House of Commons - Localisation issues in welfare reform - Communities and Local Government Committee

Localisation issues in welfare reform - Communities and Local Government Committee Contents

3 Council Tax Benefit

The Government's proposals

26. Council Tax Benefit (CTB) is an income-related social security benefit designed to help people on low incomes pay their council tax. It is paid whether or not the claimant is available for, or in, full-time paid work, and it can be claimed by owner-occupiers. Currently, local authorities administer CTB in accordance with national criteria set by DWP, and are fully reimbursed by the Department for the rebates made. Spending on CTB in 2009/10 amounted to some 2.5% of total spending on benefits, tax credits and pensions; however, only the state pension and universal benefits like Child Benefit have more recipients. At May 2011 there were 5.85 million recipients of Council Tax Benefit in England, Wales and Scotland, of whom 62% were aged under 65.[55]

27. Clause 34 of the Welfare Reform Bill provides for the abolition of Council Tax Benefit among other benefits. While others will be replaced by the Universal Credit, Council Tax Benefit will not. Instead the Government intends to devolve responsibility for assessment and payment of council tax support to local authorities, with responsibility for this policy area being passed from DWP to DCLG and a duty to be placed on local authorities to run such a scheme.[56] The White Paper argued that

The introduction of Universal Credit provides the opportunity to sweep away some of the centrally-imposed complexities of Council Tax Benefit that make it difficult for people to understand. [...] Local authorities will be better able to provide a joined-up system of support for people on low incomes that dovetails with the various rebate and discount schemes which are already part of the Council Tax regime, while at the same time protecting vulnerable groups.[57]

The Minister for Housing and Local Government, Rt Hon Grant Shapps MP, further explained the Government's rationale for the change:

To local authorities I think the big advantage is that they will have a stake for the first time in what people who live in those homes are doing; in other words, an incentive to help get the person back into work, and so on. [… For individuals], there is a real problem where, if you are living in a situation where no-one appears to care about your situation, it makes it harder to get back into a job. Clearly, having that local knowledge will be helpful. The other point to make is that council tax is a local tax set by the local authority. Somewhat bizarrely, the benefit against that tax comes straight from central government, wham, into the middle of it all. Of course, it makes perfect sense to tie together these two ends so that the local authority has a proper picture and control over it, and can assist people finding their way back into work.[58]

The localisation proposals are part of the Local Government Resource Review, which is also exploring local retention of business rates and integrated 'community' budgets. A local government finance bill will be introduced later in this parliamentary session to establish a framework for local council tax support schemes.[59]

28. A consultation on the proposals opened in August, and will close in October 2011. The consultation document proposes that billing authorities—unitary and lower-tier authorities who currently administer the Council Tax Benefit regime on behalf of the DWP—should lead on the design and administration of localised council tax support schemes.[60] Collaboration between local authorities is suggested and encouraged as a potential way to "help to reduce administrative costs, manage financial risks by enabling local authorities to manage funding over a broader area, and ensure local schemes support wider local priorities for growth".[61] The consultation acknowledges that some people may end up paying more council tax than they currently do, "if your local authority does not think that you are among those who need most support".[62]

The limitations on localisation

29. It will not be possible, under the new regime, for a local authority simply to opt out of providing some form of council tax support entirely.[63] Beyond that basic level, however, there is sharp disagreement about how much discretion local authorities should have in designing their own schemes. Citizens Advice stated that it could see no advantages to localisation of Council Tax Benefit,

However, if [it] must be localised, we believe that local authorities should be bound by clear and rigorous rules of accountability, where spending is justified in terms of wider principles such as reducing child poverty, preventing homelessness, promoting equality, and ensuring that everyone has the basic needs, as well as due consideration of further costs to government if people are not supported to manage their immediate needs. [...] We believe that these proposals will create an intractable problem by localising provision on the basis of minimal control, as it is hard to see how consistent standards can be maintained without direction from central government.[64]

Birmingham City Council set out the contrary case:

If the scheme is to be localised it must in our view be with the minimum amount of central regulation. It would seem illogical to be otherwise, [to] localise scheme design and delivery but impose a large degree of central directives.[65]

Kerry Macdermott of IRRV predicted that consortia would emerge among English local authorities for the administration of council tax support, so that differences between schemes would in the end be quite peripheral.[66] He drew a parallel with the local administration of discretionary housing payments: "That comes with a very high-level policy statement of expectations from the DWP, which gives the parameters for the award of discretionary housing payments. I think you will find that that works very well in local government. We would be realistic, pragmatic and responsible".[67]

30. Grant Shapps told us that "there certainly will be some central direction", although he was unable to give any details of what form this might take, because "the exact scheme design on which you are pressing me needs to come out of the consultation rather than the other way round."[68] The consultation states that, while "Government wants to give local authorities as much freedom as possible, within certain parameters, to design their schemes",

there may be some elements of administration where it may be desirable to: provide for a degree of consistency between authorities to support data sharing and minimise the complexity for tax payers moving between areas; [and] remove disincentives to entering into temporary work by avoiding some of the potential administrative complexity of claiming local support for council tax.[69]

The consultation invites views on the desirable minimal level of consistency between schemes, though does state that the Government is minded to give local authorities freedom to set their own income and capital thresholds for working-age claimants.[70]

31. It is already clear, however, that local authorities will be operating under some substantial constraints when designing their schemes, because of three policy aims which will take precedence: protection of work incentives, protection of pensioners from any reduction in support, and reductions of 10% in the overall budget for council tax support.

32. In its inquiry into the Universal Credit, the Work and Pensions Committee encountered a substantial body of opinion that a separate system of support for council tax is inimical to the aim of welfare simplification through the Universal Credit, and, if genuinely 'local', threatens to undermine the work incentives that are a central plank of the Government's welfare reforms.[71] The rate at which benefit is withdrawn as a claimant starts to earn or increases their earnings is known as the 'taper'. Currently different benefits have different taper rates, but the Government's intention is for Universal Credit to have a single taper of 65%—meaning that, as earnings rise, the Universal Credit is to be withdrawn at a constant rate of 65 pence for each pound of net earnings. This will produce a Marginal Deduction Rate (the impact on income of the combined effect of benefits being withdrawn and tax) significantly lower than the current maximum. Together with 'earnings disregards', this is intended to ensure a predictable and consistent financial gain for people coming off benefits and starting work.

33. Minister Grant Shapps told us that DCLG is "100% signed up to the principle that work should always pay. [...] a smooth, tapered Universal Credit is something of which DCLG is every bit as supportive as DWP".[72] We heard scepticism from some witnesses that both policies could be achieved. Dr Peter Kenway told us that policy development on Council Tax Benefit betrayed "a fundamental clash of objectives":

Are we trying to save money, which is the Treasury objective; are we trying to localise, which I think is the objective of the Department for Communities and Local Government; or are we trying to make sure that work pays and welfare reform works, which is a DWP objective? I do not think they can square all three.[73]

34. Some have argued that the solution is simply to incorporate support for council tax into the Universal Credit. The BenX Review Group countered that, were this to be done, either a complex mechanism for paying the benefit amount directly to local authorities would need to be put in place, or, if paid direct to the customer, local authorities would be put in the position of having to collect 100% of council tax, which would likely lead to soaring arrears.[74] Any difficulties in collecting council tax would result in "disastrous" financial pressures on local authorities.[75]

35. The analyses of marginal deduction rates in the White Paper assume that individuals are receiving help with council tax, which may not always be the case under varying criteria of local schemes.[76] Dr Peter Kenway argued that, if localised council tax support schemes have to preserve the 65% withdrawal rate of Universal Credit, this would "require in a sense the thing to be designed by DWP and […] designed top down."[77] The consultation document states that:

to help local authorities to develop schemes which support the work incentives that Universal Credit is intended to deliver, the Government invites views on proposed national guidelines, guidance and model schemes for the design of local support schemes so that the two systems work effectively together to provide strong, transparent work incentives for individuals.[78]

However, the document invites views rather than giving details about what the national framework might be that would ensure this.

36. The Government has committed to maintaining the current level of council tax support given to pensioners. The consultation document proposes that "the criteria, allowances and awards for council tax support to pensioners which local authorities will need to provide for in their local schemes" will be prescribed nationally.[79] This means that councils will essentially only be designing schemes for working-age claimants, although support for both working-age and pensioner claimants will be paid locally. The document suggests that councils might consider guarantees of protection to other vulnerable groups in addition to pensioners, and asks for views on the best way to balance protection for such groups with local authority flexibility.[80]

37. The announcement in the 2010 Spending Review that support for council tax would be localised was accompanied by an announcement that the Government intended to reduce spending on Council Tax Benefit by 10%.[81] Local authorities will have a reduced grant to pay for CTB, and make their own decisions to determine eligibility. The reduction in spending is projected to save £490m each year from 2013-14.[82] The prospect of this reduction has caused considerable concern, both in terms of its impact on claimants and potential claimants, and the consequences for local authority finances more generally.[83] London Councils stated that

the cuts to CTB funding will come into force at a time when overall funding available to local authorities is vastly reduced. [...] Against this backdrop, CTB paid in England has been steadily increasing in all regions over the 13 years up to 2009-10. This data is supported by the overall increase in the numbers of CTB claimants receiving 100% benefit. […] The 10% funding reduction has clear implications for the amount of CTB paid in local areas—it is likely that some CTB claimants (existing and new) will see a reduction in the amount of benefit that they are paid.[84]

Cllr Peter Fleming told us that

if you look at the people who receive Council Tax Benefit at the moment and take out of the process those who get 100% Council Tax Benefit and older people, you are left with only 9% of people not within those two groups. […] If you are then talking about a 10% reduction in the total, those 9% will carry an awfully large weight of expectation of picking up that cut in CTB funding.[85]
Table 1

Approximate impact of 10% cut to CTB if over 65s protected

This simplified illustration is based on the average of monthly 2010-11 figures and assumes no changes to recipient numbers:

Annual CTB bill of £4.817 billion, with 5.8 million recipients:

CTB recipients over 65: 2.2 million at average claim £835.33 per year = £1.857 billion
CTB recipients under 65: 3.6 million at average claim £825.33 per year = £2.960 billion

If total CTB bill to be cut by 10% to £4.335 billion:

CTB recipients over 65: 2.2 million at average claim £835.33 per year = £1.857 billion
CTB recipients under 65: 3.6 million at average claim £691.02 per year = £2.478 billion

Non-pensioners would therefore face an average cut of 16% in their council tax support. Protection for other vulnerable groups, for example those who currently receive 100% Council Tax Benefit, would exacerbate this effect.

Sources: House of Commons Scrutiny Unit based on DWP figures at http://research.dwp.gov.uk/asd/asd1/hb_ctb/hbctb_release_jul11.xls

38. The consultancy Navigant has commented that the point at which this reduction will take effect—2013-14—is the point in the Spending Review cycle at which local authorities had been expecting some respite from overall budget cuts. Navigant argued that, rather than the average council grant reductions of 0.8% for 2013-14 already announced, the Council Tax Benefit changes could result in average reductions in funding for councils of 2.8% and because the benefit is means-tested, more deprived parts of the country would be likely to be the most affected.[86] The New Policy Institute estimated that "the most affected [would lose] more than four times as much per dwelling as the least affected"—figures which Grant Shapps told us assumes a uniform 10% cut across all authorities, which may not be the case.[87] Local authorities could not simply pass on the reduction to claimants without risking increases in council tax arrears, and Alan Barton of Citizens Advice commented that if local authorities decided that all residents needed to pay some council tax, questions would arise about the practicality of collecting many very small amounts.[88]

39. Kirklees Council summarised what it saw as the combined impact all of these constraints would have on its development of a local council tax support scheme:

Regardless of any decision the authority makes about eligibility criteria, a sum equivalent to that 10% must be collected to preserve the revenue stream. That 10% amounts to £3.5 million in this borough and at the lowest council tax payable would amount to a sum of £70 per year. If certain groups (for example pensioners) are protected from any increased liability arising out of localisation then the burden of the 10% cannot be evenly spread. If the intention is that the additional burden becomes part of the incentive to find work, then the inference is that those not in work will shoulder the burden. If we were to assume that the burden for those out of work will approach 20% because of the uneven spread, the risks identified around collection and impact on the revenue stream will be amplified. Council tax is not as progressive as income tax and shifting the cost of welfare benefits on to council taxpayers will increase this. Without further information it is very difficult to see how a localised scheme might operate any differently to the current system of support. Means testing of additional financial support appears to be the only option. If the system operates as a means test then it is conceivable that local decisions about eligibility criteria could operate to undermine the intent of Universal Credit. That fear might be unfounded if local authorities are prevented from increasing the burden for those starting work. In summary it would appear that the 10% saving could increase the burden on those least able to pay and in so doing could compromise local authority revenue streams.[89]

40. The Government's intention to reduce the overall budget for Council Tax Benefit by 10% while preserving work incentives and protecting pensioners from increased council tax bills gives local authorities very little room for manoeuvre in designing their own council tax support schemes. It seems almost inevitable that the impact of the 10% reduction will fall disproportionately on some claimants, and is more likely to be felt in more deprived parts of the country, unless local authorities decide to dip into other funds.

41. The Government has a different view of this issue. Asked whether he expected local authorities to pass on the 10% reduction to claimants, or to dip into other budgets to protect support for those claiming at the moment, Grant Shapps argued that

that is old-school thinking in a sense, because it says that a local authority has no control over what happens in its authority boundaries, what economic activity is like, whether there is growth in the area, whether those business rates are kept, and the New Homes Bonus and the rest of it. [...] What we propose here is a way of achieving a 10% reduction and, at the same time, through giving local authorities a stake in the economic activity, and therefore in the welfare of their citizens, the opportunity to reduce that bill, not by unfairly not paying people who are vulnerable and need it—the White Paper makes very clear that they will be protected—but ensuring that there is a definite interest in starting up that new industrial estate, business park and getting economic activity going so there are jobs [...] if somebody is in work they will not be receiving the [CT] benefit because they will not need to.[90] [...] The culture of 'Let them rot in the houses while we pay them benefit' must come to an end. We have to do this more intelligently and involve the local authorities in the economic activity and success of their areas. Bluntly, I do not think that is worth 10%; it is actually worth a lot more to local authorities, because suddenly they get something back for making sure they are looking after their residents.[91]

42. The 10% saving would, therefore, come from "better management, administration and economic growth".[92] Steve Webb added that the DWP's Work Programme will be targeted at the most deprived areas; "Every person that the Work Programme gets back to work will be less expenditure that the local authority needs to make on Council Tax Benefit."[93] Mr Shapps stated that, at present, any local authorities that are trying to create jobs, wealth and enterprise in their areas "are almost just doing that through the goodness of their own hearts".[94] It seems to us unfair, as well as dismissive of electoral accountability, to categorise local authorities as uninterested in economic growth unless they see pay-offs in their own balance sheet.

43. We agree that it is desirable for local authorities to be able to—in the Minister's phrase—"control their destiny", but the Government should not pretend that control over diminished resources, within centrally-imposed constraints, is unproblematic. Nor can it be considered a great advance for the policy of localism. The proposals for the localisation of council tax support seem to us to provide an illusion of delegation with a minimum of real discretion, virtually guaranteeing that the funds available to support working-age unemployed people will be squeezed.

44. The Government believes the answer to this criticism is economic growth, incentivised by local authorities having to find a 10% saving and wanting to achieve still greater savings. We have seen little evidence to support the hope that new and better-paying jobs for individuals, immediately sufficient to off-set the 10% reduction in the benefit budget, will inevitably follow from these incentives; the means of economic growth are never solely in the gift of individual local authorities. We have commented in a previous report that councils would have welcomed more involvement in the development of the Work Programme to improve their capacity to tackle worklessness. It is not at all clear that the supposed incentives of the new council tax support system will make local authorities feel that they are partners with central government in the achievement of economic development.

Financial risk and management

45. While the Government's intention to achieve 10% savings relies at least to some extent on reductions in the numbers of claimants, other witnesses were concerned about what would happen should there be an increase either in the numbers eligible, or the numbers of eligible people who make claims.[95] CTB has the lowest level of take-up of any means-tested benefit.[96] Council Tax Benefit take-up for 2008-09 was in the range 63% to 70%; the number of people estimated to be entitled to but not claiming Council Tax Benefit was between 2.13 and 2.93 million people. The take-up rate is substantially lower among pensioners than non-pensioners.[97] Cllr Peter Fleming noted that the funding cut could depress efforts to encourage eligible non-claimants, particularly pensioners, to claim: "How much will we be able to encourage them with less money to go round? We can reduce the amount on admin, if it is localised; we can make that money go further, but you cannot start cutting the cash already."[98] It is not known whether the budgets passed on to local authorities will take account of current under-claiming.[99]

46. Council Tax Benefit is currently demand-led, the cost being met by DWP out of Annually Managed Expenditure, the source for expenditure considered volatile and therefore not subject to firm multi-year limits. Localised schemes will instead involve an unringfenced, fixed grant paid to local authorities from DCLG Departmental Expenditure Limits. London Councils explained the challenges it expected local authorities to face in the financial management of local schemes as a result of the fixed and reduced funding:

Should CTB be fully localised, it is unclear how an authority would meet growth in its CTB expenditure. Current regulations would prevent local authorities from borrowing to meet its spending requirements and reduced funding levels will limit the capacity for local authorities to respond to growth through its own resources. Any response by the local authority to do so could have a significant impact on frontline services or council tax levels. The ability of a local authority to manage a demand based benefit from a fixed (and smaller) cash funding pot will be a significant challenge going forward. London Councils officers would suggest that the localisation of Council Tax Benefits could represent a significant financial risk to local authorities should there be no recourse to a more flexible and buoyant funding source.[100]

47. The consultation states that local authorities themselves will need to plan to manage financial risks locally, including contingency arrangements to provide for increased take-up or demand or difficulties with collection. DCLG does not wish schemes to be changed or withdrawn part way through a billing year, or support to be rationed. Collaboration with major precepting authorities (for example, by sharing any shortfall in council tax revenue) is suggested as the default way of managing such risks.[101] Steve Webb told us that

in designing the system the local authority will have to make a realistic assessment of take-up. If it can design a simpler system it will have to allow for the fact that take-up will be higher. That might mean it narrows the scope of what it does but spends that money better, which is the goal of the exercise.[102]

Pressed on whether achieving better take-up among pensioners without disadvantage to existing claimants would entail councils using funding from other budgets, Mr Webb told us that councils "will decide locally what their priorities are".[103]

48. We are concerned about the financial risk to local authorities from assuming responsibility, within a fixed budget, for a means-tested benefit for which demand could increase as well as decrease. Collaboration between councils may share but not remove the risk, at a time when most council budgets will already be stretched to their limit. We recommend that the Government provide some means to access flexible funding to ensure that increased take-up does not result in local authorities either rationing support or raiding other budgets in-year to fulfil the terms of their council tax support scheme. Furthermore, a fixed grant will disincentivise efforts by local authorities to improve take-up among those groups who at present under-claim Council Tax Benefit.

The timescale and timing of change

49. The consultation paper sets out the timetable for implementing change. The consultation closes on 14 October 2011, with the Government's response to be published in autumn/winter 2011-12. A local government finance bill is to be introduced, also in autumn/winter, which the Government expects it to be passed in summer 2012. Local schemes are to be in operation from spring 2013.[104] The timescale of change is the aspect of the reforms that attracted perhaps the most widespread criticism in the submissions to our inquiry. There has been frustration about the long time lag between the initial announcement about localisation in the Spending Review in October 2010 and the publication of the consultation document.[105]

50. Age UK expressed disquiet that the Welfare Reform Bill, which would abolish Council Tax Benefit (and the discretionary Social Fund), was introduced before any detailed proposals for the replacement schemes had been worked out.[106] The New Policy Institute said that it was "rash" to introduce the Bill "before a plausible replacement had been identified", and that

The delay in producing a consultation document suggests that the seriousness of the situation has still not been properly grasped. The replacement of Council Tax Benefit is not some minor procedure for the out-patients department of welfare reform but a major piece of surgery. We think the operation should just be cancelled.[107]

51. Birmingham City Council set out its concerns about the number of tasks that need to be completed for an April 2013 launch:

the design of the local scheme [...] will need to be carefully modelled against both current and predicted expenditure. [...] Proposals will require in-depth impact assessment both for risks and equalities and a significant level of consultation both with elected members and with citizens. Having overcome difficulties in this area there will be work to adapt systems; determine where the work is to be dealt with; training and information to staff; communications with stakeholders and public; and many other tasks. Containing this within an ever-reducing resource will be impossible in our view.[108]

Local authorities also have in mind the need to design specifications for, tender for and thoroughly test new IT systems to support local schemes. Given the limited time available for decisions to be taken, Kirklees Council suggested that many local authorities would purchase a ready-made scheme with associated software, or pool resources with a number of other local authorities, either of which approaches could negate the advantages of local tailoring.[109] London Councils said that April 2013 was "a very challenging target" for the introduction of new council tax support schemes.[110] COSLA argued that "the timelines are so tight as to be unworkable",[111] and Kirklees concluded that "the localisation of CTB support by April 2013 is unrealistic. [...] it would appear wholly unachievable without significant risk across the sector".[112]

52. Any councils hoping to get a head start on designing their schemes may have been left disappointed by the consultation document, which mostly invites views rather than setting out more details of the proposal. Councils now know that there will be a 'national framework' to protect the work incentives of the Universal Credit, and national criteria for support to pensioners, but they do not know what these will be. The consultation offers no firm information about the basis on which grants will be allocated to councils, promising a separate technical consultation on this.[113] Collaboration between local authorities is encouraged, such as a county council or a joint body leading on the design of a single scheme in a given area, arrangements which would require specific legal provisions.[114] Collaborative risk-sharing arrangements also need to be worked out. This will be a time-consuming process.

53. For the IRRV, the question of whether a new system could be delivered to the timescale envisaged was dependent on the resources that would be made available to help it happen.[115] London Councils pointed out that the administration costs to local authorities of the present Council Tax Benefit regime are combined with the costs of administering Housing Benefit (£370 million across England). The consequent economies of scale will not be possible under the new framework, when housing costs support is incorporated into the Universal Credit. No information has yet been published about how local authorities will receive funding for the costs of implementing and administering localised council tax support.[116] The consultation states only that "detailed work will be needed to determine the amount of funding for the administration of local schemes", and makes the commitment that "the Government does not intend the administration of local schemes to put pressure on local government finances."[117]

54. The wisdom of introducing several major changes in a short span of time—the introduction of Universal Credit, changes to the present Housing Benefit regime, reduced local authority budgets, the 10% cut in CTB costs and localisation of both council tax support and the discretionary Social Fund—was questioned by some of our witnesses.[118] There is widespread awareness of the fact that new IT and administration systems could take some time to bed in, and that failures or delays in any of these systems could leave some households in a very precarious position.[119] The BenX Review Group proposed that Housing Benefit and Council Tax Benefit administration could be left with local authorities until Universal Credit (incorporating the other relevant benefits) and real-time integration of earnings with HMRC is well established.[120]

55. We asked Grant Shapps whether, if the consultation throws up concerns about the timescale for implementation, it might be put back. He responded: "We need to follow the evidence; we need to listen to what people are saying to us about implementation. We need it to work. [...] Let's find out what is said through the consultation."[121] However, while the consultation document invites views on the Government's ideal of a one-off transition rather than a staged transfer, and on what help the Government can give local authorities in the transition period, it does not explicitly invite views on whether the timescale is achievable.[122]

56. Consultation at a stage in the process where responses are genuinely able to determine outcomes is of course to be welcomed. But it is regrettable that so much time was allowed to pass between the initial announcement about localisation of council tax support and the publication of a document that invites views but gives very little additional detail about the changes ahead. By the time the Department's response to the consultation is published, there will be little more than a year for local authorities to design and implement their council tax support schemes, which is an extremely challenging timeframe. Too much time has been lost. The Government needs to consider that, even if local authorities prove technically capable of establishing new schemes to the original timescale, it might not be wise to press ahead so hastily. Reform of Council Tax Benefit will affect a huge number of households, and it is vital that the systems used to deliver it are robust.

57. Furthermore, it is unnecessarily risky to introduce a new system for council tax support at the same time as the introduction of Universal Credit and localisation of the discretionary Social Fund. Failure or delays in any part of the new welfare system could leave the most vulnerable households in a precarious position. We recommend that the Government delay the introduction of the new council tax support system by a year or more, if consultation with local authorities indicates that this would reduce the risks inherent in introducing many complex changes concurrently.

55 DWP, Quarterly Statistical Summary, 17 August 2011 Back

56 DCLG, Localising support for council tax in England: consultation, August 2011, para 5.2 Back

57 DWP, Universal Credit: welfare that works, para 36 Back

58 Qq 51-2 Back

59 DCLG, Localising support for council tax in England: consultation, para 1.5 Back

60 Ibid., para 7.1 Back

61 Ibid., para 7.2 Back

62 Ibid., para 4.5 Back

63 Q 58 Back

64 Ev 23 Back

65 Ev w47 Back

66 Q 29 Back