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       #Post#: 73029--------------------------------------------------
       Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: abipa
       Date: May 23, 2025, 7:44 pm
       ---------------------------------------------------------
       Received a notice as mentioned in the subject for parking car in
       front of a convenience store at about 1:40am. There seems to be
       only a single board which says that it is a private parking
       space but it was hardly visible being next to the board of the
       convenience store and the fact that it being that time of the
       night. There are no parking bays in the aforementioned place. No
       boards signifying that it is a private parking space is seen at
       the entry of the car park space though it hardly looks like a
       valid car parking space. Could I challenge this fine?
       [attachment deleted by admin]
       #Post#: 73033--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: b789
       Date: May 23, 2025, 11:23 pm
       ---------------------------------------------------------
       What “fine”? I will give you £100 for every occurrence you can
       show me of that word. It is just a speculative invoice from an
       unregulated private parking company for an alleged breach of
       contract by the driver.
       Easy one to deal with… as long as the unknown drivers identity
       is not revealed. There is no legal obligation on the known
       keeper (the recipient of the Notice to Keeper (NtK)) to reveal
       the identity of the unknown driver and no inference or
       assumptions can be made.
       The NtK is not compliant with all the requirements of PoFA which
       means that if the unknown driver is not identified, they cannot
       transfer liability for the charge from the unknown driver to the
       known keeper.
       Use the following as your appeal. No need to embellish or remove
       anything from it:
       --- Quote ---
       > I am the keeper of the vehicle and I dispute your 'parking
       charge'. I deny any liability or contractual agreement and I
       will be making a complaint about your predatory conduct to your
       client landowner.
       >
       > As your Notice to Keeper (NtK) does not fully comply with ALL
       the requirements of PoFA 2012, you are unable to hold the keeper
       of the vehicle liable for the charge. Partial or even
       substantial compliance is not sufficient. There will be no
       admission as to who was driving and no inference or assumptions
       can be drawn. PPS has relied on contract law allegations of
       breach against the driver only.
       >
       > The registered keeper cannot be presumed or inferred to have
       been the driver, nor pursued under some twisted interpretation
       of the law of agency. Your NtK can only hold the driver liable.
       PPS have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       #Post#: 74275--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: Abdullah
       Date: June 2, 2025, 5:28 am
       ---------------------------------------------------------
       My appeal to PPS was rejected.
       Could you please advise me on the next steps?
       Thank you.
       [attachment deleted by admin]
       #Post#: 74383--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: b789
       Date: June 2, 2025, 3:02 pm
       ---------------------------------------------------------
       As expected. You now have 33 days from the appeal rejection date
       to submit a POPLA appeal. Have search of the forum for other
       POPLA appeals to get an understanding of the structure. You will
       only be appealing as the Keeper.
       Do a search of the forum for other POPLA appeals to get an idea
       of the structure and how to present your arguments. You should
       build a POPLA appeal around these points:
       --- Quote ---
       > 1. The Notice to Keeper does not comply with paragraph 9(2)(a)
       of the Protection of Freedoms Act 2012. It does not specify the
       required period of parking and instead refers only to a single
       timestamp. A single moment in time is not sufficient to meet the
       statutory requirement for a period of parking. (Brennan v
       Premier Parking Solutions [2023])
       >
       > 2. The Notice to Keeper does not comply with paragraph
       9(2)(e)(i) of the Protection of Freedoms Act 2012. It fails to
       include the mandatory invitation for the keeper to pay the
       unpaid parking charge.
       >
       > 3. The signage at the site was inadequate, especially
       considering the alleged contravention occurred at 1:42am in
       darkness. There is no evidence that signage was visible or
       legible at that time. There is also no entrance signage, and the
       area resembles a shop forecourt with no marked bays or other
       indication that it is private land subject to parking terms.
       >
       > 4. No contract could have been formed because there is no
       evidence that the vehicle remained on site for longer than the
       minimum consideration period. The operator is put to strict
       proof that the vehicle stayed longer than the reasonable time
       required for the driver to locate, read, and understand the
       signage and decide whether to stay or leave.
       >
       > 5. The operator is put to strict proof that they had a valid
       and current contract with the landowner at the time of the
       alleged contravention, authorising them to operate on the land
       and issue and enforce parking charges in their own name.
       --- End Quote ---
       When you are ready, show us your planned POPLA submission and we
       will advise on anything that needs editing or adding.
       #Post#: 76519--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: abipa
       Date: June 14, 2025, 8:44 pm
       ---------------------------------------------------------
       I am the registered keeper of the vehicle referenced above and
       am appealing against the Parking Charge Notice issued by PPS. I
       respectfully request that POPLA consider the following grounds
       for appeal and cancel the charge:
       ⸻
       1. Non-compliance with Paragraph 9(2)(a) of Schedule 4 of the
       Protection of Freedoms Act 2012
       The Notice to Keeper (NtK) issued by the operator fails to
       comply with the mandatory requirements of Paragraph 9(2)(a) of
       Schedule 4 of the Protection of Freedoms Act (PoFA) 2012.
       Specifically, it does not specify “the period of parking
       to which the notice relates.” Instead, it refers only to a
       single timestamp, which cannot constitute a
       “period.” This omission fails to meet the statutory
       requirement.
       This point is supported by case law: Brennan v Premier Parking
       Solutions [2023], in which the court confirmed that a single
       timestamp does not fulfill the requirement to state a
       “period of parking.”
       ⸻
       2. Non-compliance with Paragraph 9(2)(e)(i) of Schedule 4 of the
       Protection of Freedoms Act 2012
       The NtK also fails to comply with Paragraph 9(2)(e)(i) of
       Schedule 4 of PoFA 2012, which requires the notice to
       “state that the creditor does not know both the name of
       the driver and a current address for service for the driver and
       invite the keeper to pay the unpaid parking charges.” The
       notice issued does not contain this mandatory wording and
       therefore fails to establish the keeper’s liability under
       PoFA.
       ⸻
       3. Inadequate and Unclear Signage, Especially at Night
       The alleged contravention occurred at 1:42am – a time when
       visibility is low. The signage at the location was not
       adequately lit or positioned to be clearly seen and understood
       by a driver entering the site in darkness. There is no evidence
       provided by the operator to show that signs were illuminated or
       legible at that time.
       Furthermore, the area appears to be a shop forecourt with no
       marked bays or clear boundary signage to indicate private land.
       There is also no entrance signage making the parking terms
       apparent upon arrival. The BPA Code of Practice requires clear,
       prominent, and well-lit signage, which is absent here.
       ⸻
       4. No Evidence of a Breach of Contract – No Proof of
       Overstay Beyond Consideration Period
       No contract can be formed without the opportunity to consider
       the terms. The BPA Code of Practice requires a reasonable
       consideration period to allow drivers time to read and
       understand the signage before entering into a contract. The
       operator has provided no evidence that the vehicle remained on
       site beyond the minimum consideration period.
       I put the operator to strict proof of the duration the vehicle
       was present, and of how long the signage reasonably takes to
       read and assess under the conditions at the time (i.e., at
       1:42am, in the dark).
       ⸻
       5. No Evidence of Landowner Authority
       The operator has not demonstrated that they have a valid,
       unredacted, and current contract with the landowner, authorising
       them to manage parking, issue charges, and take enforcement
       action in their own name. This is a requirement of the BPA Code
       of Practice (Section 7). I put the operator to strict proof of
       their legal standing at the site during the time of the alleged
       incident.
       ⸻
       For the reasons outlined above, the Parking Charge Notice is
       invalid and unenforceable. The operator has failed to meet
       statutory requirements under PoFA, has not demonstrated a valid
       contract with the landowner, and has not provided adequate
       signage or evidence of a breach. I respectfully request that
       POPLA uphold this appeal and cancel the charge
       Will this suffice?
       #Post#: 76537--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: b789
       Date: June 15, 2025, 5:05 am
       ---------------------------------------------------------
       When referring to the CoP, only signage refers to the old BPA
       CoP v9
  HTML https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/Version91.2.2024.pdf.<br
       />Everything else should refer to the relevant section of the
       BPA/IPC PPSCoP
  HTML https://irp.cdn-website.com/262226a6/files/uploaded/sector_single_Code_of_Practice_Version_1.1_130225.pdf.
       Also, you need to 'flesh out' the points a bit more. For
       example, you state that the NtK fails various PoFA requirements.
       You need to then explain that because of those failures,
       liability cannot transfer from the unknown driver to the known
       Keeper.
       #Post#: 77008--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: abipa
       Date: June 18, 2025, 8:29 am
       ---------------------------------------------------------
       I am the registered keeper of the vehicle referenced above and
       wish to appeal the Parking Charge Notice issued by Private
       Parking Solutions (PPS). I respectfully ask POPLA to consider
       the following legal and factual grounds for appeal:
       &#11835;
       1. Non-compliance with Paragraph 9(2)(a) of Schedule 4 of the
       Protection of Freedoms Act (PoFA) 2012
       The Notice to Keeper (NtK) fails to comply with Paragraph
       9(2)(a) of Schedule 4 to the PoFA 2012, which requires that the
       notice must specify:
       “the period of parking to which the notice relates.”
       The NtK issued by PPS refers only to a single timestamp rather
       than a period, which does not satisfy the requirement to state
       the duration of parking. The law clearly requires a period, not
       a snapshot moment.
       This interpretation is supported by Brennan v Premier Parking
       Solutions [2023], where the court found that a timestamp alone
       does not meet the definition of a “period of parking.”
       &#9888; As a result of this statutory failure, PPS cannot rely
       on Schedule 4 to transfer liability from the unknown driver to
       me, the registered keeper. Where the operator does not comply
       with PoFA in full, keeper liability cannot be established.
       &#11835;
       2. Non-compliance with Paragraph 9(2)(e)(i) of PoFA 2012
       PoFA 2012 requires the NtK to:
       “state that the creditor does not know both the name of the
       driver and a current address for service for the driver and
       invite the keeper to pay the unpaid parking charges.”
       The NtK from PPS does not contain this mandatory wording, nor
       any clear statement confirming that the operator lacks the
       driver’s details. Without this, the requirements of Paragraph
       9(2)(e)(i) are not met.
       &#9888; This omission renders the NtK non-compliant with PoFA,
       and therefore PPS cannot hold me, the keeper, liable for the
       charge. Liability under Schedule 4 arises only if the operator
       meets all the conditions it lays out.
       &#11835;
       3. Inadequate Signage – Especially at Night (BPA CoP v9)
       The alleged parking event occurred at 1:42 AM, during hours of
       low visibility. The signage at the location was:
       •
       •
       •
       •
       According to Section 18 of the BPA Code of Practice v9, signage
       must be:
       “clear, prominent and placed at key locations on entry and
       throughout the site,”
       and “must be readable and visible at night if parking is
       enforced at night.”
       &#9888; PPS has provided no evidence that the signage complied
       with these requirements at the time of the alleged event.
       Therefore, no valid contract could have been formed, and no
       breach could have occurred.
       &#11835;
       4. No Evidence of a Breach – No Proof of Stay Beyond
       Consideration Period (PPSCoP)
       According to the Private Parking Code of Practice (PPSCoP),
       operators must allow drivers a reasonable consideration period
       to read signage and decide whether to stay.
       PPS has failed to:
       •
       site
       •
       •
       given at 1:42 AM
       &#9888; Without such evidence, no breach of contract can be said
       to have occurred. The absence of marked bays or any visible
       boundary further blurs the basis for enforcement.
       &#11835;
       5. No Evidence of Landowner Authority (PPSCoP, Section 7)
       PPS has not demonstrated that it has a valid, current, and
       unredacted contract with the landowner that authorises:
       •
       •
       •
       The PPSCoP requires operators to hold written authorisation from
       the landowner. I put the operator to strict proof of:
       •
       •
       •
       &#9888; Without this, PPS has no legal standing to pursue this
       charge.
       &#11835;
       •
       PoFA 2012, meaning keeper liability cannot be established.
       •
       especially given the time and lighting conditions.
       •
       contract was ever formed.
       •
       Private Parking Code of Practice.
       Given the weight of these legal and procedural failings, I
       respectfully request POPLA to uphold this appeal and cancel the
       Parking Charge Notice.
       Is this better?
       #Post#: 77020--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: b789
       Date: June 18, 2025, 9:24 am
       ---------------------------------------------------------
       A bit better. However there are weaknesses in it. Point #2 is
       waffle without proper reference. The wording used is not
       "mandatory" per se. What is required is that the meaning of the
       Act must be shown.
       The whole point of mentioning paragraph 9(2)(e)(i), is that
       there is no actual "invitation" or any synonym of the word in
       their NtK that actually invited the Keeper to just pay the
       charge. The NtK does not have to actually say "you (or the
       Keeper) is now invited to pay the charge". If only has to convey
       that invitation. It does not. It could say something like "you
       can now pay the charge or provide us with the drivers
       details...". That would amount to an invitation. It could just
       say "you are now invited to pay the charge or...".
       In this case, it simply says "We, the Creditor, now require this
       amount to be paid using one of the payment methods described
       overleaf. If you were not the driver of the vehicle, you should
       notify us (in writing using the form attached) of the name of
       the driver and a current address for service for the driver and
       pass this Notice on to the driver." Where is there any
       invitation for the Keeper (or "you") to pay the charge? Just
       because it says they "...now require the amount to be paid...",
       is not an invitation to the Keeper to pay it. There can be no
       invitation by inference, just because the NtK is addressed to
       the Keeper.
       PoFA paragraph 9(2) is prefaced with the word "MUST", which
       means it is a requirement, not an option for the following sub
       paragraphs to be complied with. 9(2)(e) requires the notice to
       "...and invite the keeper-". Sub section (i) then says "to pay
       the unpaid parking charges" OR subsection (ii) which attest "to
       notify the creditor of the name of the driver...". However,
       there is no legal obligation on the Keeper to comply with
       subsection (ii).
       Point #4 is weak. Besides PoFA, another strong point is that
       there is no evidence of any contract by conduct could have been
       formed with the driver. Why have you not referenced the relevant
       section of the PPSCoP? Section 5.1 explains what a consideration
       period is. The very start of section 5.1 states: "Where a
       parking operator assumes a vehicle is parked based on time alone
       they must allow a consideration period of appropriate duration,
       subject to the requirements set out at Annex B." Where is the
       evidence that a consideration period was allowed? Where have
       they referenced PoFA 9(2)(a) which MUST state: "...the period of
       parking to which the notice relates"?
       You should then reference Brennan v Premier Parking Solutions
       (2023) [H6DP632H]. State that the judge in that persuasive
       appellate case ruled that without a "period of parking", of some
       short duration, then the notice is not compliant with PoFA.
       That leads on to the fact that without evidence of a period of
       parking, there is also no evidence of any contract having been
       formed by conduct because the PPSCoP section 5.1 refers to Annex
       B, Table B1, which shows that for this car park, there must be a
       minimum consideration period of 5 minutes. Where is the
       operators evidence that the vehicle was parked for longer than
       the minimum consideration period?
       Point #5 is not right. Of course they haven't provided evidence
       of landowner authority. You are putting them to strict proof
       that they have a valid contract flowing from the landowner.
       Have a read of section 14 of the PPSCoP and put them to strict
       proof of a valid contract that complies with all the points that
       the PPSCoP states they must evidence. Unless a Letter of
       Authority, instead of a contract evidences all those points, it
       is not sufficient.
       So, it needs fleshing out and there are plenty of other POPLA
       appeals on the forum you could search for that have the kind of
       detail you need for your own appeal.
       #Post#: 77033--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: abipa
       Date: June 18, 2025, 10:06 am
       ---------------------------------------------------------
       Point #5 is not right. Of course they haven't provided evidence
       of landowner authority. You are putting them to strict proof
       that they have a valid contract flowing from the landowner.
       I am sorry, I did not clearly understand, should I or should I
       not mention asking for the proof of valid contract from the
       landlord?
       #Post#: 77036--------------------------------------------------
       Re: Parking fine notice (by PPS) at 142-154 Victoria Road, North
       Acton Road, W3 6UL
   DIR By: b789
       Date: June 18, 2025, 10:15 am
       ---------------------------------------------------------
       You are putting the operator to strict proof that they have a
       valid contract flowing from the landowner. You do not state in
       the appeal "No Evidence of Landowner Authority" because of
       course there is no evidence of such... yet. It is only after you
       submit the appeal that the are then required to evidence their
       landowner authority.
       It's semantics, but you are dealing with a POPLA assessor who
       may only be the tea-boy. Explain everything as though you are
       talking to someone with the intellectual capacity of a
       chimpanzee.
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