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When the Federal Energy Regulatory Commission (“FERC”) adopted Order No. 872 in 2020, industry stakeholders questioned whether developers of merchant power plants still needed the benefit of the Public Utility Regulatory Policies Act of 1978 (“PURPA”).   Indeed, tax credits in the form of investment and production tax credits had facilitated the installation of wind and solar resources since the early 1990s.                  With the passage of the One Big Beautiful Bill earl