In the last 10 years, annual electric vehicle (EV) sales in the US have increased by nearly 1,100%. While approximately 115,000 new EVs were sold in US markets in 2015, calendar year 2025 sales were substantially larger—nearly 1.3 million new EVs were sold in US markets. Despite strong sales numbers, the state of the EV industry in the US at the conclusion of 2025 could best be described as one of confusion. As sales numbers increased year over year, changes in various federal policy initiatives signaled potential trouble ahead for the EV market. 2025 concluded with a shifting tide in public perception about the state of the US EV market as some media narratives forecast a crash of the industry.
Power & Pipes
FERC, CFTC, and State Energy Law Developments
FERC’s Office of Enforcement and Regulatory Accounting (Enforcement) has released its annual report on enforcement actions during fiscal year 2025, which ran from October 1, 2024 to September 30, 2025. The report provides a comprehensive overview of Enforcement’s activities across the electric, natural gas, and oil pipeline industries.
On November 20, 2025, the Federal Energy Regulatory Commission withdrew its notice of proposed rulemaking to expand the “duty of candor” in communications to FERC and terminated the related rulemaking under Docket No. RM22-20.
The Federal Energy Regulatory Commission (FERC or Commission) on November 20, 2025 withdrew the Proposed Policy Statement on Waiver of Tariff Requirements and Petitions or Complaints for Remedial Relief (Proposed Policy Statement). The Commission’s policy will be to continue to grant tariff waivers on a case-by-case basis, consistent with its statutory authority and the language of the tariff in question.
The expansion of energy-intensive technologies, including artificial intelligence (AI) data centers, has placed unprecedented demands on the electricity grid. These large loads often require vast sums of firm energy and seek to come online quickly, presenting challenges on capacity-constrained portions of the grid. The rapid pace of development is testing the limits of legacy regulatory frameworks, forcing policymakers to retrofit rules originally crafted for a far more predictable and conventional grid. What has emerged is a patchwork of regulatory solutions—large load tariffs, bespoke special contracts, and interconnection agreements—that leave open important questions about rate impacts and reliability.
The Federal Energy Regulatory Commission (FERC) on October 1, 2025 finalized a final rule under Docket No. RM25-14 to sunset dozens of existing regulations affecting the electric and natural gas industries. This regulatory action was taken pursuant to Executive Order (EO) 14270, Zero-Based Regulatory Budgeting to Unleash American Energy, issued on April 9, 2025, and is open for comment through November 20, 2025.
FERC recently approved a stipulation and consent agreement between the Los Angeles Department of Water and Power (LADWP) and Office of Enforcement and Regulatory Accounting to resolve an investigation into potential violations of the North American Electric Reliability Corporation (NERC) Rules of Procedure (ROP) and FERC regulations during a 2020 audit by the Western Electricity Coordinating Council. The settlement, and with it the large monetary penalty and additional compliance obligations, underscores the critical importance of transparency, accuracy, and truthfulness in reliability compliance monitoring and enforcement.
On September 12, 2025, the Federal Energy Regulatory Commission (FERC) terminated the proceeding in which it issued an updated policy statement that explained how FERC’s approach to considering applications to construct new interstate natural gas transportation facilities under Section 7 of the Natural Gas Act (Updated Certificate Policy Statement) would differ from the approach described in a policy statement issued in 1999 (1999 Certificate Policy Statement).
On August 29, 2025, the US secretary of energy proposed a significant regulatory shift regarding the certification process for new interstate natural gas facilities. In a letter submitted to FERC, the secretary recommended terminating the ongoing policy proceeding in Docket Nos. PL18-1-000 and PL18-1-001 and therefore rescind the 2022 draft Updated Certificate Policy Statement. Instead, the secretary advocates for continued reliance on the longstanding 1999 Certificate Policy Statement, which remains in effect.
As 2025 approaches its last quarter, a look back at the electric vehicle (EV) market in the United States reveals an initially murky picture that is overshadowed by several recent developments boding well for EV market participants. Although the first several months of 2025 were littered with government actions that prompted some to predict the demise of the US EV market, more recent developments paint a different picture.