Having read the OP attachment, my initial thought is that the evidential threshold is very low - no actual culprits were identified. Surely a priority to actually identify the culprit/s. Not only as a means to ban the person/s from the stadium, but also to allow football clubs to take civil action against offender/s.
A priority at football clubs must be to identify offenders. Supporters must also do their part in assisting stewards with identification. We`ve all been in busy, bouncing football crowds and know that it`s not always easy to find the source of an audible outburst. Worth bearing in mind that it`s becoming a growing option for clubs to advertise a text number for fans to text locations of audible violators (text-a-twat ).
If someone is ejected the stewards should photograph the offender and ensure they obtain ID details. If a culprit is advised that if details are refused, the Club will ask, via its website, for help to ID the "person in the photograph" - relevant information will likely be forthcoming at the time !! Our club stewards, if they don`t already, should operate body worn cameras - that should help with identifying "offenders".
I`ve a feeling that this problem is going to get worse before it gets better - especially when unidentified people can cause such a problem for a club. What`s stopping a rogue person from adding to the woe`s of a rival club already under sanction ?
Football clubs need to take civil action to recover costs (equalling the FA Fine) - that way, the punishment will be directed at the primary source of the offensive behaviour and not the football club. There have to be real consequences for actual offenders.