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       #Post#: 116634--------------------------------------------------
       Euro Car Parks_ Overstayed max time_M&S foodhall_Beckenham
   DIR By: Needadvice
       Date: April 21, 2026, 6:00 pm
       ---------------------------------------------------------
       Hello,
       Can anybody advise on this parking charge notice from Euro Car
       Parks please, is this worth appealing?
       The registered keeper has received a Parking Charge Notice from
       Euro Car Parks relating to a stay at an M&S car park in
       Beckenham.
  HTML https://maps.app.goo.gl/WWUkitS3TRQ2GaYx8
       Car park limit: 90 minutes
       ANPR recorded stay: 1 hour 43 minutes (entry 13:15:32, exit
       14:58:24), with ANPR photos of the vehicle number plate on
       entry/exit
       Date of event: 6 April 2026 (Bank Holiday Monday)
       PCN issued: 13 April 2026
       £85 charge, reduced to £50 if paid within 14 days
       The driver entered the car park and, due to it being a busy bank
       holiday, it took some time to find a space.
       Signage is present at the entrance, near the shop entrance, and
       in parts of the main car park. However, the driver eventually
       parked in a smaller bay (approx. 6 spaces) on the opposite side
       where there were no visible signs at all (photos available).
       On leaving, there was congestion: a one-way exit with no
       alternative routes, and a queue of cars waiting at traffic
       lights with a long cycle. This caused delays exiting the site.
       The Notice to Keeper is dated 13 April but was only received on
       20 April, so a week of the reduced payment period has already
       passed.
       Any guidance on the best approach and likelihood of success
       would be much appreciated. Is it worth appealing to Euro Car
       Parks first (and then to POPLA if rejected)?
       Many thanks in advance.
       photos uploaded on ibb, links here:
       
  HTML https://ibb.co/Cptrk593
  HTML https://ibb.co/3549mbCH
  HTML https://ibb.co/gFTP259r
  HTML https://ibb.co/LDB03Tym
  HTML https://ibb.co/M5Dyyf6P
  HTML https://ibb.co/cc2x594W
  HTML https://ibb.co/MyV5sv57
  HTML https://ibb.co/xKKWcMtL
  HTML https://ibb.co/WNSjTyr1
  HTML https://ibb.co/5hXF0vmJ
  HTML https://ibb.co/S433zzND
  HTML https://ibb.co/k2C7MH8b
  HTML https://ibb.co/d0WqMQKF
  HTML https://ibb.co/V0gnX0qj
  HTML https://ibb.co/mCh7tP4g
  HTML https://ibb.co/sJ1wF0CJ
       #Post#: 116638--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: RichardW
       Date: April 22, 2026, 1:37 am
       ---------------------------------------------------------
       You could appeal on the basis that you were unable to leave due
       to traffic congestion - they will probably reject, but it puts
       them on notice.  Make sure you appeal as keeper only, and refer
       to the driver in the 3rd person.  The PCN is missing the
       invitation to pay or name the driver which is a point for POPLA
       or the small claims court if it goes that far.  The signage may
       be a point for POPLA as well - it looks like you parked in the
       small bay on the right of the entrance - if there are no signs
       as you enter, and turn into this area, then you could argue for
       inadequate signage as well - but this will not hold much water
       if you drove around the carpark 3 times first, past all the
       other signs, and then entered the store passing the sign at the
       door (there is one shown on Street View, but it refers to
       different terms)!
       This appears to be an M&S owned car park, so, assuming you were
       a customer, you should also get on to them and ask them to get
       it cancelled.
       #Post#: 116751--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Needadvice
       Date: April 22, 2026, 5:31 pm
       ---------------------------------------------------------
       Hi, thank you very much for your advice. I really appreciate you
       taking the time to respond.
       Just to clarify a couple of points:
       The keeper did contact M&S to see if they could help cancelling
       the charge, but they advised that it is not their car park and
       is privately managed, so they were unable to help.
       Regarding the layout, the bay where the driver parked is
       actually just before the exit. What is quite unusual is that all
       the signage appears to be positioned on the opposite side of
       that bay. On the side where the vehicle was parked, there are no
       visible signs at all, despite there being plenty of space for
       them. It does feel somewhat disconnected from the rest of the
       car park in that sense. I take your point about signage being
       present elsewhere, though.
       Also, thank you for mentioning the wording point on the notice.
       Looking at it more closely, it seems to include some elements of
       the requirements under Protection of Freedoms Act 2012 Schedule
       4, but the wording appears somewhat fragmented and spread out
       rather than set out clearly in one place. Would it be correct to
       understand that this part needs to meet a fairly strict standard
       in terms of how the “invitation” is presented?
       Thank you very much again for your help.
       #Post#: 116765--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Dave65
       Date: April 23, 2026, 4:39 am
       ---------------------------------------------------------
       The keeper did contact M&S to see if they could help cancelling
       the charge, but they advised that it is not their car park and
       is privately managed, so they were unable to help.
       Yet the signage says it is managed on behalf of M&S!
       #Post#: 116819--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Needadvice
       Date: April 23, 2026, 3:23 pm
       ---------------------------------------------------------
       it does sound like the store staff just didn’t want to get
       involved.
       I might try again with someone else at a quieter time. After
       reading some similar cases on here, the point about the NtK
       potentially missing important bits is very valuable. Thanks for
       pointing it out [member=885]RichardW[/member].
       #Post#: 117094--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Needadvice
       Date: April 27, 2026, 5:35 am
       ---------------------------------------------------------
       Quick update, the keeper went back to M&S and asked again about
       cancelling, but was told they can’t cancel as it’s
       managed separately. So looks like the only option now is to
       proceed with an appeal.
       Draft appeal below, any obvious issues before submitting,
       please?
       Also, one more thing that came up when speaking to the store
       staff, they mentioned that the land is actually owned by a
       church, not M&S, which is why they said they couldn’t get
       involved. However, the signage on site says it’s managed
       on behalf of M&S.
       Would that kind of inconsistency be worth raising in terms of
       landowner authority, i.e. asking Euro Car Parks to prove they
       have the right to operate and issue charges there? Or is that
       unlikely to add much in this case?
       ***
       I am the registered keeper of the vehicle and I am appealing
       this Parking Charge Notice.
       The charge is disputed on the following grounds:
       1. No evidence of the required “period of parking”
       The Notice to Keeper does not comply with the requirements of
       Protection of Freedoms Act 2012 Schedule 4, paragraph 9(2)(a),
       as it fails to specify the period of parking.
       The notice relies solely on ANPR images showing entry and exit
       times. These do not represent the period of parking, as they
       include time spent entering, locating a space, and exiting the
       car park.
       2. Failure to account for time not spent parked (grace periods
       and congestion)
       The recorded duration includes time spent:
       - locating a parking space in a busy car park, and
       - queuing to exit due to congestion and a one-way system with
       traffic lights
       This is not parking time and must not be included in any
       calculation of a parking period.
       3. Inadequate signage in the area where the vehicle was parked
       The vehicle was parked in a small bay (approximately 6 spaces)
       near the exit where there was no visible signage at all.
       Signage in other parts of the car park does not sufficiently
       bring the terms and conditions to the attention of drivers
       parking in this specific area.
       As such, no clear contract could have been formed.
       4. Non-compliance with Schedule 4 of PoFA 2012
       The Notice to Keeper appears not to fully comply with the
       mandatory wording and requirements of Schedule 4 of the
       Protection of Freedoms Act 2012, including the requirement to
       clearly and properly set out the conditions under which keeper
       liability may apply.
       As such, the operator cannot transfer liability to the keeper.
       5. No evidence of landowner authority
       The operator is put to strict proof that it has the necessary
       authority from the landowner to issue and enforce parking
       charges at this site.
       There appears to be inconsistency regarding the land ownership
       and management arrangements. Signage suggests the site is
       managed on behalf of Marks & Spencer, while it has been
       indicated that the land may be owned by a third party.
       The operator is required to demonstrate that it has a valid and
       current contract with the landowner (or authorised agent),
       including the authority to:
       - issue parking charge notices, and
       - pursue them to recovery
       In the absence of such evidence, the charge is invalid.
       ***
       Thank you very much once again.
       #Post#: 117134--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: InterCity125
       Date: April 27, 2026, 10:14 am
       ---------------------------------------------------------
       ECP will not uphold the appeal but there is a better chance with
       POPLA since ECP PCNs are not PoFA compliant.
       #Post#: 117155--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Needadvice
       Date: April 27, 2026, 3:08 pm
       ---------------------------------------------------------
       Thank you [member=6750]InterCity125[/member], would it be ok to
       consider this draft for POPLA, I want to make sure that I raise
       relevant points from the outset. Thank you
       #Post#: 118912--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: Needadvice
       Date: May 16, 2026, 5:03 pm
       ---------------------------------------------------------
       Hello,
       Update on this case. I have now received the rejection letter
       from ECP following my initial appeal and they have provided a
       POPLA code. I am attaching the rejection letter (with address
       and number plate redacted). Hope you can see the letter through
       the link here:
  HTML https://ibb.co/XxmQcWCx
       I would really appreciate it if someone experienced could
       comment on whether the points raised in my draft would be
       suitable for a POPLA appeal, whether anything important is
       missing, or if there is anything that could strengthen my
       chances. And if the format is also suitable.
       Thank you very much
       *******
       I am the registered keeper of the vehicle and I am appealing
       this Parking Charge Notice.
       The charge is disputed on the following grounds:
       1. No evidence of the required “period of parking”
       The Notice to Keeper does not comply with the requirements of
       Protection of Freedoms Act 2012 Schedule 4, paragraph 9(2)(a),
       as it fails to specify the period of parking.
       The notice relies solely on ANPR images showing entry and exit
       times. These do not represent the period of parking, as they
       include time spent entering, locating a space, and exiting the
       car park.
       2. Failure to account for time not spent parked (grace periods
       and congestion)
       The recorded duration includes time spent:
       - locating a parking space in a busy car park, and
       - queuing to exit due to congestion and a one-way system with
       traffic lights
       This is not parking time and must not be included in any
       calculation of a parking period.
       3. Inadequate signage in the area where the vehicle was parked
       The vehicle was parked in a small bay (approximately 6 spaces)
       near the exit where there was no visible signage at all.
       Signage in other parts of the car park does not sufficiently
       bring the terms and conditions to the attention of drivers
       parking in this specific area.
       As such, no clear contract could have been formed.
       4. Non-compliance with Schedule 4 of PoFA 2012
       The Notice to Keeper appears not to fully comply with the
       mandatory wording and requirements of Schedule 4 of the
       Protection of Freedoms Act 2012, including the requirement to
       clearly and properly set out the conditions under which keeper
       liability may apply.
       As such, the operator cannot transfer liability to the keeper.
       5. No evidence of landowner authority
       The operator is put to strict proof that it has the necessary
       authority from the landowner to issue and enforce parking
       charges at this site.
       There appears to be inconsistency regarding the land ownership
       and management arrangements. Signage suggests the site is
       managed on behalf of Marks & Spencer, while it has been
       indicated that the land may be owned by a third party.
       The operator is required to demonstrate that it has a valid and
       current contract with the landowner (or authorised agent),
       including the authority to:
       - issue parking charge notices, and
       - pursue them to recovery
       In the absence of such evidence, the charge is invalid.
       #Post#: 118926--------------------------------------------------
       Re: Euro Car Parks_ Overstayed max time_M&S
       foodhall_Beckenham
   DIR By: InterCity125
       Date: May 17, 2026, 1:48 am
       ---------------------------------------------------------
       Euro Car Parks POPLA Appeal
       I am the Registered Keeper of the vehicle in question and, since
       the driver is not known to the operator, I will be making my
       representations purely as keeper.
       I understand that, under 'POPLA Rules', I must set out my appeal
       points and the parking operator must rebut them?
       Non compliance with PoFA 2012.
       The parking operators NtK fails to comply with PoFA and, as a
       result, liability cannot be passed from driver to keeper.
       In particular, the NtK fails to satisfy the legal requirements
       of PoFA Schedule 4 Paragraph 9(2)(e), 9(2)(e)(i) and
       9(2)(e)(ii).
       This non compliance is immediately fatal to the operators
       reliance on PoFA.
       Paragraph 9(2)(e), 9(2)(e)(i) and 9(2)(e)(ii) sets out the
       following;
       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;
       So, in order to establish compliance, we must examine the
       operators NtK.
       An examination of the legislation surrounding 9(2)(e) reveals
       that compliance is achieved by the setting out of the statutory
       wording immediately followed by a two limbed 'invitation to the
       keeper' to either 'pay the unpaid parking charges' or 'nominate
       another driver'.
       So, to make this really easy, in the first instance, we are
       looking for the specific statutory wording set out in 9(2)(e)
       itself.
       The legislation specifies that 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"
       An examination of the operators NtK reveals that the statutory
       wording is not present.
       This is immediately fatal to the operators reliance on PoFA.
       However, to demonstrate my appeal point further, the NtK is then
       required to present a two limbed 'invitation to the keeper'
       which 'invites 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'
       Please again note the exact wording of the statute;
       That 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— blah blah blah
       I have capitalised  the word AND for good reason since the word
       AND demonstrates that compliance is only achieved if the
       operator is able to demonstrate that both legs of the AND logic
       have been satisfied.
       Please note (and I apologise for sounding like a Junior School
       Teacher) that a 'warning to the keeper' is not 'an invitation to
       the keeper' - The words 'warn' and 'invite' have very different
       meanings and it is important that the correct wording is
       understood and applied when examining the NtK since other terms
       of the legislation require that 'a warning' be set out on the
       NtK - I understand that some POPLA assessors have become
       confused on this issue in the past and have inadvertently
       applied the reversed meanings - to be clear, a warning is not an
       invite.
       So, back to the two limbed invitation to the keeper - when the
       NtK is examined the two limbed invitation is not present.
       Nor is there an 'invitation to the keeper to pay the unpaid
       charges' - this is also the specific requirement of 9(2)(e)(i).
       So, as I am sure you can see, there are multiple compliance
       issues on the operators NtK.
       So,
       APPEAL POINT ONE - That the operators NtK does not contain the
       legally required mandatory wording required by 9(2)(e), namely;
       "the creditor does not know both the name of the driver and a
       current address for service for the driver" - I therefore ask
       the operator to specifically rebut this appeal point by
       supplying a copy of the relevant NTK, to the POPLA Assessor,
       with an orange rectangle around the wording, "the creditor does
       not know both the name of the driver and a current address for
       service for the driver" - for total clarity, please do not
       include any other notations on the provided NtK - just the
       orange rectangle.
       APPEAL POINT TWO - That, subsequent to the statutory wording
       required by 9(2)(e), the operators NtK does not set out the
       mandatory two legged invitation to the keeper to either pay the
       unpaid parking charges or nominate another driver - Once again,
       I ask the operator to specifically rebut this appeal point by
       supplying a copy of the NtK which clearly sets out, in an orange
       rectangle, the two legged legal invitation which the legislation
       requires in order to be compliant.
       APPEAL POINT THREE - That, in accordance with 9(2)(e) and
       subsequently 9(2)(e)(i), the NtK must 'invite the keeper to pay
       the unpaid parking charges' - Once I again I ask the operator to
       prove that the NtK complies with this requirement - please
       demonstrate the 'invitation to the keeper to pay the unpaid
       charges' - Please do not confuse this 'invitation' with any
       'warning to keeper' contained in the requirements of 9(2)(f).
       If both the Parking Operator and the POPLA Assessor could use my
       numbered points then this would be very useful and should ensure
       that all appeal points are correctly addressed.
       Best wishes,
       xxxxx xxxxxxx
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