Southern California Gas Company (“SoCalGas”) used ratepayer money to finance a long-running campaign to undermine efficiency standards at all levels of government, particularly when the Company determined that stronger efficiency standards could threaten its business interests by making gas appliances less competitive against electric options. Yet despite the Presiding Officer’s Decision finding that SoCalGas’ actions were “improper” and “result[ed] in appreciable harm to the regulatory process,” the Decision fails to impose meaningful consequences. By not assessing penalties for SoCalGas’ blatant, well-documented violations and only requiring a return of shareholder incentives and a portion of misspent funds, the Presiding Officer’s Decision commits legal error. The Presiding Officer’s Decision is an abdication of the Commission’s responsibility to deter future misconduct and duty to impose penalties for violations of Commission requirements.