By Andrew Rowson – January 2024
‘In Local Government there is no substitute for doing boring really well. Only when you have a solid foundation can you innovate.’
Max Caller, CBE
‘If you look at Northamptonshire through to Woking, with others in between, what was happening there was a situation crystallising around a financial risk based largely upon commercial ventures. That’s reflected a position whereby those organisations were not identifying and not addressing those risks.’
Michael Hudson, Cambridgeshire County Council S151 Officer
Certainly, if one looks back, it is absolutely the case that each of the local authorities that have had to issue section 114 notices has had failures of leadership, management and governance, and some have taken risks that were unmerited….So far….there has been a direct linkage between poor leadership and the subsequent issuance of a section 114 notice.
Rt Hon Michael Gove MP, Secretary of State, DLUHC
1 - Introduction
This report mostly comprises extracts from official minutes
or transcripts from council committee meetings, or from reports by
Cambridgeshire County Council (CCC) or its outgoing external auditor – EY. It demonstrates firstly the recklessness of
council officers and elected Members of CCC’s former Commercial and Investment
Committee for launching a high-cost, high-risk commercial venture in 2016 with
no detailed business plan, no public consultation, and on the basis of a
fundamentally flawed prospectus. The
Council and its Members appeared to be oblivious to the reality that under the original
flimsy “outline business case” even under the “extremely buoyant
economic conditions for housing development” that existed seven years ago, the
housing company was not expected to turn a profit “for years, if not decades”. That being the case, the only two ways This
Land Ltd could service its substantial interest-only loans to CCC were:
a)
By CCC borrowing yet more from the Public Works
Loan Board (PWLB) and lending it on to This Land at commercial rates, thus
creating a spiralling liability that could never be repaid, or, once central
government put an end to that option...
b)
By selling land purchased from CCC (with
borrowed money) on to developers, and using that income to service the debt to
CCC. In so doing, This Land has cannibalised
itself, whilst at the same time steadily eroding its potential for making
future profits from selling its own houses – the very opposite of what the
company was set up to do.
The longer This Land remains a loss-making enterprise, the
heavier the debt burden becomes, the more land the company has to sell, and the
less likely any prospect of ever making a profit or of repaying the debt. In the accounting period to March 2023, 78%
of This Land’s total revenue has come from Land sales rather than residential
property sales. It would appear, given
the scale of the outstanding debt (£113.8m), the sale of £53.4m worth of land
to date, and the surprisingly low sale prices of the units sold in 2022/23
(£247,000/unit on average), that This Land may already be past the point of no
return.
The second revelation in this report is EY’s dishonesty in
its statements about the prospects of CCC recovering the long-term debt owed by
its wholly owned subsidiary. In
September 2022 EY acknowledged for the first time the “new and significant
risk” of CCC not recovering some or all of its long term debt (113.8m) from
This Land Ltd. That risk was not
new. It was brought to EY’s attention in
September 2021 by a local elector in an objection to the previous year’s
accounts (2020/21), when CCC’s long-term debt from This Land had risen by £26
million to £113.8m. EY ignored that
objection (as it had ignored the two prior to that and the one after it), until
presented with a Letter Before Action in October 2022. Within days of that letter, EY
accepted all four objections relating to four successive years’ accounts.
In the September 2022 Audit & Accounts meeting, EY’s
audit partner, Mr Mark Hodgson, told Committee Members that EY was discussing with
management the possible need for “impairments” to the debt owed by This
Land because of recoverability issues.
Yet six months later, (3rd March 2023) in his decision
notice to all four objections, the same audit partner declined to issue a
public interest report about the significant risk of default because he had “not
to date identified a level of indebtedness by This Land that would affect our
value for money conclusion”. Nine
months after that, on 1st December 2023, and after several missed
self-imposed deadlines for completing its audit work on this matter, the
auditor told CCC Members that the audit team has still not completed its audit
work to establish how likely CCC is to recover all that substantial debt. Those Members, like the public, may now have
to wait until February to find out how safe local taxpayers’ money is. That would be twenty-nine months after the
matter was first brought to the external auditor’s attention, seventeen months
after the auditor first flagged it up as a significant risk in his September
2022 audit plan, and seven months after EY and CCC had access to This Land’s
2023 Business Plan. Last November's resignation
of This Land’s Chief Executive (£235,038 annual remuneration including pension
contributions) does not augur well for a positive outcome.
2 - Outline Business Case for CCC to establish a
company as a Housing Development Vehicle (HDV) – 27th May 2016
‘In view of CCC’s land holdings, and the currently
extremely buoyant economic conditions for housing development, there is an
opportunity for CCC to develop its own land rather than sell it. Simply selling sites for others
to develop, and profit from, is no longer an option for CCC. The scale
of the financial challenges facing CCC requires that it has to review every
opportunity available to it in order to create an on-going revenue stream that
can mitigate the reduction in the services that it otherwise would have to
make.
The vision is to transform CCC from being a seller
of sites to being a developer of sites. CCC is therefore developing, and
delivering, a series of principally residential development projects from its
property portfolio across Cambridgeshire, planned over an initial 10-year
timescale.’
The nature of housing developments is that there
is a significant time lag from the point at which sites are identified until
the point that a revenue stream is created. One way of ensuring that revenue is
received by CCC much earlier in this cycle is for CCC to establish a market
loan to the HDV [Housing Development Vehicle]. The HDV needs to borrow at market rates in order to avoid
state aid regulations but CCC can borrow at far more competitive rates from the
Public Works Loan Board and take the margin on the loan in to CCC’s revenue
account. CCC will therefore gain approximately 3.0 to 3.5% on everything it
lends to the HDV from the point at which the loan is made, not when sales or
rents start to be received by the HDV. This will mean that the HDV will be
making substantial losses for many years. This is not of concern as this will
be within the financial model and long-term business plan of the HDV. See Agenda Item
3 - Minutes – Commercial & Investment Committee
– 27th May 2016
‘A Member spoke in favour of the direction
proposed, given his experience as a member of another property board for a LA
with considerable assets. However, he felt
that the risk already highlighted of government changing legislation, and
ultimately the returns to the LA reducing, was a very real one which needed to
be evaluated. He also
pointed out that the simple business model presented gave the impression of “making
money out of nothing”, which may appear to be the case for the
Council’s revenue account, but it did have significant cashflow implications. He asked if enough was known
about the Council’s future cashflow predictions, and sought reassurance that the
Council would not go illiquid. Officers commented that this was a valid
point, and the level of indebtedness would significantly increase, albeit to an
acceptable level, as construction costs would require upfront funding, and this
would be reflected on the Balance Sheet.
A Member asked, on the basis of forecasts already
undertaken on borrowing, repayments and income streams, how long it would be
until there was net income. Officers
advised that they did not expect the HDV [Housing Development Vehicle] to make a profit
for some time, maybe even for decades, although the income for the
Council would be realised straight away. Much depended on the
shape and length of the development pipeline.
A Member asked if the HDV would be open to legal challenges
by other developers i.e. as a result of the Council selling land to its own
company. Officers advised that
experience around the country to date showed that land had successfully been
transferred in this way, and there had been no legal challenges to date.
Members noted the potential issues where there could be challenge, around
selling at less than best consideration. However, the model proposed would
protect the Council from such challenges, as it was proposing to transfer land
at market value to the HDV.
A Member commented that future discussions and
reports need to be clear whether they were referring to the County Council or
the HDV. He also queried
if making a return on money borrowed from the government in the way proposed
was completely legal. Officers advised that it was, although it was noted that
the government may introduce a cap on prudential borrowing in the future,
at which stage the Council would need to look at other potential mechanisms.” See Committee Meeting Minutes here.
Notwithstanding the above misgivings, Members voted
unanimously for officers to incorporate the housing company, with no detailed
business case, and without going to public consultation. Cambridge Housing and
Investment Company Ltd (CHIC) was incorporated three weeks later.
4 - Minutes – Commercial & Investment Committee
– 23rd February 2018
A
Member commented that the Committee was being asked to agree to the transfer of
very substantial assets to a company when Members do not fully understand the
reporting and governance arrangements: a workshop on these issues has
been promised but had not happened. The Committee was unaware of the name
change/ rebranding until the invitation to the relaunch event. The Member
suggested that the decision be deferred pending the workshop being carried out.
Another Member agreed, saying that this proposal was effectively being
presented as a fait accompli, and she reiterated her concerns on the Risk
Register and mitigation of the risks presented.
The Monitoring Officer and Deputy Chief Executive
reassured Members that they took their roles very seriously, especially in
ensuring the governance of the organisation was carried out in an appropriate
way. Operational issues
were the responsibility of the This Land Board: the Committee was not
running the company. The Committee had appointed the Managing
Director and shareholder representatives. Whilst the workshop on governance and
reporting processes had not yet taken place, the Committee had had a workshop
on the processes involved in the portfolio transfer, and there was no lack of
transparency or openness on how that process was taking place.
In
response to a Member question, it was confirmed that the Committee did not
normally have the right to the commercially confidential minutes of the Board
of Directors, but the Directors and Managing Director would be happy
to talk to Members as shareholders.
A Member noted that whilst one of the recommendations was
to declare the properties listed in the confidential Appendix 1 to the report
as surplus, but there was no information provided on why those properties were
surplus. In terms of process and audit trail, this information was required.
Officers pointed out that the schedules and reports on these properties had
been presented to the Committee over the course of the last 18 months. A Member
highlighted that the Committee was in unchartered territory, and whilst This
Land clearly had a clear business plan, there was nothing to compel them to
realise their objectives, and the company had no mission statement, vision or
values.
The Deputy Chief Executive commented that those issues
had been set out in their Business Plan, specifically about how the company
sought to differentiate itself. He stressed that the Council’s role as shareholder meant that they
could not compel the company to deliver a certain percentage of affordable
housing – if the Council did that, the dynamic would change, and the
relationship would become contractual, which would have implications for the
company’s ability to operate in a commercial environment. See Committee Meeting Minutes here.
5 – Blog - Rt Hon Lucy Frazer KC, MP - 4th April 2018
Lucy Frazer MP and senior representatives from Cambridgeshire County
Council; Leader of the Council Cllr Steve Count, Chief Executive
Gillian Beasley, and Deputy Chief Executive and CFO Chris Malyon, met
with, Housing, Communities and Local Government Minister, Rishi Sunak MP
to discuss the financial challenges that Cambridgeshire County
Council face given their current funding…
Lucy said, “I am very grateful to Rishi for offering this meeting to
Steve, Gillian, Chris and myself. Our meeting was extremely
positive. Rishi
listened attentively to the concerns expressed and acknowledged the
entrepreneurial spirit of Cambridgeshire County Council, praising their highly
efficient operations….
The Minister
acknowledged the Council’s highly efficient operations, praising the
shared service agreements between Cambridgeshire and Peterborough, and identifying Cambridgeshire
County Council as an example of good practice. See Lucy Frazer's website here.
6 - Commercial & Investment Committee, 16th
October 2020
Cllr Boden
‘..the Committee will have had the benefit of an email
from Mr Rowson that was sent yesterday concerning various other councils and
their attempts to raise money through commercial and investment processes. And I think that that is an extremely helpful
thing for all members to read – if you haven’t yet read it. Because it shows just how things can go wrong if they are set up in the
wrong way, and not properly monitored and any problems addressed, or if
attempts are made to overreach. And I
think it's really important because this is something which officers and
members in this Council have learned from. We’ve learned from the mistakes in some other
local councils – and there have been some… I’m not going to name any specific
names, but there are some dreadful ones in addition to those that have already
been highlighted by Mr Rowson in his email.
And we’ve learned from those lessons and we will make sure that we in
Cambridgeshire don’t make some of the same mistakes that have been made
elsewhere.
So far as this agenda item is concerned, I think that
from our point of view in this committee, it’s important to bear more in mind
than just the published figures of This Land Ltd. We’ve set This Land Ltd up in order to be
able to act in a commercial way – to be able to achieve certain objectives at
arm’s length from the Council. We obviously have an interest in the financial
performance of This Land Ltd. But the
interrelationship between the Council and This Land Ltd is of really vital
importance. And that isn’t really
reflected in the figures of This Land Ltd, but relates to the fact that, first
of all, we are receiving significant amounts of interest from This Land Ltd
which assists us significantly in revenue terms. And secondly we are effectively, in some respects, converting capital
into revenue through what we do in This Land - which is also of benefit to the
Council. So when we’re looking at
the effectiveness from this Council’s point of view of This Land Ltd, we don’t
just look, as though we are an investor, at the figures that This Land
produces. We also have to think of how
else we benefit as a Council. And I
don’t think that point always gets across very well, and it’s fairly clear from
Mr Rowson’s question that it doesn’t get across to the public as well as it
should do.
So I think that is something we all need to bear in
mind. And in connection with that, and
looking at the recommendations that we’ve got in front of us today, I would ask
– I’m not asking for the recommendations to be amended – but I would ask that
what’s been delegated to the officers and the Chairman in terms of the detailed
terms of the loan – that we ensure that the terms which are granted to This
Land Ltd are no better that they would be able to get from the commercial
market. Because we’re not here to do benefit to This Land
Ltd. We’re here for the benefit of the
Council. And in order to achieve
the best balance between what goes on within This Land Ltd and what we need in
this Council, it’s important that we do follow the requirements of central
government financing, to avoid state financing, but also to benefit this
Council by ensuring that those terms are not at uncommercial and unrealistic
rates.’ See YouTube video here. (Timestamp 1.03.56)
7 - Mark Hodgson, EY partner – CCC Audit &
Accounts Committee meeting, 29th September 2022
For your attention primarily there are two new audit
risks around the debtor associated with This Land, which links to working
capital loans made to your wholly-owned subsidiary.
There has been some significant press coverage of both
This Land and other housing-related subsidiaries in the country and their
ability to repay the borrowing they have been afforded. And in light of that we need to review the business model that This
Land has via the component auditor, their going concern assumptions, and
therefore their ability to repay the £113 million [£113.8m] that is currently
outstanding at 31st March [2022], and discuss with management the
need for any impairment over that balance because of any recoverability issues. See YouTube video here. (Timestamp: 54.26)
8 - Mark Hodgson, EY Partner – Decision Notice on a
local elector’s 2021 objection to the accounts – 3rd March 2023
Auditor’s decision and reasons:
Local authorities have a general power to trade in function-related activities
through a company (section 95 of the Local Government Act 2003 (LGA
2003)). They also have a power to invest
under section 12 of the LGA 2003. The
statutory guidance issued under 15(1) of the LGA 2003 gives further details
around what investments are – financial investments include loans (paragraph
40). Paragraph 33 states that local
authorities can make loans to (inter alia) wholly owned companies. Section 111 of the Local Government Act 1972
also provides a subsidiary power to local authorities to “do anything (whether
or not involving the expenditure, borrowing or lending of money or the
acquisition or disposal of any property or rights) which is calculated to
facilitate, or is conducive or incidental to, the discharge of any of their
functions”. It is clear CCC has the
power to pass money to This Land Ltd. We
are also not aware of any ground on which to base a conclusion of public law
unlawfulness in respect of the exercise of such powers. Therefore, there is no unlawful item of
account. We have not to date identified a level of
indebtedness by This Land Ltd that would affect our value for money conclusion. We have carefully reviewed these conclusions
again, and we do not see an unlawful item of account or grounds to make a
public interest report under the 2014 Act.
We are of the opinion that – from the governance and oversight
arrangements in respect of This Land Ltd set out by CCC in its response (as
well as the publicly available documents: particularly the Avison Young report
and subsequent action and consideration of that report well into 2022) – there
is appropriate governance, transparency and oversight of This Land Ltd.
Cllr Gay
Yes. Just on This
Land. Can you give any sense on what
sort of areas the projections (EY testing This Land’s cash flow projections in its 2022 Business Plan) cover, because I think the first capital repayment is in 2026, and obviously a
default on those payments by This Land would be very serious indeed for the
authority, and we need look no further than Thurrock to know that ill-conceived
and failed capital projects have contributed to the failures in Slough and in
Thurrock and a number of others. So have
we got any preliminary indications, and is there any sense in which we can plan
to mitigate any impacts that failure to repay on time would have?
Tom Kelly, Service Director: Finance & Procurement
Yes. So in terms
of the audit of 21/22, I think EY have highlighted that as the recoverability
of the long term debtor, or credit loss – so exactly the point Cllr Gay
makes. I think perhaps in simplified
terms, the approach that’s been taken is to look at the assurance the Council
has effectively received through the submitted This Land Business Plan, which
for the relevant year shows a surplus of £16 million over the planning period
in their central scenario. And then
looks at the assurances we’ve received and kind of test some of the underlying
assumptions related to that. So EY are
for instance looking at checking [that] some of the actual values received back
up the Business Plan. They’re looking in
detail at one of the construction sites that’s been completed, and again
checking the income and expenditure figures match through there. It relies on checking through how in
particular inflation indices have been applied to the programme, and the future
assumptions that have been made around strategic land sites that This Land
still needs to acquire.
So that gives you a sense of the detail and the type of
responses that the Council’s needing to provide as part of that testing. Of course, rolling forward to where we are
now, there’s been a subsequent business plan received from This Land Ltd, and
there’s been those national developments that Cllr Gay refers to. And we have a number of assurance mechanisms
continuing with the company and also in our kind of consideration of reserves
provision and MRP. There are kind of
mitigations in place for some of the downside risk on those scenarios. So it’s actively under consideration.
Cllr Wilson (Chair)
I’m not sure if you’ve got the bottom line. Are we comfortable that we’re going to get
the money back? I heard a lot of “things
are being studied in detail”. But the
bottom line is – are we confident we’re going to get the money back?
Service Director: Finance & Procurement
Yes. So I think
that the shareholder committee for This Land is the Strategy and Resources and
er, was Strategy and Resources – now moves across to Assets and
Procurement. Relatively recently they got the most recent
Business Plan report that does show the central scenario continuing to project
full repayment of the loans on time. The
Council has officially received that, and we are comfortable with that position. But it does show that there is risk with this
venture, and there are sensitivities where that declines. So that’s hence why we need to keep that kind
of ever watchful vigilance in respect to it.
Chair
Thank you. Any
other comments? Chris?
Cllr Boden
Not on This Land.
YouTube video here - Timestamp: 50.26
|
Type of risk
|
Description
|
Findings and conclusion
|
|
Significant
Risk
|
Recoverability
of Long-Term Debtor with This Land Group
|
We have not
yet fully completed our work in this area and will provide a verbal update on
1 December 2023. See Minutes here - Agenda Item 7.
|
In the promised verbal update at the 1st December
2023 meeting of CCC’s Audit & Accounts Committee, EY reported that its
audit team was still working on this item, which remains the only outstanding
material risk issue before the auditor can issue his 2021/22 audit opinion (Timestamp 1.20.50). The statutory deadline for 2021/22 audit
completions was 30th November 2022.
According to EY, the audit team is now looking at This
Land’s future cashflow projections from its 2023 business plan. EY and CCC have had access to the business
plan since July.
That cashflow projection, (based on the assumption of zero
inflation – see below) shows cash balances fluctuating between £10m and
£20m for the next three years, before shooting up in the second half of 2026
and 2027, just in time to repay the loan principal in three tranches:
·
January 2028 - £64.7m
·
September 2028 – circa £39.2m
·
January 2029 – circa £9.9m.
This Land’s eventual success in repaying the loans therefore
depends entirely on an unlikely surge of substantial profits in the last two
years before March 2029, in the teeth of economic headwinds of falling house
prices, falling land prices, and with an onerous debt burden. Given This Land’s track record for getting
its projections wrong, the above cashflow forecast does not inspire confidence. CCC, This Land Ltd and their respective
external auditors both assess This Land’s going concern status by looking only
at the next twelve month horizon.l
11 - This Land’s 2023 Business Plan –
Alice in Wonderland
The “outline business case” that CCC Members approved
unanimously in May 2016 made no mention of the number of houses the HDV planned
to build. A year later, CCC’s 2017/18
financial statements contained the following:
Five years later, This Land’s 2023 business plan (see below)
sets out the more modest ambition of building and selling only 490 houses
itself by January or March 2029, with a further 453 to be built by other
developers, making up 863 in total.
Given the 53 units This Land has sold in the seven years to March
2023, that presumably means that in order to meet its target of repaying the
£113.8m loan principal by 2029, This Land itself anticipates selling a further
437 homes (490-53) in the six years to 2029.
That equates to an average of 73 annual house sales until then. Most of those will need to be built without
This Land being able to borrow further from CCC. These figures and assumptions are all based
on the limited information available to the public.
This Land’s original outline business case and subsequent
business plans all proved unrealistic.
Delays in securing planning permission and other setbacks meant that the
company did not sell its first house until its fifth year of operation. Without considering where the cash would come
from to pay its growing loan interest obligations, and with central government putting
a stop to councils borrowing from the Public Works Loan Board for commercial
gain, in the last three accounting periods This Land was obliged to sell some
of the land it had purchased from CCC just to keep the company afloat. As at March 2023, only 22% of This Land’s
total revenue had come from selling houses.
The remaining 78% came from land sales.
The £53.2m figure for land sales in the graph below excludes a further
£27 million CCC claims This Land will receive from land sales between 2023 and
2026 in a “binding contract” (p 36). Additional plot sales are expected during
2023/24. That would mean This Land
receiving at least £80m of revenue from selling land it had originally bought
to build houses on. It is precisely what
council officers assured Members in May 2016 it would not do:
“Simply selling sites for
others to develop, and profit from, is no longer an option for CCC.”
The public has no information about any profit share
arrangements between This Land and the developers who have purchased the £80m
worth of land.
As noted in a previous article, the headlong dash for cash
has also meant that the average sale price of homes sold by This Land in the
last three accounting periods (as per This Land’s audited accounts) has fallen
from £550,000 per unit in 2020/21, to £329,000 in 2021/22, and to £247,000 in
2022/23.
This Land’s 2023 business plan projects future net profits totalling
£42.5 million from 2023/24 onwards:
When placed alongside the company’s audited historical
losses up to and including 2022/23, the figures look like this:
On 17th November 2023, 23 days after the company’s
latest audited were published on Companies House, This Land Ltd’s Chief
Executive resigned. Those accounts
recorded a comprehensive loss of £11.2m for the year to March 2023 - £2m higher
than the £9.2m shown in the 2023 business plan published in July (see table
above).
If the past history of 53 house sales producing net losses
of £38.35m is compared with the future promise of £42.5m net profits and 437
additional houses sold by the beginning of 2029 (see above), the two sets of data
produce starkly different net profit/loss per unit statistics:
None
of the information available to the public can explain the alchemy the company now
promises will turn its fortunes around only in three years’ time, or why that
secret of success has eluded This Land Ltd for so many years.
The
derived net profit figure of £97k per house sale above is after charging
around £4m/year of administration expenses, and after the loan interest expense
(currently over £8m/year). When those
two are added in, the figures suggest This Land’s gross profit on each house
sold in the remaining years to March 2029 will need to be at least £260,000 on
average, which is higher than This Land’s average house sale price in
2022/23. In other words, in the absence
of additional critical information not provided to the public, the figures
presented in This Land’s latest business plan do not begin to add up, and it
should not have taken EY over six months to draw clear conclusions from its
audit work – especially when it was first informed of the debt recoverability
issue well over two years ago, when the debt first rose to £113.8m.
For
years, CCC has denied the public more granular information about This Land on
the grounds of “commercial confidentiality”. In July 2023, a confidential appendix to This
Land’s latest business plan was provided only to Members of the Strategy and
Resources Committee behind closed doors. One concern is that to avoid embarrassment, CCC
might be allowing This Land to limp on until it finally crashes, generating
further substantial losses along the way that local taxpayers will ultimately
have to pay for, rather than putting the public interest first and making a sober
assessment of its subsidiary’s future prospects.
As a
result of This Land’s substantial losses to date, the succession of failed
business plans, the auditor’s recent concerns about the recoverability of loans
made to the company, vague talk of using reserves to deal with the “downside
risk” of the loans not being repaid, and the suspicious shape of the latest
cash flow projection – with cash reserves only beginning to accumulate at least
three years hence, the public can have little confidence in the latest plan
without seeing more concrete and credible information. CCC should therefore stop hiding behind the “corporate
veil” and the convenient excuse of “commercial confidentiality”,
especially since This Land has evidently not been treated on a commercial, arm’s
length basis in several respects. To
assure local taxpayers (the ultimate stakeholders) that This Land’s latest
business plan is not another illusion or a delay tactic to prolong the
company’s end artificially, the County Council should provide additional
substantial information to support the latest cash flow forecast. That information should be in the form of
numbers of projected house sales per year up to 2029, with some credible indication
of profitability per unit sold. It
should also explain why This Land has used the “base case forecast” for
its projections, predicated on a zero percent inflation rate, when inflation
rates, especially in construction, are historically extremely high, and predicted
to remain high for several years to come.
Credible granular information from the authority is essential since on
many occasions in the past EY has shown itself not to be an independent party,
as its contradictory statements on This Land also bear witness (see sections 7
and 8 above). In the absence of any
supporting evidence, a simple vote of confidence by EY on the recoverability of
the £113.8m debt is unlikely to quell the public’s unease about This Land’s
future.
