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       #Post#: 35019--------------------------------------------------
       ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: August 30, 2024, 4:45 am
       ---------------------------------------------------------
       The driver of this vehicle failed to pay for parking. It was an
       absent minded mistake that has resulted in a PCN.
       Can we rely on POFA 2012 (Schedule 4, Paragraph 9(2)(e)(i)) for
       an appeal? I understand PE are notorious for rejecting appeals.
       Many thanks in advance.
  HTML https://i.imgur.com/fqjJZDq.jpeg
  HTML https://i.imgur.com/NUYsWf7.jpeg
       #Post#: 35025--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DWMB2
       Date: August 30, 2024, 5:05 am
       ---------------------------------------------------------
       I've removed those images, you need to redact your VRM and the
       parking charge reference number.
       #Post#: 35029--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: August 30, 2024, 5:38 am
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > I've removed those images, you need to redact your VRM and the
       parking charge reference number.
       >
       --- End Quote ---
       Thank you - now edited with redacted images.
       #Post#: 35052--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: b789
       Date: August 30, 2024, 7:43 am
       ---------------------------------------------------------
       In addition to PoFA 9(2)(e)(i) there is also a failure of
       paragraph 3 because they have not clearly defined the “relevant
       land”. This leads to a failure of PoFA 9(2)(a).
       However, do not hang your hat on those technical arguments. They
       would only have a chance of working as long as the appeal is
       made by the keeper and the drivers identity is not divulged. PE
       would reject any appeal in those points anyway but the point
       would be to get a POPLA code and appeal to them.
       I have no idea where “VHK, Southall” is. Relevant land should be
       identifiable with an actual address and post code. They have not
       provided either, hence the “relevant land” argument. Check out
       the BPA Code of Practice (CoP) for what it says about it.
       #Post#: 35054--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DWMB2
       Date: August 30, 2024, 7:59 am
       ---------------------------------------------------------
       Have a search on here for "relevant land" and you should be able
       to find other appeals where this has been raised to help you
       draft something. Show us what you come up with before sending
       anything.
       If you're struggling I can help draft something over the
       weekend.
       ParkingEye will probably reject (because they can). You've more
       chance at POPLA, although they can be a bit unpredictable when
       it comes to arguments about vague location.
       #Post#: 35100--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: The Rookie
       Date: August 30, 2024, 3:36 pm
       ---------------------------------------------------------
       As above, the keeper who wasn’t there needs to be able to
       identify where the parking event occurred in order to defend any
       allegation, PoFA recognises this and the description given here
       is meaningless to me, and Google maps.
       #Post#: 35112--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: August 30, 2024, 6:52 pm
       ---------------------------------------------------------
       Many thanks all, please find my appeal wording below. Grateful
       for feedback
       --- Quote ---
       > I am writing to formally challenge the Parking Charge Notice
       (PCN) referenced above, issued to vehicle registration number
       XXXXX. As the registered keeper of the vehicle, I dispute this
       PCN on the following grounds:
       >
       > 1. Non-Compliance with Schedule 4, Paragraph 9(2)(e)(i) of the
       Protection of Freedoms Act 2012
       >
       > The Notice to Keeper (NtK) fails to comply with the strict
       requirements of Schedule 4, Paragraph 9(2)(e)(i) of the
       Protection of Freedoms Act (PoFA) 2012. Specifically, the NtK
       does not include a clear and explicit "invitation to pay" the
       unpaid parking charge. The Act requires this invitation to be
       clearly stated, without reliance on implication or indirect
       language.This omission renders the NtK non-compliant with the
       legal requirements, and as a result, you are unable to transfer
       liability for the alleged parking charge to me, the registered
       keeper.
       >
       > 2. Failure to Identify the Relevant Land (Schedule 4,
       Paragraph 9(2)(a) of PoFA 2012)
       >
       > Additionally, the NtK fails to clearly define the "relevant
       land" on which the vehicle was allegedly parked. The location
       stated as "VHK, Southall" is insufficiently specific and does
       not provide an adequate address or postcode, making it
       impossible to identify the precise location of the alleged
       contravention. This failure to accurately specify the relevant
       land is a breach of Schedule 4, Paragraph 9(2)(a) of PoFA 2012.
       >
       > 3. Non-Compliance with BPA Code of Practice.
       >
       > Furthermore, the British Parking Association (BPA) Code of
       Practice requires that the NtK clearly specifies the location
       where the alleged contravention occurred.
       >
       > The vague description provided in this instance does not meet
       the BPA’s standards for clarity and transparency, further
       invalidating this PCN. Given the above points, the PCN issued is
       not compliant with the requirements set out in PoFA 2012.
       >
       > Consequently, I request that this parking charge be cancelled
       immediately.
       --- End Quote ---
       #Post#: 35509--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: September 3, 2024, 12:59 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > In addition to PoFA 9(2)(e)(i) there is also a failure of
       paragraph 3 because they have not clearly defined the “relevant
       land”. This leads to a failure of PoFA 9(2)(a).
       >
       > However, do not hang your hat on those technical arguments.
       They would only have a chance of working as long as the appeal
       is made by the keeper and the drivers identity is not divulged.
       PE would reject any appeal in those points anyway but the point
       would be to get a POPLA code and appeal to them.
       >
       > I have no idea where “VHK, Southall” is. Relevant land should
       be identifiable with an actual address and post code. They have
       not provided either, hence the “relevant land” argument. Check
       out the BPA Code of Practice (CoP) for what it says about it.
       >
       --- End Quote ---
       --- Quote from: b789 link ---
       >
       > In addition to PoFA 9(2)(e)(i) there is also a failure of
       paragraph 3 because they have not clearly defined the “relevant
       land”. This leads to a failure of PoFA 9(2)(a).
       >
       > However, do not hang your hat on those technical arguments.
       They would only have a chance of working as long as the appeal
       is made by the keeper and the drivers identity is not divulged.
       PE would reject any appeal in those points anyway but the point
       would be to get a POPLA code and appeal to them.
       >
       > I have no idea where “VHK, Southall” is. Relevant land should
       be identifiable with an actual address and post code. They have
       not provided either, hence the “relevant land” argument. Check
       out the BPA Code of Practice (CoP) for what it says about it.
       >
       --- End Quote ---
       Many thanks both - what do you think of my draft in my previous
       post? Thanking you in advance.
       #Post#: 35529--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: b789
       Date: September 3, 2024, 3:10 pm
       ---------------------------------------------------------
       In this bit:
       --- Quote ---
       > 1. Non-Compliance with Schedule 4, Paragraph 9(2)(e)(i) of the
       Protection of Freedoms Act 2012
       >
       > The Notice to Keeper (NtK) fails to comply with the strict
       requirements of Schedule 4, Paragraph 9(2)(e)(i) of the
       Protection of Freedoms Act (PoFA) 2012. Specifically, the NtK
       does not include a clear and explicit "invitation to pay" the
       unpaid parking charge. The Act requires this invitation to be
       clearly stated, without reliance on implication or indirect
       language.This omission renders the NtK non-compliant with the
       legal requirements, and as a result, you are unable to transfer
       liability for the alleged parking charge to me, the registered
       keeper.
       >
       --- End Quote ---
       You haven't pointed out that there is no "invitation" for the
       "keeper" to pay the charge.
       PE are going to reject anything you send so just get on with it
       and send something so you can get your POPLA code.
       #Post#: 37902--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: September 22, 2024, 6:49 pm
       ---------------------------------------------------------
       Hi All,
       I received the following from Parking Eye - but its just a
       request to provide more info. I am assuming its best not to
       reply and let the appeal play out?
       See imgur link here :
  HTML https://imgur.com/UxiVGhh
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