Matt Christiansen, an attorney with Wilson Sonsini and former general counsel of the Federal Energy Regulatory Commission (FERC), was quoted in a recent POLITICO E&E News article discussing a potential FERC response to a sweeping executive order issued by President Donald Trump. The order directs energy agencies to implement “sunset” provisions—requiring certain regulations to automatically expire in as little as a year’s time unless actively reaffirmed.

In the article, Matt noted the potential legal and logistical challenges of implementing the executive order, calling it “a Herculean task,” and emphasized the importance of following proper notice-and-comment procedures to avoid legal pitfalls. Considering those challenges, he described FERC’s potential use of a notice of inquiry as a prudent move, allowing industry stakeholders to provide input before any rule changes are proposed. “I see this as the commission being very prudent,” he said.

Matt further warned that sunsetting foundational regulations—including orders as foundational as Orders 888 and 2000—could create significant uncertainty across the energy sector, disrupting how electricity is transmitted and delivered across the U.S. grid. He underscored the importance of preserving regulatory certainty while exploring reasonable reforms: “Calling into question those regulations: That can create a lot of uncertainty to the basic ways in which people get their power.”

The full article can be found here (subscription required).