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       #Post#: 23160--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: b789
       Date: May 20, 2024, 6:08 am
       ---------------------------------------------------------
       Doesn’t it let you upload a pdf with your full appeal? If so,
       just put “see uploaded PDF” in the text box.
       Otherwise, what you have is ok. I wouldn’t put too much effort
       into a Plan B appeal with this lot of scammers.
       #Post#: 24912--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: Jag84
       Date: June 4, 2024, 6:27 am
       ---------------------------------------------------------
       I've got a response back from UKPC and they have rejected my
       appeal
       Attached is image of the first page of the letter and also pdf
       document of the whole letter
       Should I now appeal to POPLA ?
       [attachment deleted by admin]
       #Post#: 24914--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: b789
       Date: June 4, 2024, 6:40 am
       ---------------------------------------------------------
       It is not surprising that UKPC would reject your appeal. You
       should appeal to POPLA and you have 32 days, not the 28 days
       stated to respond. There is no advantage to delaying the POPLA
       appeal but do make sure that you set it out properly.
       POPLA will not consider any mitigation. They will only consider
       breaches of the BPA CoP and other law. You have already
       explained those breaches in your first appeal so they should
       form the basis of your POPLA appeal.
       Mention each breach and then expand on why and how they have
       breached each point. Lead the POPLA assessor by the nose to each
       point. Use simple language as though you are writing a Janet and
       John book for early learners.
       For example, you stated in your original appeal:"The signage in
       the car park is inadequate and fails to comply with the strict
       requirements as required under PoFA 2012 9(2)(c ) to adequately
       bring to the attention of the driver the charge and the other
       facts that made them payable. This is a breach of the BPA Code
       of Practice (CoP) 19.4." Expand on why failure to "...adequately
       bring to the attention of the driver the charge..." as required
       under PoFA 9(2)(c ) is also a breach of the BPA CoP section
       19.4.
       You need to look at the BPA CoP and can do so here:
       BPA Approved Operator Code of Practice v9
  HTML https://www.britishparking.co.uk/code-of-practice-and-compliance-monitoring<br
       />and PoFA here:
       The Protection of Freedoms Act 2012 Schedule 4
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted
       Once you have something please post it here so we can critique
       it and adjust if necessary.
       #Post#: 25023--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: Jag84
       Date: June 5, 2024, 11:16 am
       ---------------------------------------------------------
       Below is my initial draft. For the last paragraph is there any
       rule I can quote that parking bays should be sufficiently wide
       for safe parking ?
       The relevant sign was positioned quite far up and surrounded by
       bags of compost from local store therefore  not easy to access
       or read. Strangely the parking company did not provide
       photograph of this particular sign ,the nearest and only one in
       this car park section,  but instead from different section of
       the car park. Blocked access to the signage failed to comply
       with terms of  "BPA Approved Operator Code of Practice". Notably
       on the two points below
       - "Signs must be conspicuous and legible"
       - "they are easy to see, read and understand."
       Access to  signage was inadequate and therefore failed to comply
       with the strict requirements as required under PoFA 2012 9(2)(c)
       to adequately bring to the attention of the driver the charge
       and the other facts that made them payable. This is a breach of
       the BPA Code of Practice (CoP) 19.4. I have attached a
       photograph of the sign where access was blocked
       Bay lines are worn and faded breaching the "Surface markings –
       delineated parking bays" condition 19.11. Lack of clear
       demarcation contributes significantly to the difficulty the
       driver would have parking in a precise manner.
       The driver did not park outside of the bay. The vehicle was
       positioned on the line, not beyond it. Additionally, as
       demonstrated in the photos, the neighbouring car was parked in a
       similar manner which obviously necessitated that the driver park
       as far to the right as possible to maintain a safe distance
       between vehicles.
       It is clear in this case the bays provided are not sufficiently
       wide for safe parking, as illustrated in the photos. The
       inadequate width of the bays makes it challenging for any driver
       to park without encroaching on the lines.
       #Post#: 25028--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: b789
       Date: June 5, 2024, 11:59 am
       ---------------------------------------------------------
       Do you have or can you get some photos of the signs that were
       obscured?
       What about considering some of these POPLA appeal points you
       could use?
       Non-compliance with BPA CoP 19.2 and Appendix B - Entrance signs
       Non-compliance with BPA CoP 19.3 & 19.9 - Specific parking-terms
       signage
       Non-compliance with BPA CoP 20.3 - Charges, and terms and
       conditions
       Non-compliance with BPA CoP 22.4 - Use of photographic evidence
       technology
       Non-compliance with BPA CoP 7 - Written authorisation of the
       landowner
       No Registered Keeper liability
       The ANPR system is neither reliable nor accurate
       No planning permission from the Council for Pole-mounted ANPR
       cameras and no advertising consent for signage
       Pre-conviction penalties are unlawful in English law
       Lack of standing
       #Post#: 25029--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: Jag84
       Date: June 5, 2024, 12:12 pm
       ---------------------------------------------------------
       I can't seem to upload the photo as it says the folder is full
       but if you look at the image I uploaded on the 7th May in this
       thread it shows the sign surrounded by bags of compost
       #Post#: 25030--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: DWMB2
       Date: June 5, 2024, 12:14 pm
       ---------------------------------------------------------
       You'll need to use a third party site like Imgur to upload any
       more images. Upload space on here is very limited.
       #Post#: 25035--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: Jag84
       Date: June 5, 2024, 12:38 pm
       ---------------------------------------------------------
       Ok but the image is uploaded in this thread on the 7th May. One
       how the sign is surrounded by bags of compost and the other
       shows the wording on the signage. I think I had to stand on the
       bags to get close photo of the sign
       In regard to the other suggested conditions
       Non-compliance with BPA CoP 19.2 and Appendix B - Entrance signs
       -----  will need to check if there we entrance signs
       Non-compliance with BPA CoP 19.3 & 19.9 - Specific parking-terms
       signage
       ----- think there might be some mileage on 19.9 i.e. "there must
       be at least one sign containing the
       terms and conditions for parking that can be viewed without
       needing to leave the vehicle". Can't recall seeing one does it
       have to be in the same section of the car park ?
       Non-compliance with BPA CoP 20.3 - Charges, and terms and
       conditions
       ---- if you look at the sign it does specify the fine amount not
       sure I can use this one
       Non-compliance with BPA CoP 22.4 - Use of photographic evidence
       technology
       ---- ANPR wasn't used just normal photos. Not sure on what point
       I would argue a case on 22.4?  It says must comply by Data
       Protection, be registered with the Information Commissioner and
       follow DVLA requirements for data. I don't have any evidence to
       suggest that none of those are true
       Non-compliance with BPA CoP 7 - Written authorisation of the
       landowner
       No Registered Keeper liability
       Pre-conviction penalties are unlawful in English law
       Lack of standing
       ----- Not sure if there is anything from the above I could make
       a case I assume they must be authorised
       #Post#: 25969--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: Jag84
       Date: June 14, 2024, 6:05 am
       ---------------------------------------------------------
       Apologies for delay in response unfortunately got laid off and
       have been going through some personal challenges but now more
       determined not to have to pay this fine
       Below is what I plan to send to POPLA. Is that OK ? I assume
       POPLA will allow me to upload photos and they have access to the
       photos the parking company has taken ?
       Appeal for Parking Fine to POPLA
       Dear POPLA Adjudicator,
       I am writing to appeal a parking fine issued to me for allegedly
       parking outside of a designated bay. I believe the fine should
       be overturned for the following reasons:
       1. Inadequate Signage
       1.1. Poor Visibility and Accessibility of Signs
       The relevant signage was positioned too high and was surrounded
       by bags of compost from a nearby store, making it difficult to
       access or read. Notably, the parking company did not provide a
       photograph of this particular sign, which was the nearest and
       only one in this section of the car park. Instead, they provided
       photographs from a different section. This is a violation of the
       BPA Code of Practice, specifically:
       Section 19.3: "Signs must be conspicuous and legible, and
       written in intelligible language, so that they are easy to see,
       read, and understand."
       1.2. Non-Compliance with PoFA 2012 Section 9(2)(c)
       The blocked access to the signage fails to comply with the
       Protection of Freedoms Act 2012, Section 9(2)(c), which requires
       that the terms of the parking charge be adequately brought to
       the attention of the driver. This constitutes a breach of the
       BPA Code of Practice (CoP) 19.1. I have attached a photograph
       showing the sign with blocked access.
       1.3. Non-Compliance with BPA CoP 19.9 - Specific Parking-Terms
       Signage
       According to BPA CoP 19.9, there must be at least one sign
       containing the terms and conditions for parking that can be
       viewed without needing to leave the vehicle. I did not see any
       such sign meeting this requirement.
       2. Poor Condition and Inadequate Width of Parking Bays
       2.1. Worn and Faded Bay Lines
       The bay lines in the car park are worn and faded, breaching the
       condition stated in BPA CoP 19.11 regarding "Surface markings –
       delineated parking bays." The lack of clear demarcation
       significantly contributes to the difficulty a driver would have
       in parking precisely within the bay.
       2.2. Insufficient Bay Width
       The bays provided are not sufficiently wide for safe parking.
       According to the BPA Code of Practice, Section 28.3, parking
       areas should be clearly marked and adequately spaced:
       28.3: "You should lay out the parking area so that drivers can
       at all times have a fair opportunity to park their vehicles and
       meet the terms and conditions of parking."
       The inadequate width of the bays, as illustrated in the attached
       photographs, makes it challenging for any driver to park without
       encroaching on the lines. This condition made it necessary for
       me to park as far to the right as possible to maintain a safe
       distance from the neighboring vehicle, which was also parked on
       or near the line.
       3. Vehicle Position
       3.1. Accurate Positioning
       The vehicle was not parked outside of the bay; it was positioned
       on the line, not beyond it. The photographs demonstrate that the
       neighboring car was parked in a similar manner, necessitating
       that I park as far to the right as possible to maintain a safe
       distance between the vehicles.
       Based on the above points, I respectfully request that the
       parking fine be overturned due to the inadequate signage, poor
       condition of the bay lines, and the insufficient width of the
       bays. These factors made it unreasonably difficult for me to
       comply with the parking terms and conditions.
       Thank you for considering my appeal.
       #Post#: 25971--------------------------------------------------
       Re: UKPC Fine for car not being in bay
   DIR By: b789
       Date: June 14, 2024, 6:18 am
       ---------------------------------------------------------
       A PCN is not a “fine”. It is an invoice. The keeper/driver has
       not committed any offence. This is a civil matter in contract
       law. Please don’t call it a “fine”.
       You should be sending the POPLA appeal as a PDF file. You can
       embed images into a PDF file.
       List your main points at the beginning and then go through each
       point individually.
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