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       #Post#: 74982--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: DWMB2
       Date: June 5, 2025, 11:57 am
       ---------------------------------------------------------
       Can you please show us the exact wording of the question to
       which you are referring?
       #Post#: 74983--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 5, 2025, 12:00 pm
       ---------------------------------------------------------
       Please see screenshot below:
       [attachimg=2]
       [attachment deleted by admin]
       #Post#: 74993--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 5, 2025, 12:40 pm
       ---------------------------------------------------------
       Next page is as follows if I select I am being held liable:
       [attachimg=1]
       [attachment deleted by admin]
       #Post#: 75234--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 7, 2025, 8:30 am
       ---------------------------------------------------------
       For completeness, I've selected I am being held liable, as VCS
       are attempting to go after me as the registered keeper.
       #Post#: 76012--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 11, 2025, 8:33 am
       ---------------------------------------------------------
       After appealing on IAS website, VCS have responded as below, it
       would be appreciated if you could advise what response I should
       give to this? I don't really have much hope of IAS being
       impartial (as read previously) but I guess 'nothing
       ventured....'.
       --- Quote ---
       >
       >
       > The operator made their Prima Facie Case on 11/06/2025
       13:41:45.
       >
       > The operator reported that...
       > The appellant was the keeper.
       > The operator is seeking keeper liability in accordance with
       PoFA..
       > The Notice to Keeper (Non-ANPR) was sent on 24/04/2025.
       > The ticket was issued on 24/04/2025.
       > The charge is based in Contract.
       >
       > The operator made the following comments...
       > 1. The Sxxxxx Cxxxx Residential Car Park is private land and
       motorists are allowed to park their vehicle provided that they
       abide by any displayed conditions of parking.
       >
       > 2. The signage on site states, ‘Parking is strictly reserved
       for valid parking permit holders Only' and ‘A valid parking
       permit must be displayed inside the front windscreen of the
       vehicle with all details clearly visible at all times.' The
       signage makes it clear that anyone observed to be in
       contravention of these Terms and Conditions will become liable
       for a PCN.
       >
       > 3. Site photos supplied show that the signage can be seen
       throughout the car park. The adjudicator will note that the VCS
       signage onsite, including its wording and positioning has been
       audited by the IPC, has passed audit, complies with the IPC Code
       of Practice and is deemed fit for purpose.
       >
       > 4. Enforcement for parking contraventions at this car site is
       undertaken by POs who use a Hand Held Terminal (HHT) to record
       details of any vehicle and its registration number, which may be
       parked in contravention of the advertised Terms & Conditions.
       Those images and other relevant information are uploaded in real
       time to a secure portal, where the information is reviewed. No
       formal Parking Charge Notice is affixed to the vehicle; instead,
       a Notice to Keeper is subsequently issued by post, this practice
       falls in line with the process and procedures as per site
       management using ANPR technology.
       >
       > 5. The Patrol Officer (PO) observed the appellant's vehicle in
       situ for 11 minutes and 39 seconds and when digitally recording
       the contravention the PO noted ‘Vehicle not displaying a valid
       parking permit.'
       >
       > 6. The contravention photographs supplied, which are time and
       date stamped corroborate the PO's observations, clearly show
       that no valid permit was displayed in the windscreen of the
       vehicle and highlight the proximity of the vehicle to
       contractual VCS signage.
       >
       > 7. Both the period of observation by the PO and our
       photographic evidence comply with the Single Code of Practice.
       >
       > 8. As registered keeper, we are holding the appellant liable
       for the Charge Notice under Schedule 4 of the Protection of
       Freedoms Act 2012, details of which where explained in the
       formal Notice sent on 24/04/2025. We note that the appellant has
       also declined to name the driver of their vehicle at the time of
       the incident in question. It is important that we make the
       adjudicator aware that we will rely on the keeper liability
       provisions within Schedule 4 of the Protection of Freedoms Act
       2012 (PoFA) and as such, do not require those details.
       >
       > 9. The contract between the appellant and VCS was formed when
       the motorist entered the car park. When entering this private
       land, a motorist freely enters into an agreement to abide by the
       conditions advertised in return for permission to enter. It is
       the motorist's responsibility to ensure that they abide by any
       clearly displayed terms and conditions. It is clear that the
       terms and conditions stated that vehicles must clearly display
       valid permit otherwise the motorist would face liability for a
       Charge Notice.
       >
       > 10. A copy of our authority to manage parking on this site,
       including where the appellant parked their vehicle was supplied
       as part of the IPC audit process and is available solely to the
       Adjudicator for their perusal.
       >
       > 11. A helpline telephone number (open 24 hours per day) is
       clearly displayed on all EPS signage for any motorist
       experiencing difficulty or who has any questions or concerns.
       This was not utilised by the appellant. If the terms and
       conditions were in any way unclear to the appellant, or they
       were unsure if they applied to them, they had the option of
       contacting us for advice.
       >
       > 12. The appellant has presented no evidence of either
       possessing a valid permit or of residency of an adjacent Signal
       Court property. However such evidence would not nullify the
       facts of their contravention or their liability for the charge.
       The terms and conditions for parking on this private land are
       clearly advertised by the signage on site.
       >
       > 13. The appellant became liable for a Charge Notice as per the
       Terms and Conditions displayed by parking without displaying a
       valid permit.
       >
       >
       --- End Quote ---
       #Post#: 76021--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: jfollows
       Date: June 11, 2025, 9:39 am
       ---------------------------------------------------------
       Go through this and counter every point that’s wrong, eg
       1. Tenants have the right to use allocated parking spaces
       according to their lease agreements, which do not require the
       display of a permit or compliance with signs erected by a third
       party, VCS
       2. Signage is irrelevant, VCS is not a party in the tenancy
       agreement and can not impose terms and conditions on parking
       3. Signage is irrelevant
       4. Enforcement is solely according to the leases and their terms
       and conditions
       5. The Patrol Officer is irrelevant
       ….
       8. Notwithstanding the irrelevance of VCS, the notice issued
       does not comply with PoFA because ….
       9. VCS can not contract with a motorist when the motorist
       already has the right to use the parking spaces according
       because of the lease
       10. VCS needs to demonstrate how its “authority” to manage
       parking has been incorporated into the residents’ leases
       ….
       12.
       etc.
       That is not a good reply, but you can do better and ensure that
       no points remain unchallenged. If you are serious about the IAS,
       that is. Otherwise, don’t bother, let them take you to court
       where you’ll win.
       #Post#: 76075--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 11, 2025, 2:04 pm
       ---------------------------------------------------------
       I'm leaning towards just leaving it as I'm not sure it's worth
       the hassle if they will find in favour of VCS, or should I take
       some time out and cover each point?
       #Post#: 76109--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: DWMB2
       Date: June 11, 2025, 4:37 pm
       ---------------------------------------------------------
       Your call as it's your time and effort.
       #Post#: 76126--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: jfollows
       Date: June 12, 2025, 12:33 am
       ---------------------------------------------------------
       --- Quote from: 3Sh3roo link ---
       >
       > I'm leaning towards just leaving it as I'm not sure it's worth
       the hassle if they will find in favour of VCS, or should I take
       some time out and cover each point?
       >
       --- End Quote ---
       If you leave it, you’re going to have to write a defence to the
       inevitable claim, but if you spend the time now it will be the
       majority of your defence in due course when/if the IAS doesn’t
       uphold your appeal, so I think it’s a case of do it now or do it
       later anyway.
       And if the IAS does uphold your appeal, you’ve saved yourself a
       lot of paperwork hassle.
       But it’s your effort and your choice of course!
       #Post#: 76222--------------------------------------------------
       Re: PCN Chester Private Car Park
   DIR By: 3Sh3roo
       Date: June 12, 2025, 10:08 am
       ---------------------------------------------------------
       Thanks for all the guidance, I've put together the following
       responses, mainly be referring to previous advice from you good
       folk. I am not very experienced at this and do need help on
       point 7, also can you please advise if my responses are on
       point?
       1. The Sxxxxx Cxxxx Residential Car Park is private land and
       motorists are allowed to park their vehicle provided that they
       abide by any displayed conditions of parking.
       APP: Once again, The Appellant is the lawful residential tenant
       of the property associated with the parking space in question.
       An Assured Shorthold Tenancy Agreement (AST) grants the
       Appellant an express and exclusive right to use an allocated
       parking space. The AST does not contain any clause requiring the
       display of a permit, nor does it incorporate or acknowledge the
       signage, terms, or scheme operated by the parking company. The
       Appellant's rights under the tenancy agreement override any
       alleged third-party terms displayed on signs. The operator is
       put to strict proof that their signage terms can override an
       existing contractual right of quiet enjoyment and exclusive use,
       and that any such signage forms part of the tenant's agreed
       obligations.
       2. The signage on site states, ‘Parking is strictly reserved for
       valid parking permit holders Only' and ‘A valid parking permit
       must be displayed inside the front windscreen of the vehicle
       with all details clearly visible at all times.' The signage
       makes it clear that anyone observed to be in contravention of
       these Terms and Conditions will become liable for a PCN.
       APP: Signage is irrelevant, VCS is not a party in the AST and
       therefore cannot impose terms and conditions on parking.
       3. Site photos supplied show that the signage can be seen
       throughout the car park. The adjudicator will note that the VCS
       signage onsite, including its wording and positioning has been
       audited by the IPC, has passed audit, complies with the IPC Code
       of Practice and is deemed fit for purpose.
       APP: Once again, signage is irrelevant as VCS are not a party in
       the AST
       4. Enforcement for parking contraventions at this car site is
       undertaken by POs who use a Hand Held Terminal (HHT) to record
       details of any vehicle and its registration number, which may be
       parked in contravention of the advertised Terms & Conditions.
       Those images and other relevant information are uploaded in real
       time to a secure portal, where the information is reviewed. No
       formal Parking Charge Notice is affixed to the vehicle; instead,
       a Notice to Keeper is subsequently issued by post, this practice
       falls in line with the process and procedures as per site
       management using ANPR technology.
       APP: Enforcement for parking is solely in line with the AST.
       5. The Patrol Officer (PO) observed the appellant's vehicle in
       situ for 11 minutes and 39 seconds and when digitally recording
       the contravention the PO noted ‘Vehicle not displaying a valid
       parking permit.'
       APP: The operator has not shown that any contravention occurred.
       The vehicle was parked in the Appellant's allocated space. A
       valid permit was present on the dashboard at the time, although
       the operator's photograph is inconclusive. In any event, the AST
       grants an unqualified right to park, and the display of a permit
       has always been a courtesy, not a condition. There is no breach
       of any enforceable term.
       6. The contravention photographs supplied, which are time and
       date stamped corroborate the PO's observations, clearly show
       that no valid permit was displayed in the windscreen of the
       vehicle and highlight the proximity of the vehicle to
       contractual VCS signage.
       APP: As the photos were taken from a distance, they do not show
       the missing permit which is always present in the car as a
       courtesy, further there are no signs.
       7. Both the period of observation by the PO and our photographic
       evidence comply with the Single Code of Practice.
       APP: Need help on how to respond to this point? Do they comply
       with the Single Coe of Practice?
       8. As registered keeper, we are holding the appellant liable for
       the Charge Notice under Schedule 4 of the Protection of Freedoms
       Act 2012, details of which where explained in the formal Notice
       sent on 24/04/2025. We note that the appellant has also declined
       to name the driver of their vehicle at the time of the incident
       in question. It is important that we make the adjudicator aware
       that we will rely on the keeper liability provisions within
       Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) and as
       such, do not require those details.
       APP: The Notice to Keeper fails to comply with the Protection of
       Freedoms Act 2012, Schedule 4, Paragraph 9(2)(a), because it
       does not specify the required “period of parking.” A single
       timestamp is not a period. This failure invalidates any attempt
       to transfer liability from the unknown driver to the registered
       keeper. If the assessor is indeed a solicitor or a barrister
       they should be familiar with the persuasive appeal decision in
       Scott Brennan v Premier Parking Solutions Ltd (2023) [H6DP632H].
       Furthermore, the operator has not shown that the vehicle was
       parked for longer than the minimum consideration period required
       under the Private Parking Single Code of Practice (Section 5.1).
       No contract could have been formed without first allowing the
       driver an opportunity to review and accept the terms.
       9. The contract between the appellant and VCS was formed when
       the motorist entered the car park. When entering this private
       land, a motorist freely enters into an agreement to abide by the
       conditions advertised in return for permission to enter. It is
       the motorist's responsibility to ensure that they abide by any
       clearly displayed terms and conditions. It is clear that the
       terms and conditions stated that vehicles must clearly display
       valid permit otherwise the motorist would face liability for a
       Charge Notice.
       APP: VCS cannot form a contract with the appellant as the
       appellant has an AST in place granting them rights to park in
       their allocated space without the need of a valid permit.
       10. A copy of our authority to manage parking on this site,
       including where the appellant parked their vehicle was supplied
       as part of the IPC audit process and is available solely to the
       Adjudicator for their perusal.
       APP: VCS needs to demonstrate how its “authority” to manage
       parking has been incorporated into the residents’ AST
       11. A helpline telephone number (open 24 hours per day) is
       clearly displayed on all EPS signage for any motorist
       experiencing difficulty or who has any questions or concerns.
       This was not utilised by the appellant. If the terms and
       conditions were in any way unclear to the appellant, or they
       were unsure if they applied to them, they had the option of
       contacting us for advice.
       APP: As an existing AST is in place which allows the appellant
       to park in their allocated space, using this number is
       completely unnecessary and irrelevant.
       12. The appellant has presented no evidence of either possessing
       a valid permit or of residency of an adjacent Signal Court
       property. However such evidence would not nullify the facts of
       their contravention or their liability for the charge. The terms
       and conditions for parking on this private land are clearly
       advertised by the signage on site.
       APP: A valid permit, though not necessary, is always on display
       on the vehicle, no evidence was requested to show this permit,
       if it was requested it a copy of it would have been presented to
       VCS.
       13. The appellant became liable for a Charge Notice as per the
       Terms and Conditions displayed by parking without displaying a
       valid permit.
       APP: Once again, as the appellant has an AST in place for their
       allocated space a valid permit is not needed.
       *****************************************************
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