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       #Post#: 73768--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: jfollows
       Date: May 29, 2025, 6:27 am
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       Oh yes, I agree, I’d missed that because I was so hung up on the
       byelaw issue.
       #Post#: 73804--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: b789
       Date: May 29, 2025, 8:20 am
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       +1
       However, it is interesting to see PE trying on the same excuse
       that MET use at Stansted and Gatwick airports. Just because the
       land is “private” does not mean it cannot be covered by byelaws.
       However, the PoFA failure alone is sufficient to quash this.
       #Post#: 73904--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: Chelsblue
       Date: May 30, 2025, 5:22 am
       ---------------------------------------------------------
       Thanks again for your assistance on this matter, before I post,
       is something like this suitable;
       I respectfully submit this response to the evidence provided by
       ParkingEye. Their submission fails to rebut the key legal
       grounds on which my appeal is based.
       1. ParkingEye Confirm They Are Not Relying on the Protection of
       Freedoms Act (PoFA) 2012
       ParkingEye clearly state in their evidence: “Please be advised,
       this Parking Charge was not issued under the Protection of
       Freedoms Act 2012.”
       This is a crucial admission. If a private parking operator
       chooses not to rely on Schedule 4 of PoFA, they cannot pursue
       the registered keeper for the charge if the driver has not been
       identified.
       In such cases, only the driver can be held liable, and I have
       not been identified as the driver. Therefore, under statute and
       common law, there is no lawful basis to transfer liability to me
       as the keeper.
       2. The Land Is Not “Relevant Land” Under PoFA
       Milton Country Park is subject to statutory control through
       byelaws made under Section 41 of the Countryside Act 1968,
       confirmed by the Secretary of State on 2 May 1994. As such, the
       land falls outside the definition of “relevant land” under PoFA
       Schedule 4, Paragraph 3(1), which explicitly excludes land
       subject to statutory control. Even if ParkingEye had attempted
       to rely on PoFA (which they have not), they would be barred from
       doing so due to the nature of the land.
       3. No Hirer Liability Applies
       I note that ParkingEye have not alleged that I am the hirer of
       the vehicle, nor have they provided any documentation or
       evidence of a hire agreement. Even if they were to attempt this,
       PoFA Schedule 4 Paragraph 14 sets out strict requirements for
       holding a hirer liable—none of which have been fulfilled, and
       none of which apply if PoFA is not being used.
       4. Conclusion
       To reiterate:
       * ParkingEye admit they are not using PoFA.
       * The land in question is not “relevant land” under PoFA.
       * The driver has not been identified.
       * I am the registered keeper and cannot be held liable under
       these circumstances.
       #Post#: 74017--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: Chelsblue
       Date: May 31, 2025, 5:33 am
       ---------------------------------------------------------
       Hello, good morning everyone. Before I submit my post, I just
       wanted to ensure everything was okay with it, or does it need
       amending? If somebody could advise, would really appreciate it.
       I've got this far and I don't want to mess it up. Best regards.
       #Post#: 74020--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: b789
       Date: May 31, 2025, 5:40 am
       ---------------------------------------------------------
       I would advise amending this bit in section 1 of your response:
       --- Quote ---
       > In such cases, only the driver can be held liable, and I have
       not been identified as the driver. Therefore, under statute and
       common law, there is no lawful basis to transfer liability to me
       as the keeper.
       --- End Quote ---
       to
       --- Quote ---
       > In such cases, only the driver can be held liable, and the
       driver has not been identified. Therefore, under statute and
       common law, there is no lawful basis to transfer liability to me
       as the keeper.
       --- End Quote ---
       Did you send or link to a copy of the byelaws when you made the
       appeal? If so, simply highlight in section 2 that a copy of
       those byelaws were provided with the initial appeal and the
       operator has not addressed this issue. Just because land is
       "private", does not mean that those byelaws do not apply.
       Otherwise, good to go.
       #Post#: 74145--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: Chelsblue
       Date: June 1, 2025, 8:17 am
       ---------------------------------------------------------
       b789 - again thanks for your help. I have submitted my comments
       to POPLA; 'We are writing to update you about your appeal.
       Your appeal is now ready to be assessed and is currently in a
       queue waiting to be allocated. We expect to make a decision on
       your appeal 6-8 weeks from the point that the appeal was first
       submitted. The next communication that you will receive from us
       will be the decision on your appeal.
       Kind regards
       POPLA Team
       Best Regards
       #Post#: 81886--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: Chelsblue
       Date: July 21, 2025, 5:21 am
       ---------------------------------------------------------
       Morning, I've just received a response from POPLA;
       'Your appeal was successful'
       'As your appeal was successful, your parking charge is not
       effective and you do not need to take any further action'
       Thank you all, really appreciate your assistance throughout.
       Best regards.
       #Post#: 81887--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: DWMB2
       Date: July 21, 2025, 5:22 am
       ---------------------------------------------------------
       Can you please share with us the assessor's reasoning?
       #Post#: 81891--------------------------------------------------
       Re: PCN - Milton Country Park, Cambridge
   DIR By: Chelsblue
       Date: July 21, 2025, 5:37 am
       ---------------------------------------------------------
       Please see reasoning;
       Decision
       Successful
       Assessor Name
       Jamie Macrae
       Assessor summary of operator case
       The parking operator has issued a Parking Charge Notice (PCN)
       due to not purchasing the appropriate parking time.
       Assessor summary of your case
       The appellant has raised the following points from their grounds
       of appeal. • The driver has not been identified, no presumption
       of driver liability. • The Protection of Freedoms Act (PoFA)
       2012 is not applicable as the land in question, Milton County
       Park, is subject to statutory control under byelaws made
       pursuant to Section 41 of the Countryside Act 1968, confirmed by
       the Secretary of State and in operation since 2 May 1994. 1. The
       land is not relevant land; the registered keeper cannot be held
       liable if the driver has not been identified. • The driver has
       not been identified. After reviewing the parking operator’s
       evidence, the appellant reiterates their grounds of appeal and
       expands on their grounds of appeal. The appellant has provided a
       byelaws document as evidence to support their appeal. The above
       evidence will be considered in making my decision.
       Assessor supporting rational for decision
       I am allowing this appeal, with my reasoning outlined below: I
       acknowledge the reason the operator has issued the PCN. The
       burden of proof lies with the operator to demonstrate that it
       has issued the PCN correctly. In this instance, I am satisfied
       that the keeper of the vehicle is entitled to appeal the
       validity of this PCN as the operator has issued a notice to the
       keeper’s address. I note the operator advises that it is not
       attempting to transfer the liability for the charge using the
       Protection of Freedoms Act 2012 and so in mind, the operator
       continues to hold the driver responsible. As such, I must first
       consider whether I am confident that I know who the driver is,
       based on the evidence received. After considering the evidence,
       I am unable to confirm that the appellant is in fact the driver.
       As such, I must allow the appeal on the basis that the operator
       has failed to demonstrate that the appellant is the driver and
       therefore liable for the charge. As I am allowing the appeal on
       this basis, I do not need to consider the other grounds of
       appeal raised by the appellant. Accordingly, I must allow this
       appeal.
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