This issue concerns transactions (Up-To Congestion transactions) that were created as a mechanism to provide some price certainty in the day-ahead energy market. Customers can specify how much they are willing to pay for congestion between a transaction source and sink. If the congestion charges are up to or less than the specified amount, then the transaction is scheduled. These transactions were also eligible for allocation of Marginal Loss over-collections. PJM and its market monitor learned of behavior in which parties were alleged to be submitting uneconomic up-to congestion bids as a means of collecting marginal loss over-collection allocations in excess of the cost of their Up-To Congestion bids.