant price discovery function and to
receive written data, views and arguments relevant to its
determination from the ECM and other interested persons.
\12\ PJM Interconnection, as noted above, is the RTO that
coordinates the generation and distribution of electricity in all or
parts of 13 states and the District of Columbia. FERC is an
independent federal regulatory agency that, among other things,
regulates the interstate transmission of natural gas, oil and
electricity. EPSA describes itself as the ``national trade
association representing competitive power suppliers, including
generators and marketers.'' FIEG describes itself as an association
of investment and commercial banks who are active participants in
various sectors of the natural gas markets, ``including acting as
marketers, lenders, underwriters of debt and equity securities, and
proprietary investors.'' EEI is the ``association of shareholder-
owned electric companies, international affiliates and industry
associates worldwide.'' ICE is an ECM, as noted above. PUCT is the
independent organization that oversees the Electric Reliability
Council of Texas (``ERCOT'') to ``ensure nondiscriminatory access to
the transmission and distribution systems, to ensure the reliability
and adequacy of the regional electrical network, and to perform
other essential market functions.'' The comment letters are
available on the Commission's Web site: https://www.cftc.gov/lawandregulation/federalregister/federalregistercomments/2009/09-032.html.
\13\ PJM Interconnection stated that it ``takes no position as
to whether the ICE [contracts] * * * perform significant price
discovery functions.''
\14\ FERC expressed the opinion that a determination by the
Commission that any of the subject contracts performs a significant
price discovery function ``would not appear to conflict with FERC's
exclusive jurisdiction under the Federal Power Act (FPA) over the
transmission or sale for resale of electric energy in interstate
commerce or with its other regulatory responsibilities under the
FPA'' and further that ``FERC staff will monitor proposed SPDC
determinations and advise the CFTC of any potential conflicts with
FERC's exclusive jurisdiction over RTOs, [(regional transmission
organizations)], ISOs [(independent system operators)] or other
jurisdictional entities.''
---------------------------------------------------------------------------
III. Section 2(h)(7) of the CEA
The Commission is directed by section 2(h)(7) of the CEA to
consider the following criteria in determining a contract's significant
price discovery function:
Price Linkage--the extent to which the agreement, contract
or transaction uses or otherwise relies on a daily or final settlement
price, or other major price parameter, of a contract or contracts
listed for trading on or subject to the rules of a designated contract
market (``DCM'') or derivatives transaction execution facility
(``DTEF''), or a SPDC traded on an electronic trading facility, to
value a position, transfer or convert a position, cash or financially
settle a position, or close out a position.
Arbitrage--the extent to which the price for the
agreement, contract or transaction is sufficiently related to the price
of a contract or contracts listed for trading on or subject to the
rules of a DCM or DTEF, or a SPDC traded on or subject to the rules of
an electronic trading facility, so as to permit market participants to
effectively arbitrage between the markets by simultaneously maintaining
positions or executing trades in the contracts on a frequent and
recurring basis.
Material price reference--the extent to which, on a
frequent and recurring basis, bids, offers or transactions in a
commodity are directly based on, or are determined by referencing or
consulting, the prices generated by agreements, contracts or
transactions being traded or executed on the electronic trading
facility.
Material liquidity--the extent to which the volume of
agreements, contracts or transactions in a commodity being traded on
the electronic trading facility is sufficient to have a material effect
on other agreements, contracts or transactions
[[Page 42392]]
listed for trading on or subject to the rules of a DCM, DTEF or
electronic trading facility operating in reliance on the exemption in
section 2(h)(3).
Not all criteria must be present to support a determination that a
particular contract performs a significant price discovery function,
and one or more criteria may be inapplicable to a particular
contract.\15\ Moreover, the statutory language neither prioritizes the
criteria nor specifies the degree to which a SPDC must conform to the
various criteria. In Guidance issued in connection with the Part 36
rules governing ECMs with SPDCs, the Commission observed that these
criteria do not lend themselves to a mechanical checklist or formulaic
analysis. Accordingly, the Commission has indicated that in making its
determinations it will consider the circumstances under which the
presence of a particular criterion, or combination of criteria, would
be sufficient to support a SPDC determination.\16\ For example, for
contracts that are linked to other contracts or that may be arbitraged
with other contracts, the Commission will consider whether the price of
the potential SPDC moves in such harmony with the other contract that
the two markets essentially become interchangeable. This co-movement of
prices would be an indication that activity in the contract had reached
a level sufficient for the contract to perform a significant price
discovery function. In evaluating a contract's price discovery role as
a price reference, the Commission the extent to which, on a frequent
and recurring basis, bids, offers or transactions are directly based
on, or are determined by referencing, the prices established for the
contract.
---------------------------------------------------------------------------
\15\ In its October 26, 2009, Federal Register release, the
Commission identified material price reference and material
liquidity as the possible criteria for SPDC determination of the PJM
and OPJ contracts. Arbitrage and price linkage were not identified
as possible criteria. As a result, arbitrage and price linkage will
not be discussed further in this document and the associated Orders.
\16\ 17 CFR 36, Appendix A.
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IV. Findings and Conclusions
The Commission's findings and conclusions with respect to the PJM
and OPJ contracts are discussed separately below.
a. The PJM WH Real Time Peak (PJM) Contract and the SPDC Indicia
The PJM contract is cash settled based on the arithmetic average of
peak-hour, real-time locational marginal prices (``LMPs'') \17\
published by PJM Interconnection for its Western Hub for all peak hours
during the contract month. The hourly LMPs are derived from power
trades that result in physical delivery. The size of the PJM contract
is 800 megawatt hours (``MWh''), and the PJM contract is listed for 110
calendar months.
---------------------------------------------------------------------------
\17\ An LMP represents the additional cost associated with
producing an incremental amount of electricity. LMPs account for
generation costs, congestion along the transmission lines, and
electricity loss.
---------------------------------------------------------------------------
In general, electricity is bought and sold in an auction setting on
an hourly basis at various point along the electrical grid. An LMP
associated with a specific hour is calculated as the volume-weighted
average price of all of the transactions where electricity is to be
supplied and consumed during that hour.
Electricity is traded in a day-ahead market as well as a real-time
market. The day-ahead market establishes prices for electricity that is
to be delivered during the specified hour on the following day. Day-
ahead prices are determined based on generation and energy transaction
quotes offered in advance. Because the offers and bids are dependent on
estimates of supply and demand, electricity needs usually are not
perfectly satisfied in the day-ahead market. In this regard, on the day
the electricity is transmitted and used, auction participants typically
realize that they bought or sold either too much power or too little
power. A real-time auction is operated to alleviate this problem by
serving as a balancing mechanism. Specifically, electricity traders use
the real-time market to sell excess electricity and buy additional
power to meet demand.
PJM Interconnection is an RTO that coordinates the movement of
wholesale electricity in all or parts of Delaware, Illinois, Indiana,
Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio,
Pennsylvania, Tennessee, Virginia, West Virginia and the District of
Columbia. PJM Interconnection's transmission network is the largest
centrally-dispatched grid in North America. PJM Interconnection
dispatches about 163,500 MW of generating capacity over 56,350 miles of
transmission lines and serves more than 51 million customers. The RTO's
members, totaling more than 500, include power generators, transmission
owners, electricity distributors, power marketers and large consumers.
PJM Interconnection is responsible for operating a competitive
wholesale electricity market as well as maintaining the reliability of
the grid. The RTO acts as a neutral, independent party, and its
activities are regulated by FERC. The company coordinates the
continuous buying, selling and delivery of wholesale electricity
through robust, open and competitive spot markets. In operating the
markets, PJM balances the needs of suppliers, wholesale customers and
other market participants, and it continuously monitors market
behavior.
Electricity is priced at individual points along the transmission
network called nodes. An electric grid has many interconnections or
buses. RTOs group certain buses together to form hubs, which do not
necessarily follow along state lines or geographic boundaries. Power
also is priced at the hub level and serves as a basis for trading
electricity. PJM Interconnnection has 11 hubs, including AEP GEN, AEP-
Dayton, Chicago GEN, Chicago, Dominion, Eastern, Northern Illinois, New
Jersey, Ohio, West INT and Western Hub.\18\ The Western Hub is basket
of 109 buses that stretch all the way from Erie, PA, to Washington,
DC.\19\
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\18\ https://www.ferc.gov/market-oversight/mkt-electric/pjm.asp.
\19\ https://www.ferc.gov/market-oversight/mkt-electric/pjm/2010/05-2010-elec-pjm-archive.pdf.
---------------------------------------------------------------------------
1. Material Price Reference Criterion
The Commission's October 26, 2009, Federal Register notice
identified the PJM contract as a potential SPDC based on the material
price reference and material liquidity criteria. The Commission
considered the fact that ICE sells its price data to market
participants in a number of different packages which vary in terms of
the hubs covered, time periods, and whether the data are daily only or
historical. For example, ICE offers the ``East Power of Day'' package
with access to all price data or just current prices plus a selected
number of months (i.e., 12, 24, 36 or 48 months) of historical data.
This package includes price data for the PJM contract.
The Commission also noted that its October 2007 Report on the
Oversight of Trading on Regulated Futures Exchanges and Exempt
Commercial Markets (``ECM Study'') found that in general, market
participants view ICE as a price discovery market for certain
electricity contracts. The study did not specify which markets
performed this function; nevertheless, the Commission determined that
the PJM contract, while not mentioned by name in the ECM Study,
warranted further review.
The Commission explains in its Guidance to the statutory criteria
that in evaluating a contract under the material price reference
criterion, it will rely on one of two sources of evidence--direct or
indirect--to determine that the price of a contract was being used as a
[[Page 42393]]
material price reference and therefore, serving a significant price
discovery function.\20\ With respect to direct evidence, the Commission
will consider the extent to which, on a frequent and recurring basis,
cash market bids, offers or transactions are directly based on or
quoted at a differential to, the prices generated on the ECM in
question. Direct evidence may be established when cash market
participants are quoting bid or offer prices or entering into
transactions at prices that are set either explicitly or implicitly at
a differential to prices established for the contract in question. Cash
market prices are set explicitly at a differential to the section
2(h)(3) contract when, for instance, they are quoted in dollars and
cents above or below the reference contract's price. Cash market prices
are set implicitly at a differential to a section 2(h)(3) contract
when, for instance, they are arrived at after adding to, or subtracting
from the section 2(h)(3) contract, but then quoted or reported at a
flat price. With respect to indirect evidence, the Commission will
consider the extent to which the price of the contract in question is
being routinely disseminated in widely distributed industry
publications--or offered by the ECM itself for some form of
remuneration--and consulted on a frequent and recurring basis by
industry participants in pricing cash market transactions.
---------------------------------------------------------------------------
\20\ 17 CFR 36, Appendix A.
---------------------------------------------------------------------------
The PJM Western hub is a major pricing center for electricity in
the eastern portion of the United States. Traders, including producers,
keep abreast of the electricity prices at PJM's Western Hub when
conducting cash deals. These traders look to a competitively determined
price as an indication of expected values of power at the Western Hub
when entering into cash market transaction for electricity, especially
those trades providing for physical delivery in the future.
Furthermore, power prices in other neighboring markets, such as New
York ISO's Zone A (Western New York), Zone G (Hudson Valley region) and
Zone J (New York City) as well as Midwest ISO's Cinergy hub are
typically based implicitly relative to the prices reported for PJM
Interconnection's Western hub. Traders use the ICE PJM contract, as
well as other ICE power contracts, to hedge cash market positions and
transactions--activities which enhance the PJM contract's price
discovery utility. The substantial volume of trading and open interest
in the PJM contract appears to attest to its use for this purpose.
While the PJM contract's settlement prices may not be the only factor
influencing spot and forward transactions, electricity traders consider
the ICE price to be a critical factor in conducting OTC
transactions.\21\ In these circumstances, the PJM contract satisfies
the direct price reference test.
---------------------------------------------------------------------------
\21\ In addition to referencing ICE prices, firms participating
in PJM's Western hub power market may rely on other cash market
quotes as well as industry publications and price indices that are
published by third-party price reporting firms in entering into
power transactions.
---------------------------------------------------------------------------
The fact that ICE's PJM monthly contract is used more widely as a
source of pricing information than the daily contract (i.e., the
``PDP'' contract) \22\ bolsters the argument that it serves as a direct
price reference. In this regard, PJM contract prices power at the
Western hub up to almost ten years into the future. Thus, market
participants can use the PJM contract to lock in electricity prices far
into the future. Traders use monthly power contracts like the PJM
contract to price future power electricity commitments, where such
commitments are based on long-range forecasts of power supply and
demand. In contrast, the PDP contract is listed for a much shorter
length of time--up to 38 days in the future. As generation and usage
nears, market participants have a better understanding of actual power
supply and needs. As a result, they can modify previously-established
hedges with daily contracts, like the PDP contract.
---------------------------------------------------------------------------
\22\ The PDP contract is cash settled based on the arithmetic
average of peak-hour, real-time LMPs posted by PJM for the Western
hub for all peak hours on the day of generation. The LMPs are
derived from power trades that result in physical delivery. The size
of the SDP contract is 800 MWh, and the PDP contract is listed for
38 consecutive calendar days.
---------------------------------------------------------------------------
The Commission notes that the Western hub is a major trading point
for electricity, and that the PJM contract's prices are well regarded
in the industry as indicative of the value of power at the Western hub.
Accordingly, the Commission believes that it is reasonable to conclude
that market participants purchase the data packages that include the
PJM contract's prices in substantial part because the PJM contract's
prices have particular value to them. Moreover, such prices are
consulted on a frequent and recurring basis by industry participants in
pricing cash market transactions. In light of the above, the PJM
contract also meets the indirect price reference test.
The New York Mercantile Exchange (``NYMEX'') lists a futures
contract on its ClearPort platform-- the PJM Western Hub Peak Calendar-
Month Real-Time LMP Swap futures contract --that is comparable to the
ICE PJM contract. However, unlike the ICE contract, none of the trades
in the NYMEX version are executed in NYMEX's centralized marketplace;
instead, all of the transactions originate as bilateral swaps that are
submitted to NYMEX for clearing. The daily settlement prices of NYMEX's
monthly, peak-hour Western hub contract are influenced, in part, by the
daily settlement prices of the ICE PJM contract. NYMEX determines the
daily settlement prices for its power contracts through a survey of
cash market voice brokers. Voice brokers, in turn, refer to the ICE PJM
price, among other information, as an important indicator as to where
the market is trading. In this manner, the ICE PJM price influences the
settlement price for the NYMEX monthly, peak-hour Western hub power
contract. This conclusion is supported by an analysis of the daily
settlement prices for the PJM contract and the NYMEX equivalent which
indicates that 81 percent of the daily settlement prices \23\ for the
NYMEX version of the contract are within one standard deviation of the
PJM contract's price settlement prices.
---------------------------------------------------------------------------
\23\ The price data covered the period December 2008 through
December 2009.
---------------------------------------------------------------------------
i. Federal Register Comments:
EPSA, FIEG, EEI and ICE stated that no other contract directly
references or settles to the PJM contract's price. Moreover, the
commenters argued that the underlying cash price series against which
the PJM contract is settled \24\ is the authentic reference price and
not the ICE contract itself. Commission staff believes that this
interpretation of price reference is too narrow and believes that a
cash-settled derivatives contract could meet the price reference
criterion if market participants ``consult [the derivatives contract]
on a frequent and recurring basis'' when pricing forward, fixed-price
commitments or other cash-settled derivatives that seek to ``lock in''
a fixed price for some future point in time to hedge against adverse
price movements.
---------------------------------------------------------------------------
\24\ In this case, the average of the real-time peak-hour
Western hub electricity prices over the contract month, which are
derived from cash market transactions.
---------------------------------------------------------------------------
As noted above, PJM's Western hub is a major trading center for
electricity in the eastern United States. Traders, including producers,
keep abreast of the prices of the PJM contract when conducting cash
deals. These traders look to a competitively determined price as an
indication of expected values of electricity at the Western hub when
entering into cash market transaction for power, especially those
trades that provide for physical delivery in the future. Traders use
the ICE PJM
[[Page 42394]]
contract to hedge cash market positions and transactions, which
enhances the PJM contract's price discovery utility. While the PJM
contract's settlement prices may not be the only factor influencing
spot and forward transactions, natural gas traders consider the ICE
price to be a crucial factor in conducting OTC transactions.
In addition, EPSA stated that the publication of price data for the
PJM contract price is a weak justification for material price reference
because market participants generally do not purchase ICE data sets for
one contract's prices, such as those for the PJM contract. Instead,
traders are interested in the settlement prices, so the fact that ICE
sells the PJM prices as part of a broad package is not conclusive
evidence that market participants are buying the ICE data sets because
they find the PJM prices have substantial value. As noted above, the
Commission recognizes that publication of the PJM contract's prices is
indirect evidence of routine dissemination. Thus, the Commission has
concluded that traders likely purchase the ICE data packages
specifically for the PJM contract's prices and consult such prices on a
frequent and recurring basis in pricing cash market transactions.
Lastly, ICE and EEI criticized the ECM Study since it did not
specifically identify the PJM contract as a contract that is referred
to by market participants on a frequent and recurring basis. In
response, the Commission notes that it cited the ECM Study's general
finding that some ICE electricity contracts appear to be regarded as
price discovery markets merely as indication that an investigation of
certain ICE contracts may be warranted. The ECM Study was not intended
to serve as the sole basis for determining whether or not a particular
contract meets the material price reference criterion.
ii. Conclusion Regarding Material Price Reference:
The Commission finds that the ICE PJM contract meets the material
price reference criterion because cash market transactions are priced
either explicitly or implicitly on a frequent and recurring basis at a
differential to the PJM contract's price (direct evidence). Moreover,
the PJM contract's price data are sold to market participants, and
those individuals likely purchase the ICE data packages specifically
for the PJM contract's prices and consult such prices on a frequent and
recurring basis in pricing cash market transactions (indirect
evidence).
2. Material Liquidity Criterion
In its October 26, 2009, Federal Register notice, the Commission
identified the PJM contract as a potential SPDC based on the material
price reference and material liquidity criteria. To assess whether a
contract meets the material liquidity criterion, the Commission first
examines trading activity as a general measurement of the contract's
size and potential importance. If the Commission finds that the
contract in question meets a threshold of trading activity that would
render it of potential importance, the Commission will then perform a
statistical analysis to measure the effect that changes to the subject-
contract's prices potentially may have on prices for other contracts
listed on an ECM or a DCM.
The Commission's Guidance to the statutory criteria (Appendix A to
Part 36) notes that ``[t]raditionally, objective measures of trading
such as volume or open interest have been used as measures of
liquidity.'' In this regard, the total number of transactions executed
on ICE's electronic platform in the PJM contract was 7,990 in the
second quarter of 2009, resulting in a daily average of 124.8 trades.
During the same period, the PJM contract had a total trading volume of
268,489 contracts and an average daily trading volume of 4,195.1
contracts. Moreover, open interest as of June 30, 2009, was 318,788
contracts, which included trades executed on ICE's electronic trading
platform, as well as trades executed off of ICE's electronic trading
platform and then brought to ICE for clearing. In this regard, ICE does
not differentiate between open interest created by a transaction
executed on its trading platform and that created by a transaction
executed off its trading platform.\25\
---------------------------------------------------------------------------
\25\ 74 FR 54966 (October 26, 2009).
---------------------------------------------------------------------------
In a subsequent filing dated March 24, 2010, ICE reported that
total trading volume in the fourth quarter of 2009 was 371,885
contracts (or 5,721.3 contracts on a daily basis). In terms of number
of transactions, 9,913 trades occurred in the fourth quarter of 2009
(152.5 trades per day). As of December 31, 2009, open interest in the
PJM contract was 344,754 contracts, which included trades executed on
ICE's electronic trading platform, as well as trades executed off of
ICE's electronic trading platform and then brought to ICE for clearing.
The number of trades per day was substantial during the period
between the second and fourth quarters of 2009. In addition, trading
activity in the PJM contract, as characterized by total quarterly
volume, indicates that the PJM contract experiences trading activity
that is greater than that of thinly-traded futures markets.\26\ Thus,
it is reasonable to infer that the PJM contract could have a material
effect on other ECM contracts or on DCM contracts.
---------------------------------------------------------------------------
\26\ Staff has advised the Commission that in its experience, a
thinly-traded contract is, generally, one that has a quarterly
trading volume of 100,000 contracts or less. In this regard, in the
third quarter of 2009, physical commodity futures contracts with
trading volume of 100,000 contracts or fewer constituted less than
one percent of total trading volume of all physical commodity
futures contracts.
---------------------------------------------------------------------------
To measure the effect that the PJM contract potentially could have
on another ECM contract staff performed a statistical analysis \27\
using daily settlement prices (between July 1, 2008 and December 31,
2009) for the ICE PJM and OPJ contracts. The simulation suggest that,
on average over the sample period, a one percent rise in the PJM
contract's price elicited a 2.15 percent increase in ICE OPJ contract's
price.
---------------------------------------------------------------------------
\27\ Specifically, Commission staff econometrically estimated a
cointegrated vector autoregression (CVAR) model using daily
settlement prices. CVAR methods permit a dichotomization of the data
relationships into long run equilibrium components (called the
cointegration space or cointegrating relationships) and a short run
component. A CVAR model was chosen over the more traditional vector
autoregression model in levels because the statistical properties of
the data (lack of stationarity and ergodicity) precluded the more
traditional modeling treatment. Moreover, the statistical properties
of the data necessitated the modeling of the contracts' prices as a
CVAR model containing both first differences (to handle
stationarity) and an error-correction term to capture long run
equilibrium relationships. The prices were treated as a single
reduced-form model in order to test hypothesis that power prices in
the same market affect each other. The prices of ICE's PJM and OPJ
contracts are positively related to each other in a cointegrating
relationship and display a high level of statistical strength. On
average during the sample period, each percentage rise in PJM
contract's price elicited a 2.15 percent rise in OPJ contract's
price.
---------------------------------------------------------------------------
i. Federal Register Comments:
ICE stated that the PJM contract lacks a sufficient number of
trades to meet the material liquidity criterion. Along with EPSA and
EEI, ICE argued that the PJM contract cannot have a material effect on
DCM contracts or other ECM contracts because these other contracts do
not cash settle to the PJM contract's price. Instead, the DCM contracts
and the PJM contract are both cash settled based on physical
transactions, which neither the ECM or the DCM contracts can influence.
The Commission's statistical analysis shows that changes in the ICE PJM
contract's price significantly influences the prices of other ECM
contracts (namely, the OPJ contract). In this regard, a one-percent
rise in the PJM contract's price leads to a 2.15 percent rise in OPJ
contract's price.
[[Page 42395]]
ICE noted that the Commission's Guidance had posited concepts of
liquidity that generally assumed a fairly constant stream of prices
throughout the trading day, and noted that the relatively low number of
trades per day in the PJM contract did not meet this standard of
liquidity. The Commission observes that a continuous stream of prices
would indeed be an indication of liquidity for certain markets but the
Guidance also notes that ``quantifying the levels of immediacy and
price concession that would define material liquidity may differ from
one market or commodity to another.'' \28\
---------------------------------------------------------------------------
\28\ Guidance, supra.
---------------------------------------------------------------------------
ICE opined that the Commission ``seems to have adopted a five trade
per day test for material liquidity.'' To the contrary, the Commission
adopted a five trades-per-day threshold as a reporting requirement to
enable it to ``independently be aware of ECM contracts that may develop
into SPDCs'' \29\ rather than solely relying upon an ECM on its own to
identify any such potential SPDCs to the Commission. Thus, any contract
that meets this threshold may be subject to scrutiny as a potential
SPDC; however, the contract will not be found to be a SPDC merely
because it met the reporting threshold.
---------------------------------------------------------------------------
\29\ 73 FR 75892 (December 12, 2008).
---------------------------------------------------------------------------
ICE argued that the statistics provided by ICE were misinterpreted
and misapplied by the Commission. In particular, ICE stated that the
volume figures used in the Commission's analysis (cited above)
``include trades made in all months'' as well as in strips of contract
months. ICE suggested that a more appropriate method of determining
liquidity is to examine the activity in a single traded month of a
given contract.'' \30\ It is the Commission's opinion that liquidity,
as it pertains to the PJM contract, is typically a function of trading
activity in particular lead months and, given sufficient liquidity in
such months, the ICE PJM contract itself would be considered liquid.
ICE's analysis of its own trade data confirms this to be the case for
the PJM contract, and thus, the Commission believes that it applied the
statistical data cited above in an appropriate manner for gauging
material liquidity.
---------------------------------------------------------------------------
\30\ In addition, ICE stated that the trades-per-day statistics
that it provided to the Commission in its quarterly filing and which
were cited in the Commission's October 26, 2009, Federal Register
notice includes 2(h)(1) transactions, which were not completed on
the electronic trading platform and should not be considered in the
SPDC determination process. The Commission staff asked ICE to review
the data it sent in its quarterly filings; ICE confirmed that the
volume data it provided and which the Commission cited includes only
transaction data executed on ICE's electronic trading platform. As
noted above, supplemental data supplied by ICE confirmed that block
trades are in addition to the trades that were conducted on the
electronic platform; block trades comprise about 49 percent of all
transactions in the PJM contract (as of the fourth quarter of 2009).
Commission acknowledges that the open interest information it
provided in its October 26, 2009, Federal Register notice includes
transactions made off the ICE platform. However, once open interest
is created, there is no way for ICE to differentiate between ``on-
exchange'' versus ``off-exchange'' created positions, and all such
positions are fungible with one another and may be offset in any way
agreeable to the position holder regardless of how the position was
initially created.
---------------------------------------------------------------------------
ii. Conclusion Regarding Material Liquidity:
For the reasons discussed above, the Commission finds that the PJM
contract meets the material liquidity criterion. Specifically, there is
sufficient trading activity in the PJM contract to have a material
effect on ``other agreements, contracts or transactions listed for
trading on or subject to the rules of a designated contract market * *
* or an electronic trading facility operating in reliance on the
exemption in section 2(h)(3) of the Act'' (that is, an ECM).
3. Overall Conclusion Regarding the PJM Contract
After considering the entire record in this matter, including the
comments received, the Commission has determined that the ICE PJM
contract performs a significant price discovery function under two of
the four criteria established in section 2(h)(7) of the CEA.
Specifically, the Commission has determined that the PJM contract meets
the material price reference and material liquidity criteria at this
time. Accordingly, the Commission is issuing the attached Order
declaring that the PJM contract is a SPDC.
Issuance of this Order signals the immediate effectiveness of the
Commission's authorities with respect to ICE as a registered entity in
connection with its PJM contract,\31\ and triggers the obligations,
requirements--both procedural and substantive--and timetables
prescribed in Commission rule 36.3(c)(4) for ECMs.
---------------------------------------------------------------------------
\31\ See 73 FR 75888, 75893 (Dec. 12, 2008).
---------------------------------------------------------------------------
b. The PJM WH Real Time Off-Peak (OPJ) Contract and the SPDC Indicia
The OPJ contract is cash settled based on the arithmetic average of
off-peak hour, real-time LMPs published by PJM Interconnection for its
Western Hub for all off-peak hours during the contract month. The
hourly LMPs are derived from power trades that result in physical
delivery. The size of the OPJ contract is 50 MWh, and the OPJ contract
is listed for up to 86 calendar months.
In general, electricity is bought and sold in an auction setting on
an hourly basis at various points along the electrical grid. An LMP
associated with a specific hour is calculated as the volume-weighted
average price of all of the transactions where electricity is to be
supplied and consumed during that hour.
Electricity is traded in a day-ahead market as well as a real-time
market. The day-ahead market establishes prices for electricity that is
to be delivered during the specified hour on the following day. Day-
ahead prices are determined based on generation and energy transaction
quotes offered in advance. Because the offers and bids are dependent on
estimates of supply and demand, electricity needs usually are not
perfectly satisfied in the day-ahead market. In this regard, on the day
the electricity is transmitted and used, auction participants typically
realize that they bought or sold either too much power or too little
power. A real-time auction is operated to alleviate this problem by
serving as a balancing mechanism. Specifically, electricity traders use
the real-time market to sell excess electricity and buy additional
power to meet demand.
PJM Interconnection is an RTO that coordinates the movement of
wholesale electricity in all or parts of Delaware, Illinois, Indiana,
Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio,
Pennsylvania, Tennessee, Virginia, West Virginia and the District of
Columbia. PJM Interconnection's transmission network is the largest
centrally dispatched grid in North America. PJM Interconnection
dispatches about 163,500 MW of generating capacity over 56,350 miles of
transmission lines and serves more than 51 million customers. The RTO's
members, totaling more than 500, include power generators, transmission
owners, electricity distributors, power marketers and large consumers.
PJM Interconnection is responsible for operating a competitive
wholesale electricity market as well as maintaining the reliability of
the grid. The RTO acts as a neutral, independent party, and its
activities are monitored by FERC. The company coordinates the
continuous buying, selling and delivery of wholesale electricity
through robust, open and competitive spot markets. In operating the
markets, PJM balances the needs of suppliers, wholesale customers and
other market participants, and it continuously monitors market
behavior.
Electricity is priced at individual points along the transmission
network
[[Page 42396]]
called nodes. An electric grid has many interconnections or buses. RTOs
group certain buses together to form hubs for pricing and trading
purposes, and these hubs do not necessarily follow along state lines or
geographic boundaries. Power also is priced at the hub level and serves
as a basis for trading electricity. PJM Interconnnection has 11 hubs,
including AEP GEN, AEP-Dayton, Chicago GEN, Chicago, Dominion, Eastern,
Northern Illinois, New Jersey, Ohio, West INT and Western Hub.\32\ The
Western Hub is a basket of 109 buses that stretch all the way from
Erie, PA, to Washington, DC.\33\
---------------------------------------------------------------------------
\32\ https://www.ferc.gov/market-oversight/mkt-electric/pjm.asp.
\33\ https://www.ferc.gov/market-oversight/mkt-electric/pjm/2010/05-2010-elec-pjm-archive.pdf.
---------------------------------------------------------------------------
1. Material Price Reference Criterion
The Commission's October 26, 2009, Federal Register notice
identified the OJP contract as a potential SPDC based on the material
price reference and material liquidity criteria. The Commission
considered the fact that ICE sells its price data to market
participants in a number of different packages which vary in terms of
the hubs covered, time periods, and whether the data are daily only or
historical. For example, ICE offers the ``East Power of Day''package
with access to all price data or just current prices plus a selected
number of months (i.e., 12, 24, 36 or 48 months) of historical data.
This package includes price data for the OPJ contract.
The Commission also noted that its October 2007 ECM Study found
that in general, market participants view ICE as a price discovery
market for certain electricity contracts. The study did not specify
which markets performed this function; nevertheless, the Commission
determined that the OPJ contract, while not mentioned by name in the
ECM Study, warranted further review.
The Commission explains in its Guidance to the statutory criteria
that in evaluating a contract under the material price reference
criterion, it will rely on one of two sources of evidence--direct or
indirect--to determine that the price of a contract was being used as a
material price reference and therefore, serving a significant price
discovery function.\34\ With respect to direct evidence, the Commission
will consider the extent to which, on a frequent and recurring basis,
cash market bids, offers or transactions are directly based on or
quoted at a differential to, the prices generated on the ECM in
question. Direct evidence may be established when cash market
participants are quoting bid or offer prices or entering into
transactions at prices that are set either explicitly or implicitly at
a differential to prices established for the contract in question. Cash
market prices are set explicitly at a differential to the section
2(h)(3) contract when, for instance, they are quoted in dollars and
cents above or below the reference contract's price. Cash market prices
are set implicitly at a differential to a section 2(h)(3) contract
when, for instance, they are arrived at after adding to, or subtracting
from the section 2(h)(3) contract, but then quoted or reported at a
flat price. With respect to indirect evidence, the Commission will
consider the extent to which the price of the contract in question is
being routinely disseminated in widely distributed industry
publications--or offered by the ECM itself for some form of
remuneration--and consulted on a frequent and recurring basis by
industry participants in pricing cash market transactions.
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\34\ 17 CFR 36, Appendix A.
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PJM's Western hub is a major pricing center for electricity in the
eastern portion of the United States. Traders, including producers,
keep abreast of the electricity prices at PJM's Western hub when
conducting cash deals. These traders look to a competitively determined
price as an indication of expected values of power at the Western hub
when entering into cash market transactions for electricity, especially
those trades providing for physical delivery in the future.
Furthermore, power prices in other neighboring markets, such as New
York ISO's Zone A (Western New York), Zone G (Hudson Valley region) and
Zone J (New York City) as well as Midwest ISO's Cinergy hub, are
typically based implicitly relative to the prices reported for PJM
Interconnection's Western hub. Traders use the ICE OPJ contract, as
well as other ICE power contracts, to hedge cash market positions and
transactions--activities which enhance the OPJ contract's price
discovery utility. The substantial volume of trading and open interest
in the OPJ contract appears to attest to its use for this purpose.
While the OPJ contract's settlement prices may not be the only factor
influencing spot and forward transactions, electricity traders consider
the ICE price to be a critical factor in conducting OTC
transactions.\35\ As a result, the OPJ contract satisfies the direct
price reference test.
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\35\ In addition to referencing ICE prices, firms participating
in PJM's Western hub power market may rely on other cash market
quotes as well as industry publications and price indices that are
published by third-party price reporting firms in entering into
power transactions.
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The fact that ICE's OPJ monthly contract is used widely as a source
of pricing information is further evidence of direct price reference.
In this regard, OPJ contract prices power at the Western hub about
seven years into the future. Thus, market participants can use the OPJ
contract to lock-in electricity prices far into the future. Traders use
monthly power contracts like the OPJ contract to price future power
electricity commitments, where such commitments are based on long-range
forecasts of power supply and demand.
The Commission notes that the Western hub is a major trading point
for electricity, and the OPJ contract's prices are well regarded in the
industry as indicative of the value of off-peak power at the Western
hub. Accordingly, the Commission believes that it is reasonable to
conclude that market participants purchase the data packages that
include the OPJ contract's prices in substantial part because the OPJ
contract's prices have particular value to them. Moreover, such prices
are consulted on a frequent and recurring basis by industry
participants in pricing cash market transactions. In light of the
above, the OPJ contract meets the indirect price reference test.
NYMEX lists a futures contract that is comparable to the ICE OPJ
contract on its ClearPort platform called the PJM Western Hub Off-Peak
Calendar-Month Real-Time LMP Swap futures contract. However, unlike the
ICE contract, none of the trades in the NYMEX version are executed in
NYMEX's centralized marketplace; instead, all of the transactions
originate as bilateral swaps that are submitted to NYMEX for clearing.
The daily settlement prices of NYMEX's monthly, off-peak hour Western
hub contract are influenced, in part, by the daily settlement prices of
the ICE OPJ contract. This is because NYMEX determines the daily
settlement prices for its power contracts through a survey of cash
market voice brokers. Voice brokers, in turn, refer to the ICE OPJ
price, among other information, as an important indicator as to where
the market is trading. Therefore, the ICE OPJ price influences the
settlement price for the NYMEX monthly, off-peak hour Western hub power
contract. This conclusion is supported by an analysis of the daily
settlement prices for the OPJ contract and the NYMEX equivalent which
demonstrates that 94 percent of the daily settlement prices \36\ for
the
[[Page 42397]]
NYMEX version of the contract are within one standard deviation of the
OPJ contract's price settlement prices.
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\36\ The price data covered the period December 2008 through
December 2009.
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i. Federal Register Comments:
EPSA, FIEG, EEI and ICE stated that no other contract directly
references or settles to the OPJ contract's price. Moreover, the
commenters argued that the underlying cash price series against which
the OPJ contract is settled (in this case, the average of the real-time
off-peak hour Western Hub electricity prices over the contract month,
which are derived from cash market transactions) is the authentic
reference price and not the ICE contract itself. The Commission
believes that this interpretation of price reference is too narrow and
believes that a cash-settled derivatives contract could meet the price
reference criterion if market participants ``consult on a frequent and
recurring basis'' the derivatives contract when pricing forward, fixed-
price commitments or other cash-settled derivatives that seek to ``lock
in'' a fixed price for some future point in time to hedge against
adverse price movements.
PJM's Western hub is a major trading center for electricity in the
eastern United States. Traders, including producers, keep abreast of
the prices of the OPJ contract when conducting cash deals. These
traders look to a competitively determined price as an indication of
expected values of electricity at the Western hub when entering into
cash market transaction for power, especially those trades that provide
for physical delivery in the future. Traders use the ICE OPJ contract
to hedge cash market positions and transactions, which enhances the OPJ
contract's price discovery utility. While the OPJ contract's settlement
prices may not be the only factor influencing spot and forward
transactions, power traders consider the ICE price to be a crucial
factor in conducting OTC transactions.
In addition, EPSA stated that the publication of price data for the
OPJ contract price is weak justification for material price reference.
Market participants generally do not purchase ICE data sets for one
contract's prices. Instead, traders are interested in the settlement
prices, so the fact that ICE sells the OPJ prices as part of a broad
package is not conclusive evidence that market participants are buying
the ICE data sets because the OPJ prices have substantial value to
them. The Commission notes that publication of the OPJ contract's
prices is indirect evidence of routine dissemination. Thus, the
Commission has concluded that traders likely specifically purchase the
ICE data packages for the OPJ contract's prices and consult such prices
on a frequent and recurring basis in pricing cash market transactions.
Lastly, ICE and EEI criticized the Commission's reliance on the ECM
Study since it did not specifically identify the OPJ contract as a
contract that is referred to by market participants on a frequent and
recurring basis. The Commission notes that it cited the ECM Study's
general finding that some ICE electricity contracts appear to be
regarded as price discovery markets merely as indication that an
investigation of certain ICE contracts may be warranted. The ECM Study
was not intended to serve as the sole basis for determining whether or
not a particular contract meets the material price reference criterion.
ii. Conclusion Regarding Material Price Reference:
The Commission finds that the ICE OPJ contract meets the material
price reference criterion because cash market transactions are priced
either explicitly or implicitly on a frequent and recurring basis at a
differential to the OPJ contract's price (direct evidence). Moreover,
the OPJ contract's price data are sold to market participants, and
those individuals likely purchase the ICE data packages specifically
for the OPJ contract's prices and consult such prices on a frequent and
recurring basis in pricing cash market transactions (indirect
evidence).
2. Material Liquidity Criterion
As noted above, in its October 26, 2009, Federal Register notice,
the Commission identified the OJP contract as a potential SPDC based on
the material price reference and material liquidity criteria. To assess
whether a contract meets the material liquidity criterion, the
Commission first examines trading activity as a general measurement of
the contract's size and potential importance. If the Commission finds
that the contract in question meets a threshold of trading activity
that would render it of potential importance, the Commission will then
perform a statistical analysis to measure the effect that changes to
the subject-contract's prices potentially may have on prices for other
contracts listed on an ECM or a DCM.
The Commission's Guidance (Appendix A to Part 36) notes that
``[t]raditionally, objective measures of trading such as volume or open
interest have been used as measures of liquidity.'' in this regard, the
total number of transactions executed on ICE's electronic platform in
the OPJ contract was 437 in the second quarter of 2009, resulting in a
daily average of 6.8 trades. During the same period, the OPJ contract
had a total trading volume of 325,799 contracts and an average daily
trading volume of 5,090.6 contracts. Moreover, open interest as of June
30, 2009, was 2,976,492 contracts, which included trades executed on
ICE's electronic trading platform, as well as trades executed off of
ICE's electronic trading platform and then brought to ICE for clearing.
In this regard, ICE does not differentiate between open interest
created by a transaction executed on its trading platform and that
created by a transaction executed off its trading platform.\37\
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\37\ 74 FR 54966 (October 26, 2009).
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In a subsequent filing dated March 24, 2010, ICE reported that
total trading volume in the fourth quarter of 2009 was 622,984
contracts (or 9,584.4 contracts on a daily basis). In terms of number
of transactions, 456 trades occurred in the fourth quarter of 2009 (7.0
trades per day). As of December 31, 2009, open interest in the OPJ
contract was 3,293,899 contracts, which included trades executed on
ICE's electronic trading platform, as well as trades executed off of
ICE's electronic trading platform and then brought to ICE for clearing.
The number of trades per day was substantial during the period
between the second and fourth quarters of 2009. In addition, trading
activity in the OPJ contract, as characterized by total quarterly
volume, indicates that the OPJ contract experiences trading activity
that is greater than that of thinly-traded futures markets.\38\ Thus,
it is reasonable to infer that the OPJ contract could have a material
effect on other ECM contracts or on DCM contracts.
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\38\ Staff has advised the Commission that in its experience, a
thinly-traded contract is, generally, one that has a quarterly
trading volume of 100,000 contracts or less. In this regard, in the
third quarter of 2009, physical commodity futures contracts with
trading volume of 100,000 contracts or fewer constituted less than
one percent of total trading volume of all physical commodity
futures contracts.
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To measure the effect that the PJM contract could have on another
ECM contract staff performed a statistical analysis \39\ using daily
settlement prices
[[Page 42398]]
(between July 1, 2008 and December 31, 2009) for the ICE PJM and OPJ
contracts. The simulation suggests that, on average over the sample
period, a one percent rise in the OPJ contract's price elicited a 0.47
percent increase in ICE PJM contract's price.
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\39\ Specifically, Commission staff econometrically estimated a
cointegrated vector autoregression (CVAR) model using daily
settlement prices. CVAR methods permit a dichotomization of the data