Yes in paras 88, 89 and 90 the commission did make a big song and dance about rejecting the PL framework.
88 The Commission recognises the attraction of a regulator imposing a structured formula that was required to be applied in breaches of a particular regulation. Such a structured formula would fully inform clubs of the consequences of PSR breaches – although that would deny the Commission the power, as a specialist tribunal, to approach the question of sanction in whatever way it considered to be appropriate to the individual case before it.
89structured formula such as is advocated by the Premier League would be inconsistent with the unrestricted powers conferred by Rules W50&51. We consider that it is not for a Commission to introduce such a structured formula even on a case by case basis. We consider that we are required by the Rules to hear and consider the mitigation, after which we have a wide discretion to impose any of the sanctions listed in Rule W51. If the Premier League wishes to impose a mandatory structured formula on a Commission dealing with PSR breaches, it can do so. In that event the Commission would be required to comply with those Rules. But as things stand at present that has not been done: the Commission has the wide discretion conferred by Rules W50&51.
90 We therefore decline to adopt the structured formula proposed by the Premier League. We will determine the appropriate sanction according to all the circumstances of the case, including (as required by Rules W50&51) any mitigating factors.
They then proceeded to get to the exact same points deduction that the PL formula would have arrived at (assuming 19.5 million was rounded up to 20m) with absolutely zero detail on how they came to their figure. So forgive me if I think it whiffs a bit.
Agree that there being no set formula published (as in EFL) it might help our appeal. However I do think if they are going to start docking points off clubs that there should be a formula published and agreed in advance to ensure at least a modicum of consistency between judgements.