Not correct BR.
The commission had the discretion to give whatever penalty they thought appropriate.
To get to / justify the points deduction figure they "created " a mechanism.
I have no idea what their terms of reference were but the fact that they had neither historical precedent or sentencing guidelines is frankly bizarre and in those circumstances, they would argue , they adopted a mechanism which would be a precedent and give certainty for future cases.
Of course we know that the complete opposite will apply in reality.
The creation of this mechanism should be one of the central planks of the appeal on sentence but the lacuna presents s huge problem.