SUMMARY OF FACTS AND PROCEDURAL HISTORY
WATT, Justice.
In an effort to encourage the development of cogeneration and small power production facilities, and to reduce the demand for fossil fuels, the United States Congress enacted the Public Utility Regulatory Policies Act of 1978 ("PURPA"), Pub.L. 95-617, 92 Stat. 3117 (codified as amended at 16 U.S.C. § 824a-3).
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