Thanks for clarifying that. I was under the impression that the Commission was in fact going by that structured standard, hence the 10 points. If they in fact rejected it but then arbitrarily came up with 10 points anyway, then we would have a better chance of getting that reduced on appeal as an unfairly harsh punishment.
Had they actually been publicly committing to that standard, it would be hard to see how we could get it reduced on appeal after having already admitted guilt. Which was my argument earlier in the thread.
But it does now open the door a little to the appeals strategy of "well, we are guilty, but the punishment doesn't remotely fit the crime."