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       #Post#: 38221--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: September 25, 2024, 3:28 am
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       Hi All,
       Just bumping this to the top - any idea on whether I should
       respond?
       Thanks in advance
       #Post#: 38225--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DWMB2
       Date: September 25, 2024, 4:05 am
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       I'd ignore and wait for a decision on the appeal.
       Please don't bump threads. This is a busy forum and sometimes
       replies might not be immediate (we do this in our spare time).
       If everyone bumped their threads it would be impossible to keep
       up.
       #Post#: 44927--------------------------------------------------
       Re: ParkingEye - Failure to Pay for Parking - Southall
   DIR By: DavidJP
       Date: November 10, 2024, 11:52 am
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       Dear Folks,
       I've now had a formal rejection from ParkingEye. Seems pretty
       standard but have been provided a POPLA code.
       Would you be able to critique my POPLA appeal, please?
       Thank you!
       Dear POPLA Assessor,
       I am the registered keeper of the vehicle referenced in the
       Parking Charge Notice (PCN) issued by ParkingEye Ltd on 12
       August 2024 at VHK, Southall car park. I am appealing this
       charge on the following grounds:
       1. Failure to Comply with Schedule 4, Paragraph 9(2)(e)(i) of
       the Protection of Freedoms Act 2012 (PoFA)
       The Notice to Keeper (NtK) fails to comply with the mandatory
       wording requirements as outlined in PoFA 2012. Specifically:
       Lack of an Explicit "Invitation to Pay": Schedule 4, Paragraph
       9(2)(e)(i) of PoFA requires the NtK to explicitly invite the
       keeper to pay the unpaid parking charge. The NtK issued by
       ParkingEye does not contain such an invitation in clear terms.
       The wording is insufficient and ambiguous, failing to convey a
       direct obligation for the keeper to pay. As PoFA demands strict
       compliance, this failure invalidates the NtK and prevents the
       transfer of liability from the driver to me, the registered
       keeper.
       2. Insufficient Identification of "Relevant Land" as per
       Schedule 4, Paragraph 9(2)(a) of PoFA
       The NtK does not properly identify the “relevant land” on which
       the alleged contravention occurred. The vague reference to “VHK,
       Southall” fails to provide an adequate and specific description
       of the location. The requirement under PoFA is to specify the
       land clearly so that the registered keeper can identify where
       the vehicle was parked. Without a full address or postcode, this
       NtK is non-compliant with Schedule 4, Paragraph 9(2)(a) of PoFA,
       and therefore, ParkingEye cannot hold me, the registered keeper,
       liable.
       3. Breach of BPA Code of Practice – Inadequate Signage
       The British Parking Association (BPA) Code of Practice requires
       that all parking terms and conditions be clearly displayed on
       signage throughout the site. This includes the charge amount and
       the conditions for parking. The signage at [VHK, Southall car
       park] is inadequate for the following reasons:
       Insufficient Visibility: The signs are not clearly visible upon
       entering or throughout the car park. They are poorly positioned,
       and the font is too small to be easily read, particularly in the
       hours of reduced visibility (e.g., at 19:50, when the alleged
       contravention occurred).
       Lack of Clarity: The terms and conditions, including the
       consequences of non-compliance, are not prominently displayed in
       a clear and concise manner as required by the BPA Code of
       Practice.
       This lack of adequate signage makes it impossible for a driver
       to be fully aware of the contractual obligations they are
       entering into, which undermines the legitimacy of the parking
       charge.
       4. No Evidence of Landowner Authority
       ParkingEye has not provided evidence that they have the
       authority from the landowner to issue and enforce parking
       charges at this site. The BPA Code of Practice (Section 7)
       requires that ParkingEye have a written contract with the
       landowner, granting them the authority to operate on the land
       and pursue parking charges. I request ParkingEye provide an
       unredacted copy of their contract with the landowner,
       demonstrating their authority. If they cannot provide this, the
       charge is invalid.
       5. The Charge is Not a Genuine Pre-Estimate of Loss
       The amount demanded, Ł100, does not represent a genuine
       pre-estimate of the loss incurred by the landowner. The car park
       is free, and the charge is purely punitive. This contravenes the
       principles established in previous cases, where only genuine
       pre-estimates of loss can justify such charges. ParkingEye must
       justify the charge amount with a breakdown of actual losses
       caused by the alleged contravention.
       Conclusion
       The NtK issued by ParkingEye is non-compliant with PoFA 2012 on
       multiple counts, and the signage at the site is inadequate,
       breaching the BPA Code of Practice. Furthermore, the legitimacy
       of ParkingEye’s authority to issue charges is in question, and
       the amount charged is not a genuine pre-estimate of loss. For
       these reasons, I request that POPLA upholds my appeal and
       cancels this Parking Charge Notice.
       Thank you for your consideration.
       Yours faithfully,
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