PJM has identified a risk to Financial Transmission Right (FTR) market revenue funding when the awarding of IARRs for a Customer-Funded Upgrade request impacts current or future market-to-market flowgates. This risk of underfunding can occur because there is no mechanism for PJM to be granted the appropriate Firm Flow Entitlements (FFEs) associated with the external upgrades built for IARR requests. Any portion of the current FFEs for an impacted coordinated flowgate that is less than the 80% of the IARR MW total will result in FTR revenue inadequacy. PJM has coordinated with MISO and because MISO’s internal IARR rules they cannot guarantee future FFEs to PJM for PJM member requested IARRs. PJM wishes to receive member input on how to best document and implement any potential enhancements to address this concern.