The Number and Scope of Violations: A single violation is less severe than multiple offenses. A widespread violation that affects a large number of consumers is a more severe than one that is limited in scope. For a continuing violation, § 2108 counts each day as a separate offense.

SCE's efforts to increase customer satisfaction results by improper means and to fail to accurately record health and safety data was widespread throughout the company, affected all ratepayers and employees, and were continuing violations.