Why make new rules?
IANAL, but it seems to me that writing new rules requires all kind of public comment and procedure, followed by years of legal challenges by red states and companies.
In this case, since the Ijit(sic) Pal commission public comment process was so clearly flawed, could not the current commission find their own process flawed and hence revoke their own (2017) rule changes.
That leaves any challengers trying to prove that the 2017 decision and everything leading up to it was spotless, and the adminstration just saying mea culpa ( on behalf of the Trump administration).