Someone earlier posted a screenshot of the part of the document that explains how the 10 point deduction was calculated (too far back to find it right now). But basically, it was related specifically to the amount of losses over the £105 million threshold. If I remember correctly, any overage at all is an automatic 6 points, and then every £5 million chunk of the overage amount garners one more additional point.
They didn't arbitrarily decide on 10 points from scratch, then. It was based on a standard calculation. £19.7 million / £5 = 4 points (they rounded up, ha) + 6 automatic points = 10 point deduction.
What worries me about that is how do we then get that reduced on appeal?
There would only be two ways I could see:
1) Argue that the calculated amount of the losses was wrong, but that only gets us at best 1 or 2 points taken off, as the automatic 6 point deduction would still stand for the existence of any breach at all + whatever amount of losses was still shown to have happened. Plus we did already admit to the breach apparently.
or
2) Argue that the entire system of an automatic 6 points + 1 point per £5 million is unfair. But that would require whatever body who hears the appeal to be willing to overturn the actual punishment structure in general - not only as it applies to us but for all future breaches by anybody. That seems a hard sell too, even if it is the ethically correct one. This is not an ethically correct system we're operating in.
So as much as it pains me, I kind of agree with a few earlier who said the 10 points will stick. I just don't see how we win an appeal without essentially overturning the system, which you know isn't going to happen for us of all clubs.