Economic harm: The severity of a violation increases with (i) the level of costs imposed on the victims of the violation, and (ii) the unlawful benefits gained by the public utility. Generally, the greater of these two amounts will be used in setting the fine. The fact that economic harm may be hard to quantify does not diminish the severity of the offense or the need for sanctions.

The economic harm to the ratepayers by the actions of SCE was substantial. We have found that SCE received ratepayer funding of (1) $28 million for customer satisfaction awards based on false and misleading information, (2) $20 million for health and safety awards based on misleading information; and (3) $32,714,000 Results Sharing funds based on false and misleading information.