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       #Post#: 118971--------------------------------------------------
       Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 17, 2026, 12:05 pm
       ---------------------------------------------------------
       Dear all,
       I'd appreciate advice on a Notice to Keeper received from Euro
       Car Parks. I am the Registered Keeper of the vehicle.
       Summary of events:
       On 18/04/2026, the driver entered the Horse & Barge car park
       (Duke Street, Thorn Lane, Reading, RG1 2AG) at 13:37 per the
       ANPR entry time on the PCN.
       The driver remained in the vehicle for a period after arrival.
       When the driver attempted to pay via the Pay by Phone app,
       internet connectivity issues delayed the transaction although no
       proof is present. The driver eventually started a paid Pay by
       Phone session at 14:17 for £5.70 (Receipt available), with the
       session set to expire at 18:00.
       The vehicle exited the car park at 18:10:00 per the ANPR exit
       time — 10 minutes after the paid session expired.
       PCN details:
       Date of Event: 18/04/2026
       Date Issued: 23/04/2026 (5 days after event)
       Contravention stated on PCN: "The vehicle was parked without a
       valid Pay by Phone transaction"
       Entry: 13:37 / Exit: 18:10:00 / Time in car park: 4h 33m
       Charge: £100 (reduced to £60 if paid within 14 days, by
       07/05/2026)
       Issued under Schedule 4 of the Protection of Freedoms Act 2012
       Operator is a BPA Approved Operator
       No comms held with Euro Car Parks till date.
       Points I'd like advice on:
       The stated contravention is "parked without a valid Pay by Phone
       transaction", however a valid Pay by Phone transaction was made
       (£5.70, session 14:17–18:00). A receipt from the Pay by Phone
       app is available. Does the misstatement of the contravention
       itself give grounds to challenge? I understand the parking
       ticket started later than entry time.
       The period between ANPR entry (13:37) and start of paid session
       (14:17) is approximately 39 minutes. Is this defensible in the
       appeal considering the failed attempts earlier by the driver,
       although no proof?
       Any POFA Schedule 4 compliance issues to flag on the wording of
       the NTK?
       The paid session expired at 18:00 and the vehicle exited at
       18:10:00 — exactly 10 minutes after expiry. Under the BPA Code
       of Practice, a minimum grace period is required after the paid
       period ends before a PCN can be issued. Is the overstay
       defensible on this basis?
       No appeal has been submitted yet. PCN images, payment receipt
       and signage photos links are given below.
       What is the best course of action at this stage?
       Thanks in advance for any advice.
       PCN Front:
  HTML https://ibb.co/zVYw3ZPg
       PCN Back:
  HTML https://ibb.co/Q7KW6SQC
       Parking payment receipt:
  HTML https://ibb.co/zTsgPX93
       Notice images at the parking:
  HTML https://ibb.co/YF769TX0
  HTML https://ibb.co/pjDXzHff
       #Post#: 119019--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 18, 2026, 3:47 am
       ---------------------------------------------------------
       Any comment is appreciated, thanks!
       #Post#: 119024--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Dave65
       Date: May 18, 2026, 4:35 am
       ---------------------------------------------------------
       There must be other signage within the car park, warning of the
       charge if the terms are not met (such as £100).
       #Post#: 119030--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 18, 2026, 5:12 am
       ---------------------------------------------------------
       --- Quote from: Dave65 link ---
       >
       > There must be other signage within the car park, warning of
       the charge if the terms are not met (such as £100).
       >
       --- End Quote ---
       Hi,
       Yes there is inside as well, see link below, thanks.
  HTML https://ibb.co/yn1qzy74
       I will attach it in the original post.
       Regards
       #Post#: 119132--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 19, 2026, 3:13 am
       ---------------------------------------------------------
       Please, any thoughts on this will be appreciated. Thanks!
       #Post#: 119147--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Dave65
       Date: May 19, 2026, 4:29 am
       ---------------------------------------------------------
       The code of practice on the BPA says any charge should be
       predominately displayed, this is not.
       Also, from a post by a previous poster b789 says that ECP will
       almost discontinue their claim before they have to pay the court
       fee.
       Have a search on the search box for posts "ECP"
       #Post#: 119149--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Dave65
       Date: May 19, 2026, 4:32 am
       ---------------------------------------------------------
       By b789
       ECP reply by b789 November 05 2025
       ECP NtKs are never fully compliant with PoFA. They all fail PoFA
       para 9(2)(e)(i). Whilst ECP would not agree and most POPLA
       assessors are too intellectually malnourished or plainly moronic
       to understand, you still go through the motions.
       What I can assure you of, with greater than 99.9% certainly, is
       that if you follow the advice, you will not have to pay a penny
       to ECP.
       For now, simply appeal to ECP. There is no legal obligation on
       the known keeper (the recipient of the Notice to Keeper (NtK))
       to reveal the identity of the unknown driver and no inference or
       assumptions can be made.
       The NtK is not compliant with all the requirements of PoFA which
       means that if the unknown driver is not identified, they cannot
       transfer liability for the charge from the unknown driver to the
       known keeper.
       Use the following as your appeal. No need to embellish or remove
       anything from it:
       Quote
       I am the keeper of the vehicle and I dispute your 'parking
       charge'. I deny any liability or contractual agreement and I
       will be making a complaint about your predatory conduct to your
       client landowner.
       As your Notice to Keeper (NtK) does not fully comply with ALL
       the requirements of PoFA 2012, you are unable to hold the keeper
       of the vehicle liable for the charge. Partial or even
       substantial compliance is not sufficient. There will be no
       admission as to who was driving and no inference or assumptions
       can be drawn. ECP has relied on contract law allegations of
       breach against the driver only.
       The registered keeper cannot be presumed or inferred to have
       been the driver, nor pursued under some twisted interpretation
       of the law of agency. Your NtK can only hold the driver liable.
       ECP have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       When that is rejected, you will have 33 days to make a POPLA
       appeal, which for this operator would include the following
       point, amongst the others:
       Quote
       Schedule 4 paragraph 9(2) is binary (“MUST” means all or
       nothing) and this NtK omits the mandatory invitation to the
       keeper to pay under 9(2)(e)(i)
       Schedule 4 paragraph 9(2) does not say the notice should include
       certain things. It says: “The notice must — (a)… (b)… (c)… (d)…
       (e)… (f)… (g)… (h)… (i)…”. “Must” is compulsory. PoFA 9(2) is a
       statutory gateway to keeper liability: either every required
       element is present or the gateway never opens. There is no such
       thing as “partial” or even “substantial compliance” with 9(2).
       Like pregnancy, it is binary: a notice is either PoFA-compliant
       or it is not. If one required limb is missing, the operator
       cannot use PoFA to pursue the keeper. End of.
       Here the missing limb is 9(2)(e)(i). That sub-paragraph requires
       the NtK to invite the keeper to pay the unpaid parking charges.
       The law is explicit that the invitation must be directed to “the
       keeper”. It is not enough to tell “the driver” to pay; it must
       invite “the keeper” to pay if the creditor wants keeper
       liability.
       What this NtK actually does is talk only to “the driver” when
       demanding payment, and nowhere invites “the keeper” to pay. The
       demand section of the NtK is framed in driver terms (e.g.
       language such as “the driver is required to pay within 28 days”
       / “payment is due from the driver”), and there is no sentence
       that invites “the keeper” to pay the unpaid parking charges. The
       word “keeper” (if used at all) appears only in neutral
       data/disclosure paragraphs or generic definitions, not in any
       invitation to pay. That omission is precisely what 9(2)(e)(i)
       forbids.
       For the avoidance of doubt, 9(2)(e) contains two limbs: (i) an
       invitation to the keeper to pay, and (ii) an invitation to
       either identify and serve the driver and to pass the notice to
       the driver. Even setting aside 9(2)(e)(ii), the absence of the
       9(2)(e)(i) keeper-payment invitation alone is fatal to PoFA
       compliance. The statute makes keeper liability contingent on
       strict satisfaction of every “must” in 9(2). Where a notice
       invites only “the driver” to pay, it fails 9(2)(e)(i), so it is
       not a PoFA notice. The operator therefore cannot transfer
       liability from an unidentified driver to the registered keeper.
       Only the driver could ever be liable; the driver is not
       identified. The keeper is not liable in law.
       #Post#: 119248--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 19, 2026, 2:04 pm
       ---------------------------------------------------------
       Thank you very much for the suggestion, I will respond as
       suggested.
       Many thanks!
       #Post#: 119267--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Riz101
       Date: May 19, 2026, 5:27 pm
       ---------------------------------------------------------
       Apologies, I'm being extra careful.
       I cannot fully paste the text, last line is cutting off due to
       text limit on ECP appeal page, is it ok to miss the last
       sentence? I will completely drop it if OK?
  HTML https://ibb.co/HfDfqvBw
       #Post#: 119281--------------------------------------------------
       Re: Euro Car Parks PCN - Parked without a valid Pay by Phone
       transaction- Horse & Barge, Reading
   DIR By: Dave65
       Date: May 20, 2026, 4:31 am
       ---------------------------------------------------------
       Well it`s only at the first stage, so be it.
       ECP will almost reject anyway, but you are showing you are not a
       push over.
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