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       #Post#: 13634--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: DWMB2
       Date: January 12, 2024, 5:59 am
       ---------------------------------------------------------
       The fact they were prepared to settle up for £15 suggests they
       know they've no case.
       Yes, you'll need to get your POPLA appeal in ASAP - have you
       been drafting one on the basis of the lack of PoFA compliance?
       #Post#: 13636--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: January 12, 2024, 6:06 am
       ---------------------------------------------------------
       Hi, Thanks, Please could you direct me to the link to draft this
       appeal or if there is a draft appeal to use, i can do so.
       #Post#: 13640--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: DWMB2
       Date: January 12, 2024, 6:25 am
       ---------------------------------------------------------
       I'm not sure that there's a template "ready to go" - if you
       search on PePiPoo and the MoneySavingExpert private parking
       forums for Gatwick cases there should be some that have gone to
       POPLA that will have examples you can use to help you. The
       points you should be making will be along the following key
       lines:
       - That you are appealing as the registered keeper, and that NCP
       do not know the identity of the driver, and that you have no
       liability as the keeper because:
       - Parking at Gatwick Airport, including the drop off zones, is
       subject to statutory control, namely byelways, and is therefore
       not 'Relevant Land' as defined by Schedule 4 of the Protection
       of Freedoms Act 2012 (PoFA). As a result of this, they cannot
       use the provisions of PoFA to hold you liable as the registered
       keeper
       - Even if it were relevant land, which is denied, NCP's notice
       does not conform to the requirements of a Notice to Keeper as
       prescribed by paragraph 9 of the Act, as it was not given within
       the relevant period of 14 days of the parking incident, as
       required by 9(4)
       - Signage - Nosy Parker may be more familiar with the issues
       with the signage at Gatwick, but it is known to be shoddy
       The PoFA points should be enough to get POPLA on board. If you
       can draft something up ASAP and show us, ideally today.
       #Post#: 13641--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: January 12, 2024, 7:19 am
       ---------------------------------------------------------
       This is what i have found on mse website:
       I am appealing as keeper. I am not obliged to identify the
       driver and I decline to do so.
       1. The operator is unable to transfer liability to me as keeper
       pursuant to Schedule 4 to the Protection of Freedoms Act 2012
       (“POFA”) because the drop off zones at Gatwick are not ‘relevant
       land’ as defined in POFA.
       2. Even if (which is not the case) the land in question is
       relevant land the operator’s notice was delivered after the
       expiry of the ‘relevant period’ as defined in POFA paragraph
       9(5).
       3 In addition the operator’s notice does not conform to the
       requirements set out in POFA paragraphs 9(2)(f).
       Furthermore, as keeper I am entitled to all the defences
       available to the driver including (without limitation) the
       following:
       4. The parking charge is not notified until after the contract
       is entered into and under the principles set out by the Court of
       Appeal in Thornton v Shoe Lane Parking, does not form part of
       the contract between the driver and the operator;
       5 The signage is not compliant with the BPA Code of Practice.
       #Post#: 13648--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: H C Andersen
       Date: January 12, 2024, 9:06 am
       ---------------------------------------------------------
       If POPLA allow up to 33 days from the date of the operator's
       letter then this is Sat. 13th. (letter dated 11 Dec.)
       If not, then you're likely to be too late.
       Get what you've got submitted ASP.
       But POPLA isn't a judicial proceeding, the only one which counts
       is civil court.
       Not only are you not required to name the driver, you're under
       no legal duty to respond to their drivel. Just because they
       initiate correspondence doesn't mean it has any legal
       significance, and theirs doesn't because the only relevant
       statute, Sch. 4 Protection of Freedoms Act 2012, specifically
       excludes such a claim from its scope!
       As others know, I don't agree with the template because
       implicitly it subscribes to a legally false premise e.g. of
       course their notice doesn't comply with PoFA, it never sought
       to; and it makes no demands on the keeper etc.
       But we don't have time to debate this - go with what you've got
       and hope you're not too late.
       #Post#: 13652--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: January 12, 2024, 9:52 am
       ---------------------------------------------------------
       Sure, thanks, I have appealed it now.
       #Post#: 13693--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: Nosy Parker
       Date: January 13, 2024, 2:17 am
       ---------------------------------------------------------
       You can add the following at a later stage when you get the
       opportunity to comment on NCP's case - if they even bother to
       oppose the appeal:
       Attention is drawn to the fact that POPLA's Complaints Team has
       twice issued apologies for assessors wrongly applying keeper
       liability for parking on airport land and confirming that, as
       airport land is not 'relevant land' as defined in POFA, there
       can be no keeper liability for parking on airport land.  The
       most recent apology relates to POPLA case 4822223007 and was
       issued on 7 December 2023.
       #Post#: 15029--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: February 5, 2024, 2:46 am
       ---------------------------------------------------------
       Hello experts, I recieved an email 30th Jan from Popla that NCP
       has now uploaded its evidence and I have got 7 days from the
       date of this correspondence to provide any comments. Should I
       add any comments?
       #Post#: 15032--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: Nosy Parker
       Date: February 5, 2024, 3:23 am
       ---------------------------------------------------------
       --- Quote from: Nosy Parker link ---
       >
       >
       > You can add the following at a later stage when you get the
       opportunity to comment on NCP's case - if they even bother to
       oppose the appeal:
       >
       > Attention is drawn to the fact that POPLA's Complaints Team
       has twice issued apologies for assessors wrongly applying keeper
       liability for parking on airport land and confirming that, as
       airport land is not 'relevant land' as defined in POFA, there
       can be no keeper liability for parking on airport land.  The
       most recent apology relates to POPLA case 4822223007 and was
       issued on 7 December 2023.
       >
       --- End Quote ---
       Did you mean to ask us whether you should comment on the
       operator’s evidence without showing that evidence to us, or are
       you about to post it for us to review?
       If the latter, please obscure any information that could
       identify you (POPLA code, PCN number, vehicle number, name,
       address). Use an external hosting site such as www.imgur.com and
       post the link.
       If the former, then obviously we can’t advise beyond repeating
       the statement I previously advised you to include in your
       comments.
       #Post#: 15033--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: Nosy Parker
       Date: February 5, 2024, 3:28 am
       ---------------------------------------------------------
       PS As you received the POPLA email on 30 January, that date is
       day 1 of your 7 days to respond and today is the last day.
       So you must act today if you want to comment on the operator’s
       evidence. If you say nothing else, at least say what I advised
       you twice to say.
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