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       #Post#: 47456--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: November 28, 2024, 8:57 am
       ---------------------------------------------------------
       They just sent a new Popla code!
       Presumably it's now worth appealing?
  HTML https://imgur.com/a/9R42aWd
       has the original rejection and the
       new one
       #Post#: 47465--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: b789
       Date: November 28, 2024, 9:55 am
       ---------------------------------------------------------
       Good news, sort of, so you can now make an appeal to POPLA. You
       have a deadline of Tuesday 31st December to lodge your POPLA
       appeal. There is no need to rush it and they are taking at least
       6-8 weeks to me an assessment at the moment so you postpone
       receiving a decision until around mid February 2025.
       I suggest you start to cobble together what you think is an
       appeal to POPLA and show us so that we can then advise on any
       changes or improvements. Poor signage is a very powerful point
       to make. Also, failure to fully comply with PoFA is another as
       there is no mention of the period of parking as required by
       paragraph 9(2)(a) of PoFA. Throw in lack of authority to issue
       PCNs and but them to strict proof of a valid contract.
       #Post#: 47470--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: November 28, 2024, 10:06 am
       ---------------------------------------------------------
       We originally discussed not complying with their request for the
       details of the driver. Should I continue that or do I now tell
       them who is responsible for the charge?
       The charge stated the time - when 9(2a) states "period" is there
       an obligation to write a start and end time?
       Thanks
       E
       #Post#: 47472--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: b789
       Date: November 28, 2024, 10:14 am
       ---------------------------------------------------------
       Continue to only appeal as the Registered Keeper (RK). They have
       no idea who the driver is and you are under no legal obligation
       to identify the driver to an unregulated private parking
       company.
       If we put it together, PoFA paragraph 9(2)(a) states:
       --- Quote ---
       > 9 (1) A notice which is to be relied on as a notice to keeper
       for the purposes of paragraph 6(1)(b) is given in accordance
       with this paragraph if the following requirements are met.
       >
       > (2) The notice must—
       >
       > (a) specify the vehicle, the relevant land on which it was
       parked and the period of parking to which the notice relates;
       --- End Quote ---
       So, is there anything in the NtK you received that "specifies"
       the "period of parking"? You tell me.
       Unless ALL the requirements of PoFA are fully complied with,
       then they cannot hold the Keeper liable. So, don't identify the
       driver.
       #Post#: 48051--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: December 3, 2024, 9:15 am
       ---------------------------------------------------------
       I am writing to appeal a Parking Charge Notice (PCN) issued to
       my vehicle on ------ by Private Parking Solutions (London) Ltd.
       I am the registered keeper of the vehicle in question and have
       not disclosed the identity of the driver.
       The basis of my appeal is the failure of the parking company to
       comply with the requirements set out in the Protection of
       Freedoms Act (PoFA) 2012 and on the grounds that the parking
       signage does not comply with the regulations required for
       enforceable private parking contracts. Specifically, I contest
       that the Notice to Keeper (NTK) issued by Private Parking
       Solutions (London) Ltd does not specify the "period of parking"
       as required under Paragraph 9(2)(a) of Schedule 4 of the PoFA.
       While the NTK mentions the time of the alleged parking
       contravention, it fails to state the actual "period of parking"
       during which the vehicle was purportedly parked. The PoFA
       clearly differentiates between the time of issue and the period
       of parking, and the NTK must include the latter to meet the
       statutory requirements. Similarly, the deficiencies in the
       signage mean that no contract was formed between the driver and
       Private Parking Solutions (London) Ltd.
       **Key points of my appeal are as follows:**
       1. **Lack of Specified Period of Parking:**
       According to Paragraph 9(2)(a) of Schedule 4 of the PoFA, for
       the NTK to be valid, it must specify "the period of parking to
       which the notice relates." The NTK issued by [parking company's
       name] only mentions a single point in time, rather than a
       specific period during which the vehicle was parked. This
       omission is a clear failure to comply with the PoFA
       requirements, rendering the NTK invalid.
       2. **Non-Compliance with PoFA:**
       The failure to specify the "period of parking" invalidates
       the NTK under the PoFA 2012. As such, the parking company does
       not have the legal right to claim unpaid parking charges from
       the registered keeper.
       3. **Requirement for Strict Adherence:**
       As the registered keeper, I am entitled to expect that the
       parking company adheres strictly to all statutory requirements
       when issuing a NTK. Non-compliance with these requirements
       invalidates any claim against me.
       4. Lack of Adequate Illumination
       The sign is mounted on a pole with no provision for adequate
       lighting. The photograph clearly shows that the sign is
       difficult to read in low-light conditions, rendering it
       impossible for motorists to see and understand the terms at
       night. This does not comply with the British Parking Association
       (BPA) Code of Practice, Section 19.3, which requires that
       parking terms must be clearly visible and legible under all
       conditions, including at night or in poor weather.
       5. Insufficient Notice of Key Terms
       The sign fails to meet the standards of the Consumer Rights Act
       2015 and BPA Code of Practice. The terms and conditions,
       including the potential £100 Parking Charge Notice, are written
       in small, dense text. Key information such as the penalty amount
       and conditions for enforcement is not prominent or clearly
       displayed.
       The ParkingEye v Beavis [2015] UKSC 67 case stressed the
       importance of clear and prominent signage for creating a binding
       parking contract. Here, the terms are obscured due to poor
       design and positioning, undermining their enforceability.
       6. Ambiguous Time Restrictions
       The sign lists a complex schedule of restricted parking hours
       for each day. This schedule is excessively convoluted, making it
       unreasonable to expect drivers to understand and comply within
       the short time they have to park and assess the situation. As
       per the BPA Code of Practice (Section 19.4), terms must be clear
       and concise. This sign clearly fails this standard.
       7. Non-Compliance with Regulatory Design Standards
       The sign does not adhere to the Traffic Signs Regulations and
       General Directions 2016 (TSRGD) standards, which apply to
       private parking signage. While TSRGD is not legally binding on
       private operators, compliance is often cited as a benchmark for
       clarity and enforceability.
       8. Lack of Clear Authority
       The sign lacks clear evidence of Private Parking Solutions'
       authority to manage parking on this land. The BPA Code of
       Practice, Section 7, requires parking operators to display
       evidence of their contractual right to issue parking charges on
       the site. This is absent from the sign.
       Given these points, I respectfully request that POPLA upholds my
       appeal and instructs Private Parking Solutions (London) Ltd to
       cancel the PCN.
       Yours faithfully,
       #Post#: 48072--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: H C Andersen
       Date: December 3, 2024, 11:16 am
       ---------------------------------------------------------
       The time and date of the breach? (you've obscured this).
       The back of the PCN pl.
       There's no BPA Code of Practice as such, there's the Private
       Parking Sector Single Code of Practice if the event took place
       on or after 1 Oct.
       So I suggest you re-read your draft and remove references to an
       out of date CoP, I also suggest you remove reference to TSRGD
       which has nothing whatsoever to do with contracts for parking on
       private land(it applies to traffic authorities), I also suggest
       you aggregate and don't repeat points under PoFA and CoP
       breaches, and remove the double negative here:
       I contest that the Notice to Keeper (NTK) issued by Private
       Parking Solutions (London) Ltd does not specify the "period of
       parking" as required under Paragraph 9(2)(a) of Schedule 4 of
       the PoFA.
       #Post#: 48073--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: December 3, 2024, 11:22 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > The time and date of the breach? (you've obscured this).
       > The back of the PCN pl.
       >
       > [/i]
       >
       --- End Quote ---
       Noted - will redraft
       I obscured the date and time deliberately (always have done
       since pepipoo). Will obviously add it back in or was there
       something specific about it? Happened October 8th so will read
       the private parking sector single code of conduct. Thanks
       #Post#: 48794--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: December 7, 2024, 12:33 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > The time and date of the breach? (you've obscured this).
       > The back of the PCN pl.
       >
       > There's no BPA Code of Practice as such, there's the Private
       Parking Sector Single Code of Practice if the event took place
       on or after 1 Oct.
       >
       > So I suggest you re-read your draft and remove references to
       an out of date CoP, I also suggest you remove reference to TSRGD
       which has nothing whatsoever to do with contracts for parking on
       private land(it applies to traffic authorities), I also suggest
       you aggregate and don't repeat points under PoFA and CoP
       breaches, and remove the double negative here:
       >
       > I contest that the Notice to Keeper (NTK) issued by Private
       Parking Solutions (London) Ltd does not specify the "period of
       parking" as required under Paragraph 9(2)(a) of Schedule 4 of
       the PoFA.
       >
       >
       --- End Quote ---
       I am writing to appeal a Parking Charge Notice (PCN) issued to
       my vehicle on ********* by Private Parking Solutions (London)
       Ltd. I am the registered keeper of the vehicle in question and
       have not disclosed the identity of the driver.
       The basis of my appeal is the failure of the parking company to
       comply with the requirements set out in the Protection of
       Freedoms Act (PoFA) 2012 and the inadequacy of the parking
       signage. Specifically, I contest that the Notice to Keeper (NTK)
       issued by Private Parking Solutions (London) Ltd fails to
       specify the "period of parking" as required under Paragraph
       9(2)(a) of Schedule 4 of the PoFA.
       Key points of my appeal are as follows:
       1. Lack of Specified Period of Parking:
       According to Paragraph 9(2)(a) of Schedule 4 of the PoFA, for
       the NTK to be valid, it must specify "the period of parking to
       which the notice relates." The NTK issued by Private Parking
       Solutions (London) Ltd only mentions a single point in time,
       rather than a specific period during which the vehicle was
       parked. This omission is a clear failure to comply with the PoFA
       requirements, rendering the NTK invalid. As such, the parking
       company does not have the legal right to claim unpaid parking
       charges from the registered keeper.
       2. Inadequate Signage:
       The parking signage does not comply with the regulations
       required for enforceable private parking contracts. The signage
       fails to clearly display the terms and conditions, including the
       potential £100 Parking Charge Notice, in a manner that meets the
       standards of the Consumer Rights Act 2015 and the Private
       Parking Sector Single Code of Practice.
       Lack of Adequate Illumination:
       The sign is mounted on a pole with no provision for
       adequate lighting. It is difficult to read in low-light
       conditions, rendering it impossible for motorists to see and
       understand the terms at night. This does not comply with the
       requirement that parking terms must be clearly visible and
       legible under all conditions, including at night or in poor
       weather.
       - **Insufficient Notice of Key Terms:**
       The terms and conditions are written in small, dense text.
       Key information such as the penalty amount and conditions for
       enforcement is not prominent or clearly displayed.
       Ambiguous Time Restrictions:
       The sign lists a complex schedule of restricted parking
       hours for each day. This schedule is excessively convoluted,
       making it unreasonable to expect drivers to understand and
       comply within the short time they have to park and assess the
       situation.
       3. Lack of Clear Authority:
       The sign lacks clear evidence of Private Parking Solutions'
       authority to manage parking on this land. The Private Parking
       Sector Single Code of Practice requires parking operators to
       display evidence of their contractual right to issue parking
       charges on the site. This is absent from the sign.
       Given these points, I respectfully request that POPLA upholds my
       appeal and instructs Private Parking Solutions (London) Ltd to
       cancel the PCN.
       Yours faithfully
       #Post#: 48862--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: H C Andersen
       Date: December 8, 2024, 7:05 am
       ---------------------------------------------------------
       Dear Mr Assessor,
       PCN *********
       The issue in dispute here is whether the creditor has the right
       to enforce against the driver the requirement to pay the parking
       charge and, if so, whether they could claim this from the keeper
       of the vehicle.
       I have set out my appeal accordingly.
       Does the creditor have the right to enforce against the driver
       the requirement to pay the parking charge
       Before going into the detail of the events on the site and my
       appeal, the assessor is obliged to satisfy themselves that the
       creditor has the necessary authority to enter into contracts and
       impose parking charges on behalf of the landowner. This would
       necessitate the creditor providing evidence to this effect and I
       reserve the right to present argument based upon this once a
       copy has been provided to me.
       Subject to the creditor having this authority, I dispute that
       this could give rise to a relevant obligation on the driver's
       part in this case because the signs in situ fail to comply with
       the Code of Practice as follows:
       ...the signage issues.
       Does the creditor have the right to recover unpaid parking
       charges from the keeper of the vehicle
       This would require the creditor to comply with the provisions of
       paragraphs 5,6,9,11 and 12 (as the case may be) of Schedule 4 to
       the Protection of Freedoms Act 2012. However, the creditor has
       failed to comply with paragraph 9, and therefore paragraph 6,
       for the following reasons:
       ****** your NTK issues.
       Would be my approach to structure...apart from any other reason
       because this is how the assessor would approach the issue.
       #Post#: 49154--------------------------------------------------
       Re: Parked on private land on mistaken advice of resident
   DIR By: eyalmms
       Date: December 10, 2024, 3:40 am
       ---------------------------------------------------------
       Really appreciate the ongoing feedback
       Is this better?
       **Dear Mr. Assessor,**
       **PCN: [Your Reference Number]**
       The issue in dispute here is whether the creditor has the right
       to enforce against the driver the requirement to pay the parking
       charge and, if so, whether they can claim this from the keeper
       of the vehicle.
       I have set out my appeal accordingly:
       **Does the creditor have the right to enforce against the driver
       the requirement to pay the parking charge?**
       Before going into the detail of the events on the site and my
       appeal, the assessor is obliged to satisfy themselves that the
       creditor has the necessary authority to enter into contracts and
       impose parking charges on behalf of the landowner. This would
       necessitate the creditor providing evidence to this effect, and
       I reserve the right to present an argument based upon this once
       a copy has been provided to me.
       Subject to the creditor having this authority, I dispute that
       this could give rise to a relevant obligation on the driver's
       part in this case because the signs in situ fail to comply with
       the Code of Practice as follows:
       1. **Inadequate Signage:**
       The parking signage does not comply with the regulations
       required for enforceable private parking contracts. The signage
       fails to clearly display the terms and conditions, including the
       potential £100 Parking Charge Notice, in a manner that meets the
       standards of the Consumer Rights Act 2015 and the Private
       Parking Sector Single Code of Practice.
       - **Lack of Adequate Illumination:**
       The sign is mounted on a pole with no provision for
       adequate lighting. It is difficult to read in low-light
       conditions, rendering it impossible for motorists to see and
       understand the terms at night. This does not comply with the
       requirement that parking terms must be clearly visible and
       legible under all conditions, including at night or in poor
       weather.
       - **Insufficient Notice of Key Terms:**
       The terms and conditions are written in small, dense text.
       Key information such as the penalty amount and conditions for
       enforcement is not prominent or clearly displayed.
       - **Ambiguous Time Restrictions:**
       The sign lists a complex schedule of restricted parking
       hours for each day. This schedule is excessively convoluted,
       making it unreasonable to expect drivers to understand and
       comply within the short time they have to park and assess the
       situation.
       **Does the creditor have the right to recover unpaid parking
       charges from the keeper of the vehicle?**
       This would require the creditor to comply with the provisions of
       paragraphs 5, 6, 9, 11, and 12 (as the case may be) of Schedule
       4 to the Protection of Freedoms Act 2012. However, the creditor
       has failed to comply with paragraph 9, and therefore paragraph
       6, for the following reasons:
       2. **Lack of Specified Period of Parking:**
       According to Paragraph 9(2)(a) of Schedule 4 of the PoFA, for
       the NTK to be valid, it must specify "the period of parking to
       which the notice relates." The NTK issued by Private Parking
       Solutions (London) Ltd only mentions a single point in time,
       rather than a specific period during which the vehicle was
       parked. This omission is a clear failure to comply with the PoFA
       requirements, rendering the NTK invalid. As such, the parking
       company does not have the legal right to claim unpaid parking
       charges from the registered keeper.
       3. **Lack of Clear Authority:**
       The sign lacks clear evidence of Private Parking Solutions'
       authority to manage parking on this land. The Private Parking
       Sector Single Code of Practice requires parking operators to
       display evidence of their contractual right to issue parking
       charges on the site. This is absent from the sign.
       Given these points, I respectfully request that POPLA upholds my
       appeal and instructs Private Parking Solutions (London) Ltd to
       cancel the PCN.
       Yours faithfully,
       *****************************************************
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