PJM staff has experienced increases in up to congestion bid volumes. It is possible continued increasing volume could cause concern regarding the ability for the Day Ahead Market to solve in the required timeframe. PJM staff believes the addition of an Operating Agreement provision to protect against excessive bid volumes would be beneficial. The IMM has recommended the application of FTR forfeiture rules to up to congestion transactions because they are analogous to other virtual bids and offers from this perspective.