Thanks pcb_in. If I understand it right the 220 days includes all holidays. My list of holidays included business and paid holidays, but the UKBA officer didn't make a distinction between them.

My Case: Entered UK on Work Permit in 2005, changed to HSMP and switched jobs, subsequently changing to Tier 1. My Application: ILR, booked an appointment with Solihull PEO for 1st week February. The documents I had taken: 5 years' P60, 5 year bank statements, 5 year pay slips, Life in UK pass ...