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#Post#: 120594--------------------------------------------------
ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster - No
LBC yet
DIR By: TesterChavern
Date: June 3, 2026, 9:51 am
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Hi all, first post, looking for a sense check on where I stand
before anything formal arrives.
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THE BASICS
Parking company: Euro Car Parks
Location: Weavers Wharf, Kidderminster
Date of alleged contravention: August 2025
Site type: ANPR, reason given as "no valid payment or validation
to cover duration of stay"
My position: I am the registered keeper. The vehicle was sold a
few weeks after the alleged contravention date.
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THE ISSUE
I never received the original Notice to Keeper. The first
correspondence I was aware of was a letter from Debt Recovery
Plus demanding £170. I believe the NTK may not have reached me
due to the vehicle being sold shortly after the parking date.
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CORRESPONDENCE TIMELINE
Step 1 - My initial contact via ECP website contact form
Upon receiving the DRP letter I submitted a message via ECP's
website requesting a copy of the original notice, photos, and
confirmation of the original charge amount. I cited PoFA 2012
and noted ECP remains the legal creditor.
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Step 2 - ECP's response
ECP replied from a no-reply address stating they could not
accept my correspondence as the matter had been passed to DRP,
and that all communication must now go through them.
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Step 3 - My formal email to ECP appeals address
As I could not reply to the no-reply address I forwarded the
chain to the appeals email listed on their website at the time.
In this email I confirmed I was not refusing payment, offered to
settle at the original charge amount, cited Schedule 4 PoFA 2012
noting ECP remains legal creditor and DRP has no independent
standing, requested ECP either accept direct payment or confirm
they were not pursuing the matter, and noted I did not consent
to further third party data processing under UK GDPR. ECP never
replied.
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Step 4 - Attempted further contact after DCBL letter arrived
When I later tried to chase via the appeals email I received an
automated response stating that address is no longer in use,
directing me to the website contact form. When I used the
contact form I received an automated response saying the matter
had been referred to DCBL and to speak to them. ECP have
effectively closed off all direct communication routes.
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DRP LETTERS
I have DRP chaser letters dated 3rd November, 18th November, 3rd
December and 31st December. I do not have the original DRP
letter or any correspondence before early November as some
letters were lost during a house move. No formal Letter Before
Claim was received at any point during the DRP correspondence
period.
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MOST RECENT DEVELOPMENT
After moving house I received my first ever letter from DCBL
(Direct Collection Bailiffs Ltd) acting for ECP. The letter
states £170 is owed, gives 14 days to pay or contact them,
explicitly states it is NOT subject to High Court or bailiff
action, and says they may recommend their client commence legal
action.
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WHERE I AM NOW
No LBC. No court claim. First DCBL letter only at this stage. I
have copies of my ECP correspondence and the four DRP letters
available if helpful. I did not appeal via POPLA as I was
unaware of the charge until the DRP letter arrived, by which
point that window had long passed.
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MY QUESTIONS
Is the DCBL letter a standard pre-action step or does it
indicate court action is genuinely closer?
Given the NTK was never received, is ECP's keeper liability
position under PoFA 2012 weakened?
Should I respond to DCBL at all, or sit tight?
If a claim arrives, is £170 likely to be the enforceable amount
or would a court reduce it?
Any known history of ECP/DCBL issuing claims for this site or at
this value?
Given ECP have blocked all direct communication routes, does
this strengthen my position at all?
Thanks in advance.
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#Post#: 120596--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: jfollows
Date: June 3, 2026, 9:54 am
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The normal advice is that you should always ignore debt recovery
companies, be they DCBL or Debt Recovery Plus or whoever.
Just note that DCB Legal is a different company and will shortly
send you things like a Letter of Claim and raise a court claim.
In the meantime you should raise a Subject Acess Request to Euro
Car Parks for all the information they hold on you, which will
include the original parking notice.
ECP sending the original notice to the address recorded on the
car’s V5C is a basic requirement. It is unlikely that ECP didn’t
obtain this address, but seeing the original PCN will clarify
this.
If there is any history for this site, you can search the forum
for it.
#Post#: 120610--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: TesterChavern
Date: June 3, 2026, 10:54 am
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Appreciate the reply.
I’ve now sent a SAR via the ICO, mainly to force disclosure of
the NTK, DVLA KADOE logs and full case history so I can confirm
whether PoFA has been properly complied with.
From your experience, how likely is it at this stage that DCB
Legal actually pick this up and issue a Letter of Claim?
#Post#: 120612--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: jfollows
Date: June 3, 2026, 11:02 am
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Very likely.
#Post#: 120613--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: InterCity125
Date: June 3, 2026, 11:09 am
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I can pretty much guarantee you that the ECP issued NtK will not
be PoFA compliant and that, in theory, should make this easy to
defend and they will have no idea who the driver was.
But let's wait for the NtK to arrive to be sure.
ECP normally respond to SAR very quickly - probably because they
see money - maybe they know that SAR requests normal lead to
payment, who knows?
#Post#: 122962--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: TesterChavern
Date: June 25, 2026, 8:13 am
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Thanks for the advice on the SAR. I've now received ECP's
response.
The SAR includes:
ANPR images of the vehicle entering at 12:06:53 and exiting at
12:38:59 on 03/08/2025.
DVLA response showing they requested and received my keeper
details on 08/08/2025.
NTK dated 08/08/2025 and addressed to the correct DVLA address.
A final notification letter dated 07/09/2025.
I genuinely never received the NTK or final notification letter
and only became aware of the charge when DRP started writing to
me. However, ECP now have copies of both documents on file and
the address shown is correct.
I've attached/redacted copies of the NTK wording. I note they
are missing my latest correspondence past my initial email.
Given the above, do any PoFA or procedural issues remain that
are worth pursuing, or does the NTK appear compliant on its
face?
For context, the alleged contravention is "No valid payment or
validation made to cover the duration of stay" at Weavers Wharf,
Kidderminster. The stay was approximately 32 minutes.
Appreciate any views before I decide how to deal with any future
DCB Legal correspondence.
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#Post#: 122981--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: InterCity125
Date: June 25, 2026, 10:15 am
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The NtK is not PoFA compliant.
Can we assume that they have no idea who the driver was?
#Post#: 122990--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: TesterChavern
Date: June 25, 2026, 12:17 pm
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Thanks.
No driver has ever been identified by me and I have never stated
who was driving in any correspondence. The SAR only contains
ANPR images of the vehicle and the DVLA keeper lookup.
If the NtK is not PoFA compliant, does that mean ECP cannot rely
on keeper liability and would instead need to prove who the
driver was?
Also, could you point me to the specific PoFA defect in the NtK
wording? I’d like to understand exactly which requirement of
Schedule 4 you believe has not been met.
#Post#: 123026--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: InterCity125
Date: June 26, 2026, 1:32 am
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This is some comments I made in another Euro Car Parks thread
relating to the evidence ECP provided at the POPLA stage.
This should give you the pointers you are seeking?
Comments on Euro Car Parks evidence.
I note with interest that ECP have not engaged with any of my
evidence or specific appeal points.
This appears to mean an automatic win for the appellant since
the operator is required to rebut each appeal point under POPLA
rules?
However, I note from other appeals on the internet that POPLA
Assessors often break from protocol and ignore these specific
rules.
I will therefore make the following comments based on what the
operator has submitted.
The operator has submitted a generic evidence pack rather than
an evidence pack / response in keeping with my appeal.
This appears deliberate and I believe that they have taken this
approach as they are unable to rebut non PoFA compliance appeal
points using their own NtK because the NtK does not meet the
requirements for either wording or format.
I will once again highlight the short comings of the operators
NtK.
I would request that the POPLA Assessor keeps firmly to my
appeal points in order to make sure all appeal points are
addressed using the legislation.
PoFA Schedule 4 Paragraph 9(2)(b) specifies;
"The notice must inform 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"
However, the operator's notice specifies;
"You are now advised under the paragraph 9(2)(b) of schedule 4
of the Protection of Freedoms Act 2012 that the driver of the
motor vehicle is required to pay this parking charge in full."
You will immediately notice that the operator's sentence fails
to meet the complete requirements of 9(2)(b) - whilst they
specify that the driver is required to pay the parking charge,
the sentence fails to state the second part of the requirement,
namely; that the parking charges have not been paid in full.
In order to demonstrate integrity and transparency, if the POPLA
Assessor believes that the notice does contain the sentence (the
parking charges have not been paid in full) required by 9(2)(b),
I would respectfully ask the Assessor to quote, verbatim, the
sentence from the NtK which meets the two requirements of
9(2)(b).
The missing information is immediately fatal to the operators
reliance on PoFA as total compliance is required.
Further,
PoFA Schedule 4 Paragraph 9(2)(e) specifies 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—
Sub-paragraphs 9(2)(e)(i) and 9(2)(2)(ii) then set out both the
wording and format for the two conditions of the invitation
which 9(2)(e) requires.
The two conditions must be separated by the word 'or' - the word
'or' has a defined legal meaning in legislation so must be
contained in the invitation.
The compliant sentence would therefore read as follows; (or
something very close)
Your are notified under paragraph 9(2)(e) of schedule 4 of the
Protection of Freedoms Act 2012 that 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)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."
The required paragraph containing the statutory wording and two
limbed invitation (separated by the word 'or') is not present on
the operator's NtK.
Once again this immediately fatal to the operator's reliance on
PoFA.
When examined, the operators NtK jumps directly from their
(incorrect) version of 9(2)(b) straight onto the requirements of
9(2)(f) - the requirements of 9(2)(e) are totally over looked.
Once again, in order to demonstrate integrity and transparency,
if the POPLA Assessor believes that the notice does contain the
sentence which specifies both the mandatory wording and two
limbed invitation then I would respectfully ask the Assessor to
quote, verbatim, the sentence from the NtK which meets all the
requirements of 9(2)(e) along with the two conditions of the
keeper invitation specified in sub-paragraphs 9(2)(e)(i) and
9(2)(e)(ii).
This information is not present.
I am happy that paragraph 9(2)(f) is present and compliant but
the presence of 9(2)(f) does not negate the requirements of
9(2)(b) and 9(2)(e).
Feel free to ask any questions.
They will (in 99% of cases) pull out at the Court stage but
you'll need to jump through the hoops.
#Post#: 123028--------------------------------------------------
Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
- No LBC yet
DIR By: TesterChavern
Date: June 26, 2026, 2:42 am
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Thanks, that’s really helpful and I appreciate you taking the
time to explain it.
I’ve never identified the driver in any correspondence, so it
sounds like if ECP can’t rely on keeper liability under PoFA,
they’d need to prove who was driving, which they don’t appear to
have evidence of.
At this stage, is the best approach simply to ignore any further
DCBL letters and wait to see if DCB Legal issue a Letter of
Claim? If they do, I’ll come back here before responding.
Thanks again for your help.
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