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       #Post#: 23085--------------------------------------------------
       UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: Keeper
       Date: May 19, 2024, 1:54 pm
       ---------------------------------------------------------
       Hi all,
       After returning from overseas to find a stash of letters and
       feeling rather cheesed off so thought I'd turn to the gurus on
       here after I was so wonderfully helped by the lovely people from
       Pepipoo, to get my mother's vehicle out of a Heathrow parking
       charge.
       Explanation / Context
       NOTE: I've tried to keep it brief but I'm also unsure what may
       or may not be relevant, so thought it best to stick all the
       facts in!
       I am the keeper. The driver went to this location on 26th March,
       somewhere they had been to before and parked where they have
       always parked in the past (it's next to a climbing centre). N.B.
       The restrictions are clearly new as the climbing centre had a
       sign stating when it was safe to park and I can see the sign has
       been modified with some tape to reflect the changes.
       The driver parked there and then left later that evening.
       I went overseas on the morning of the 29th of March (provable)
       and did not return until the 2nd of May. Not sure if relevant
       but I was going to return on the 18th of April but had to stay
       longer as my father suddenly became unwell while overseas and
       needed cardiac procedures to be carried out.
       I returned to the following notices somewhere in a mountain of
       mail (attached in a pdf)
       28th March: UKPC NTK Parked in a permit area
       11th April: UKPC NTK Final Reminder
       24th April: Debt Collection Agency Letter
       10 May: Debt Collection Agency letter
       Car Park Signage
       I have attached photos of the car park signage. I'm not sure
       exactly which bay the driver parked in but you can see from the
       signs that they may not be within visibility or regulatory
       regulations (you will know better than me!). There's one more
       sign I can try and add a photo of for location, it was on a gate
       that was open so that it wasn't really visible (it's the actual
       notice in the last photo).
       At this point I, the keeper, have made no contact with either
       UKPC or the Debt Collection Agency - I thought this was best
       until I heard from you guys. What should I do next?
       Cheers!
       [attachment deleted by admin]
       #Post#: 23106--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: DWMB2
       Date: May 19, 2024, 4:17 pm
       ---------------------------------------------------------
       First things first, I'm very sorry to hear about your father, I
       hope all is well.
       Before we move onto the facts of the parking incident itself,
       some process. The fact you were abroad for the times stated is
       unlikely to have much bearing on the case, other than the fact
       you are now beyond UKPC's arbitrary appeal window - this means
       they won't consider any appeals, nor provide a POPLA code, but
       this is not the end of the world. Ignore the debt collectors,
       you should not engage with them at all. File but ignore their
       letters. You need to keep an eye out for anything that is marked
       as a 'Letter Before Claim' or similar, which will come from
       UKPC's solicitors/legal firm. UKPC do tend to issue a lot of
       claims - another thing they (or more accurately their chosen law
       firm DCB Legal) tend to do, if the matter is defended, is
       discontinue the claims before they ever reach a courtroom. This
       thread from the MSE Forum makes for interesting reading: DCB
       LEGAL RECORD OF PRIVATE PARKING COURT CLAIM DISCONTINUATIONS
  HTML https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations.<br
       />Usual caveat that past performance is not always a reliable
       indicator of future conduct, but you'll see there's been a
       definite pattern.
       Now, onto the incident. You mention that it is your mother's
       vehicle, but that you are the registered keeper?
       --- Quote from: Keeper link ---
       >
       > Car Park Signage
       >
       > I have attached photos of the car park signage. I'm not sure
       exactly which bay the driver parked in but you can see from the
       signs that they may not be within visibility or regulatory
       regulations (you will know better than me!). There's one more
       sign I can try and add a photo of for location, it was on a gate
       that was open so that it wasn't really visible (it's the actual
       notice in the last photo).
       >
       --- End Quote ---
       That signage looks shoddy for a number of reasons - is there a
       sign at the entrance? The £100 charge isn't particularly
       prominent for a start, such a charge should be clearly brought
       to the motorists attention. The placement also looks poor, the
       signage should be 'there to be seen' - this is compounded if
       there is no sign at the entrance. There's also a potential
       argument that the signage is forbidding, as it doesn't make an
       offer to those without a permit to park on certain terms.
       #Post#: 23126--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: Keeper
       Date: May 19, 2024, 6:51 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > First things first, I'm very sorry to hear about your father,
       I hope all is well.
       >
       > Before we move onto the facts of the parking incident itself,
       some process. The fact you were abroad for the times stated is
       unlikely to have much bearing on the case, other than the fact
       you are now beyond UKPC's arbitrary appeal window - this means
       they won't consider any appeals, nor provide a POPLA code, but
       this is not the end of the world. Ignore the debt collectors,
       you should not engage with them at all. File but ignore their
       letters. You need to keep an eye out for anything that is marked
       as a 'Letter Before Claim' or similar, which will come from
       UKPC's solicitors/legal firm. UKPC do tend to issue a lot of
       claims - another thing they (or more accurately their chosen law
       firm DCB Legal) tend to do, if the matter is defended, is
       discontinue the claims before they ever reach a courtroom. This
       thread from the MSE Forum makes for interesting reading: DCB
       LEGAL RECORD OF PRIVATE PARKING COURT CLAIM DISCONTINUATIONS
  HTML https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations.<br
       />Usual caveat that past performance is not always a reliable
       indicator of future conduct, but you'll see there's been a
       definite pattern.
       >
       > Now, onto the incident. You mention that it is your mother's
       vehicle, but that you are the registered keeper?
       >
       > [quote author=Keeper link=topic=1947.msg23085#msg23085
       date=1716144866]
       > Car Park Signage
       >
       > I have attached photos of the car park signage. I'm not sure
       exactly which bay the driver parked in but you can see from the
       signs that they may not be within visibility or regulatory
       regulations (you will know better than me!). There's one more
       sign I can try and add a photo of for location, it was on a gate
       that was open so that it wasn't really visible (it's the actual
       notice in the last photo).
       >
       --- End Quote ---
       That signage looks shoddy for a number of reasons - is there a
       sign at the entrance? The £100 charge isn't particularly
       prominent for a start, such a charge should be clearly brought
       to the motorists attention. The placement also looks poor, the
       signage should be 'there to be seen' - this is compounded if
       there is no sign at the entrance. There's also a potential
       argument that the signage is forbidding, as it doesn't make an
       offer to those without a permit to park on certain terms.
       [/quote]
       Many thanks, my father is now well and returned to the UK
       yesterday - he got very lucky with early treatment. Appreciate
       it!
       In response:
       1. Apologies, my poor punctuation. Previous incident, resolved
       years ago by helpful members of another forum, was my mother's
       car. I didn't know about this place at the time! This case
       relates to my vehicle.
       2. Here
  HTML https://maps.app.goo.gl/z8QLN3VTDdWSunPZ8
       is a street view of
       the space. You'll see the sign by White Spider on the left,
       since the driver was last there and since the street view car
       went around, the days and times have been taped over, so indeed
       one without a permit is simply forbidden to park in those spaces
       immediately past the grey gate at any time, under any terms. The
       sign you can read in my photos is the one (presumably updated
       since street view) on the left hand gate.
       3. Really interesting info, thanks. Typically would a claim be
       for the amount on the charge plus some sort of admin fee? Seeing
       as if I were to want to pay now, it would be £170, bearing in
       mind that it's not possible to claim costs in the small claims
       court, it would seem I have nothing to lose, as long as I don't
       miss the initial pre-claim correspondence.
       4. Understood on not corresponding with debt collection agency.
       Is there any sense in writing to UKPC explaining that I was out
       of the country and that I wish to contest the charge? Whilst I
       understand the answer is probably no, my question is more if
       this may help me in the future if I have taken this step.
       Many thanks again
       #Post#: 23129--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: b789
       Date: May 19, 2024, 7:39 pm
       ---------------------------------------------------------
       One point that may come in useful if/when this progresses to a
       claim, which is highly likely but will not result in anything
       other than a discontinuation before a hearing if you follow all
       the advice. You say the driver visited the location on 26th
       March and it was a location they had visited previously but had
       no or different restrictions back then. Was the previous visit
       more or less than 4 months previously?
       If the last previous visit was less than 4 months previously,
       were there any prominent signs indicating that the terms of
       parking had been changed? If so, they have breached their own
       ATA, the BPA, Code of Practice rule 19.10 which states:
       --- Quote ---
       > Material change - notices
       >
       > Where there is any material change to any pre-existing terms
       and conditions that would not be immediately apparent to a
       motorist entering controlled land that is or has been open for
       public parking, you must place additional (temporary) notices at
       the site entrance for a period of not less than 4 months from
       the date of the change making it clear that new terms and
       conditions/charges apply, such that regular visitors who might
       be familiar with the old terms do not inadvertently incur
       parking charges.
       --- End Quote ---
       Whilst some may advocate trying to appeal to the better nature
       of the customer service ethos of UKPC and try and mitigate the
       circumstance so that they reset the clock and let you appeal, it
       is just going to be a waste of time and effort. There are some
       rules in the CoP that could be argued that they should re-issue
       the PCN and start the clock but, to be honest, they won’t.
       Whilst we haven’t yet seen both sides of the NtK (suitably
       redacted but with all dates showing) there is likely to be
       another flaw or two in it that will force them to make the claim
       under PoFA against the keeper. However, there is now an updated
       item to add to any robust defence to request that the claim is
       dismissed at the allocation stage as they will be in breach of
       several CPRs and PoFA. We will cross that bridge if and when we
       need to. For now, the keeper must not reveal the identity of the
       driver.
       #Post#: 23479--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: Keeper
       Date: May 22, 2024, 2:41 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > One point that may come in useful if/when this progresses to a
       claim, which is highly likely but will not result in anything
       other than a discontinuation before a hearing if you follow all
       the advice. You say the driver visited the location on 26th
       March and it was a location they had visited previously but had
       no or different restrictions back then. Was the previous visit
       more or less than 4 months previously?
       >
       > If the last previous visit was less than 4 months previously,
       were there any prominent signs indicating that the terms of
       parking had been changed? If so, they have breached their own
       ATA, the BPA, Code of Practice rule 19.10 which states:
       >
       > [quote]Material change - notices
       >
       > Where there is any material change to any pre-existing terms
       and conditions that would not be immediately apparent to a
       motorist entering controlled land that is or has been open for
       public parking, you must place additional (temporary) notices at
       the site entrance for a period of not less than 4 months from
       the date of the change making it clear that new terms and
       conditions/charges apply, such that regular visitors who might
       be familiar with the old terms do not inadvertently incur
       parking charges.
       --- End Quote ---
       Whilst some may advocate trying to appeal to the better nature
       of the customer service ethos of UKPC and try and mitigate the
       circumstance so that they reset the clock and let you appeal, it
       is just going to be a waste of time and effort. There are some
       rules in the CoP that could be argued that they should re-issue
       the PCN and start the clock but, to be honest, they won’t.
       Whilst we haven’t yet seen both sides of the NtK (suitably
       redacted but with all dates showing) there is likely to be
       another flaw or two in it that will force them to make the claim
       under PoFA against the keeper. However, there is now an updated
       item to add to any robust defence to request that the claim is
       dismissed at the allocation stage as they will be in breach of
       several CPRs and PoFA. We will cross that bridge if and when we
       need to. For now, the keeper must not reveal the identity of the
       driver.
       [/quote]
       1. Honestly not sure when signage changed - driver's last visit
       was probably in the last 4 months but the driver may have used
       their small private car park owned by the climbing centre - the
       area where the notice has been served for is outside the
       climbing centre but formerly okay to park there during certain
       hours. I will call the climbing centre to find out when rules
       changed...
       2. Full NTK with both sides attached to original post
       3. I hear you on an appeal - thanks for this info!
       #Post#: 23481--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: b789
       Date: May 22, 2024, 2:57 am
       ---------------------------------------------------------
       A Quick Look at the NtK shows PoFA failure to specify any
       “period of parking” in breach of 9(2)(a) and (c ). Also, the
       time stamp in the photo on the NtK appears to have been cropped
       which is a failure of BPA CoP 21.5a.
       #Post#: 23639--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: Keeper
       Date: May 23, 2024, 2:12 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > A Quick Look at the NtK shows PoFA failure to specify any
       “period of parking” in breach of 9(2)(a) and (c ). Also, the
       time stamp in the photo on the NtK appears to have been cropped
       which is a failure of BPA CoP 21.5a.
       >
       --- End Quote ---
       Many thanks for checking. Does this mean that your voice echoes
       the advice above to do nothing? Or should I send something to
       UKPC saying highlighting non-compliance with PoFA?
       #Post#: 23649--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: b789
       Date: May 23, 2024, 5:08 am
       ---------------------------------------------------------
       There are a couple of things you should be doing for now. Plan A
       is always the easiest to get these cancelled is to get the
       landowner to tell their agent to cancel it. You can continue
       with Plan A right up until the commencement of Plan D.
       What did the business you were visiting at the time have to say
       about their patrons being invoiced for £100 for the privilege?
       What was the date the original NtK was issued? Was it 27th March
       or earlier?
       Can you evidence that you were out of the country between the
       dates of the first NtK (plus 2 working days) and the 28th day
       after that? If so, you can complain (not appeal) to UKPC and
       request that they reissue the original NtK and restart the
       clock, thus allowing you to appeal. There is clause in the
       latest edition of the BPA CoP 23.8 that states they must reissue
       and restart the process if you can evidence that you (the
       addressee) could not have appealed within the original 28 day
       window. If you can and they don’t, a complaint to the BPA is in
       order.
       Apart from the above, all you can do for now is continue with
       Plan A and wait or the ridiculous but useless debt collector
       letters. If, or more likely when, you receive a real Letter of
       Claim, either directly from UKPC themselves or DCB Legal (not
       anything from DCB Ltd), then come back for advice on how to
       proceed.
       A claim is the start of Plan D and is easily dealt with and will
       end up with an eventual discontinuation.
       #Post#: 23815--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: H C Andersen
       Date: May 24, 2024, 4:07 pm
       ---------------------------------------------------------
       [member=26]b789[/member], why do you think the term 'period of
       parking' cannot be construed as a moment in time when the nature
       of the contravention does not require proof of the breach to be
       anything other than the vehicle was in situ. From the PPC's
       perspective 1 second is the same as 30 minutes, but from the
       keeper's perspective a consideration period would apply.
       And for the OP, what was the driver up to on the site? Your
       account does not state that the driver was actually a patron of
       any business on the site...'the area where the notice has been
       served for is outside the climbing centre but formerly okay to
       park there during certain hours.'
       Before we possibly go off in the wrong direction, let's clarify
       key issues pl.
       #Post#: 23831--------------------------------------------------
       Re: UKPC NTK - No Permit - Hook Rise, Chessington
   DIR By: b789
       Date: May 24, 2024, 6:28 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > [member=26]b789[/member], why do you think the term 'period of
       parking' cannot be construed as a moment in time when the nature
       of the contravention does not require proof of the breach to be
       anything other than the vehicle was in situ. From the PPC's
       perspective 1 second is the same as 30 minutes, but from the
       keeper's perspective a consideration period would apply.
       >
       --- End Quote ---
       The “period of parking” argument has been won at POPLA and at
       court several times. Unfortunately, I don’t have those POPLA
       appeals to hand at the moment.
       Whilst not yet enacted, the incoming statutory Code of Practice
       defines "2.24 parking period" as:
       "the length of time that a vehicle has been parked, i.e. left
       stationary otherwise than in the course of driving, after any
       relevant consideration period has expired (excluding instances
       where the driver has stopped to enable passengers to leave or
       enter the vehicle). This is not the period between a vehicle
       being recorded as entering and departing controlled land."
       The following has been used successfully in the past:
       “POFA paragraph 9(2)(a) says that a NTK must specify 'the period
       of parking to which the notice relates' The operator's purported
       NTK does not specify the period of parking to which the NTK
       relates as a period has a start and an end and the operator's
       purported NTK specifies only a single point in time.  This
       failure alone renders the charge unenforceable against the
       keeper.”
       The above, believe it or not, was for an IAS appeal and the
       following definition is what won it:
       “Paragraph 16.1 of the IPC's Code of Practice says 'Where a
       Parking Charge is issued Notices must comply with the applicable
       requirements as set out in Schedule 3'.  Schedule 3 echoes the
       POFA requirement  for a period of parking to be specified in the
       NTK and refers to an example NTK in Appendix 5 where the
       following form of words is prescribed:
       Period of Parking:
       From: (Date and Time of entry)
       To: (Date and Time of Exit)”
       When I have time, I will try and find more cases. However,
       “period of parking” is a valid argument if presented properly as
       it is one more point to use in any appeal or defence to show
       non-compliance with the requirements of PoFA. Hence, the OP
       should not throw away the no keeper liability option as an
       appeal or defence argument by revealing the identity of the
       driver.
       *****************************************************
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