On June 16, 2016 FERC issued a Final Rule on a previously issued Notice of Proposed Rulemaking (NOPR) regarding sub-hourly settlements and the triggers for shortage pricing. Within the Final Rule, FERC established three areas in which settlement and dispatch intervals must align: real-time market energy transactions, operating reserves and intertie transactions. FERC also ordered that shortage pricing must be triggered in any interval in which a shortage of energy or operating reserves occurs. FERC also stated clearly within the order that changes to the demand curves used for shortage pricing were not in scope. PJM is required to submit a compliance filing for Order 825 in early January 2017. PJM would like to engage the stakeholders in a discussion on the interactions between the shortage pricing portion of the order and the existing demand curves used for shortage pricing. PJM believes that these two are incompatible and that a change is required to the demand curves in order to implement Order 825 without adverse impacts to the market.