1. There is an important issue of law as to the scope of the remedies available
for violations of the Public Utility Regulatory Policies Act ["PURPA"], 16 U.S.C.
§824, et seq., which amended the Federal Power Act ["FPA"], 16 U.S.C. §791, et
seq., which were each adopted by Congress under the Commerce Clause of the United
States Constitution, including prevailing party attorney fees, and/or whether there are
any such remedies beyond declaratory and injunctive relief for such violations;
and/or the need to synthesize conflicting circuit authority.

2. There is an important issue of law as to the definition of "comprehensive
remedies" under federal statutory schemes, in the context of whether 42 U.S.C. §1983
remedies are available for violations under federal statutes – e.g. in connection with
PURPA – and the implied Congressional intent therein to foreclose 42 U.S.C. §1983
remedies for such statutory violations; and/or the need to synthesize conflicting
circuit authority.

Whether PURPA provides comprehensive remedies that foreclose 42 U.S.C. §1983 claims