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       #Post#: 115191--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: jfollows
       Date: April 3, 2026, 3:37 pm
       ---------------------------------------------------------
       You need to rebut any of the points they make with which you
       disagree, otherwise they will claim that you agree with them.
       If you post your draft response here before sending it, you will
       get input.
       #Post#: 115193--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: Sm86
       Date: April 3, 2026, 3:47 pm
       ---------------------------------------------------------
       To be honest it's all a bit confusing to me and I have just been
       following [member=6750]InterCity125[/member] guidance
       Hopefully he will see me through this 🙏🏻
       #Post#: 115200--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: InterCity125
       Date: April 4, 2026, 2:14 am
       ---------------------------------------------------------
       I can come up with something.
       They're on the ropes with the PoFA compliance issue - we can now
       exploit this.
       #Post#: 115202--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: InterCity125
       Date: April 4, 2026, 3:23 am
       ---------------------------------------------------------
       Comments on operator's evidence.
       In the first instance, the operator has not rebutted any of my
       appeal points using their provided NtK - this is because the NtK
       is not compliant - providing their NtK would only prove
       non-compliance and, as such, they have avoided this situation.
       The parking operator states, "The NtK substantially complies
       with PoFA requirements" - 'substantial compliance' is NOT
       sufficient for PoFA Schedule 4 since the legislation states that
       compliance occurs, "if ALL the applicable conditions under this
       Schedule are met" - an admission of substantial compliance is an
       admission that the notice is not totally compliant.
       The operator states, "The legislation does not require verbatim
       replication of statutory wording, but rather that the notice
       conveys the required information clearly " - this is a totally
       unsupported legal assertion - the wording used in the
       legislation is totally objective in nature and the operator has
       provided no legal evidence to support their claim - the operator
       is deliberately trying to introduce subjectivity to term 9(2)(e)
       when the wording is legally tight.
       The operator attempts to show compliance with 9(2)(e) where they
       state, "The NtK confirms that liability may be transferred to
       the keeper in the absence of driver details, thereby fulfilling
       the statutory intent" - This is not a correct interpretation of
       9(2)(e) - The operator has fallen into the trap which I
       mentioned in my initial appeal; namely, they are attempting to
       use the wording from 9(2)(f) (the transfer of liability after 28
       days) to satisfy the requirements of 9(2)(e) - the warning that
       liability could be transferred bears no relevance to the
       requirement set out in 9(2)(e) which specifies 'that the notice
       must state that the creditor does not know the name and address
       of the driver' - the 'statutory intent' is not therefore met
       since the two sentences have totally different and unrelated
       meanings - ultimately, the operator could easily show compliance
       with 9(2)(e) by providing their NtK and marking the relevant
       statement with an orange rectangle as I requested in my appeal
       point - they avoid this request because the specific wording is
       not present on their NtK.
       9(2)(e) specifies;
       The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver AND invite the keeper—
       (i)to pay the unpaid parking charges; or
       (ii)if the keeper was not the driver of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver;
       In this instance, the words MUST STATE can have no other
       interpretation - importantly, the legislation does not say MUST
       IMPLY or MUST SUGGEST - the wording couldn't be legally tighter
       - in simple terms, the notice does not contain any sentence of
       wording which reflects the requirements of 9(2)(e) and therefore
       the notice is not compliant with Schedule 4.
       Furthermore, there is no two limbed 'invitation to the keeper'
       to either 'pay the unpaid parking charges' or 'if the keeper was
       not the driver of the vehicle, to notify the creditor of the
       name of the driver and a current address for service for the
       driver and to pass the notice on to the driver' - the suggestion
       that other parts of the notice loosely satisfy those
       requirements is nonsense since the legislation requires that the
       invitation is presented in a clear fashion with the two limbed
       choice directed at the keeper and that this two limbed
       invitation must be given immediately after the statutory wording
       specified by 9(2)(e).
       The operator makes NO ATTEMPT to demonstrate the correct
       presentation of the two limbed invitation and the method of
       suggested compliance is demonstrably chaotic.
       If both the sentence and two limbed choice is in fact present on
       the NtK then I now invite the POPLA Assessor to clearly set out
       the sentence and two limbed invitation? PLEASE DO NOT SKIP OVER
       THIS POINT - Please use the numbered appeal points in my
       original appeal as to ensure that all appeal points are
       addressed.
       Compliance is actually achieved with the following paragraph;
       >>>>>>>>>>
       At the present time the creditor does not know both the name of
       the driver and a current address for service for the driver.
       The Keeper is therefore invited to;
       i) Pay the unpaid parking charges;
       Or
       ii) if the keeper was not the driver of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver.
       >>>>>>>>>>
       Many thanks.
       #Post#: 115212--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: Sm86
       Date: April 4, 2026, 2:24 pm
       ---------------------------------------------------------
       I submitted this today.  Thanks so much for all your help, it
       really is appreciated.  I will keep you updated on the outcome.
       #Post#: 115272--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: InterCity125
       Date: April 7, 2026, 2:57 am
       ---------------------------------------------------------
       Quick question; is it possible to either amend or add further
       comments on the operators evidence?
       I've noticed a couple of extra points which may add weight to
       the non-compliant NtK.
       #Post#: 115273--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: DWMB2
       Date: April 7, 2026, 3:09 am
       ---------------------------------------------------------
       I'm fairly sure you can't once submitted.
       #Post#: 115274--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: Sm86
       Date: April 7, 2026, 3:23 am
       ---------------------------------------------------------
       Unfortunately not.  It says once submitted that's it.
       #Post#: 121036--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: Sm86
       Date: June 7, 2026, 3:59 pm
       ---------------------------------------------------------
       Some bad news arrived today.  Popla rejected the appeal.
       This was their response -
       Decision
       The operator has provided photographic evidence of the signage
       in place in the car park, which details the terms and conditions
       of parking. The signs advise that the car park is an authorised
       users only car park. The signage goes on to state that failure
       to meet the above terms will result in a PCN being issued for
       £100. The Protection of Freedoms Act (PoFA) is a law that allows
       parking operators to transfer liability to the registered keeper
       in the event the driver or hirer is not identified. In this
       case, it is not clear who the driver of the appellant’s vehicle
       is, so I must consider the Protection of Freedoms Act (PoFA)
       2012, as the operator issued the Parking Charge Notice (PCN) to
       the keeper of the vehicle. The operator has provided me with a
       copy of the notice to keeper sent to the appellant. I have
       reviewed the notice to keeper against the relevant sections of
       PoFA 2012 and I am satisfied that it is compliant. I will
       therefore be assessing the appellant’s liability as the keeper
       of the vehicle. Furthermore, I acknowledge their comments about
       the words on POFA being verbatim, however, this is not the case.
       The requirements of 9(2)(a) to (i) must state the various
       requirements. Whilst I concede that they have not followed the
       exact format from (a) to (i), and possibly not the words to the
       letter, they have covered all the requirements of POFA. The PCN
       is issued within 14 days of the parking event. The PCN
       stipulates the reason for the PCN and includes images of the
       offending vehicle. The PCN informs the keeper that the driver is
       required to pay parking charges in respect of the specified
       period of parking and that the parking charges have not been
       paid in full; and describe the parking charges due from the
       driver as at the end of that period, the circumstances in which
       the requirement to pay them arose (including the means by which
       the requirement was brought to the attention of drivers) and the
       other facts that made them payable. It goes on to specify the
       total amount of those parking charges that are unpaid, as at a
       time which is specified in the notice; and no later than the end
       of the day before the day on which the notice is either sent by
       post or, as the case may be, handed to or left at a current
       address for service for the keeper (see sub-paragraph (4)). It
       also says that the creditor does not know both the name of the
       driver and a current address for service for the driver and
       invite the keeper— to pay the unpaid parking charges; or if the
       keeper was not the driver of the vehicle, to notify the creditor
       of the name of the driver and a current address for service for
       the driver and to pass the notice on to the driver. The PCN also
       makes it clear that Secure Parking Solutions LTD is the
       creditor. The PCN warns the keeper that if, after the period of
       28 days beginning with the day after that on which the notice is
       given— the amount of the unpaid parking charges specified under
       paragraph (d) has not been paid in full, and the creditor does
       not know both the name of the driver and a current address for
       service for the driver, the creditor will (if all the applicable
       conditions under this Schedule are met) have the right to
       recover from the keeper so much of that amount as remains
       unpaid. The PCN also goes on to inform the keeper of any
       discount offered for prompt payment and the arrangements for the
       resolution of disputes or complaints that are available,
       identify the creditor and specify how and to whom payment or
       notification to the creditor may be made specify the date on
       which the notice is sent (where it is sent by post) or given (in
       any other case). Therefore, I am satisfied that the PCN meets
       POFA. I acknowledge they feel the never rebutted their appeal
       points during the initial appeal. If the appellant has any
       issues surrounding the operator’s appeal process, they will need
       to take this up with the operator directly. POPLA is an appeals
       service; we are unable to comment on the operator’s appeal
       process. Customer service issues should be directed to the
       operator. Ultimately, it is the responsibility of the motorist
       to ensure compliance with the terms and conditions of the car
       park. In this instance, as the driver was not a authorised to
       use the car park, they were not permitted to park in the car
       park. Accordingly, I must refuse this appeal.
       #Post#: 121062--------------------------------------------------
       Re: Parking on pavement in front of shop (Cake Box, Small Heath,
       Coventry Rd)
   DIR By: InterCity125
       Date: June 8, 2026, 1:58 am
       ---------------------------------------------------------
       What was the assessors name?
       There's a clear error in the assessment.
       We can formulate a complaint.
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