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       #Post#: 85875--------------------------------------------------
       ECP - Walsall Waterfront Carpark - PCN
   DIR By: jayudd
       Date: August 15, 2025, 5:31 pm
       ---------------------------------------------------------
       Dear All,
       I hope you can help with the below.
       The driver was visiting family in Walsall and had booked a room
       for his daughters in the Premier Inn, that is located by the
       Waterfront.
       The driver was just dropping the daughters off and the length of
       period of time was because another member of the family had the
       room booked under their name so they had to be present in order
       to let the daughters into the room. This is the cause of the
       delay for nearly an hour.
       As a result, the driver subsequently did not think they should
       buy a ticket given the fact that they will not be staying at the
       hotel.
       I have attached a copy of the NtK received:
       Page 1:
  HTML https://i.imgur.com/FxtgrrO.jpeg
       Page 2:
  HTML https://i.imgur.com/Mc3AO3F.jpeg
       What can be done here please?
       I saw another post regarding a similar situation in Liverpool,
       should I use the letter the OP sent in for their review?
       Any help will be greatly appreciated.
       Best wishes,
       JayUdd
       #Post#: 85899--------------------------------------------------
       Re: ECP - Walsall Waterfront Carpark - PCN
   DIR By: Dave65
       Date: August 16, 2025, 5:10 am
       ---------------------------------------------------------
       The first port of call is to contact the Premier Inn and speak
       to the manager and ask them to cancel this PPN as a booking was
       made.
       Also, the PPN does not meet the criteria for the PoFA.
       b789 usually says not to pay ECP.
       #Post#: 85936--------------------------------------------------
       Re: ECP - Walsall Waterfront Carpark - PCN
   DIR By: b789
       Date: August 16, 2025, 8:12 am
       ---------------------------------------------------------
       If you follow the advice, you will not be paying a penny to ECP.
       You can appeal to both the operator and POPLA once the initial
       appeal is rejected but the most likely way this will pan out is
       that a county court claim will eventually be issued and as long
       as you defend it with the template defence we provide, you are
       guaranteed with greater than 99% certainty that it will either
       be struck out or discontinued before they are required to pay
       the £27 trial fee.
       As the Notice to Keeper (NtK) is not fully compliant with all
       the requirements of POFA 2012, they cannot hold the Keeper
       liable. As there is no legal obligation on the Keeper to
       identify the driver to an unregulated private parking firm, they
       would have no way of pursuing the Keeper.
       The process is likely to drag on for many months. 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 ---
       > 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]Subject: Appeal Against PCN – Keeper Liability Rejected
       Due to PoFA Non-Compliance
       >
       > 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 Schedule 4 of the Protection of Freedoms Act
       2012 (PoFA), 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. ECP 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.
       ECP have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       >
       > Specifically:
       >
       > [indent]• PoFA 9(2)(e)(i) requires that the NtK must invite
       the keeper to pay the unpaid parking charges. Your notice fails
       to do so. It merely refers to the driver’s liability and
       requests the keeper to identify the driver, which is not
       sufficient. Without a direct invitation to the keeper to pay,
       the conditions for transferring liability are not met.
       > • PoFA 9(2)(a) requires the NtK to identify the relevant land.
       Walsall Waterfront is a non specific location and covers a large
       area. This ambiguity fails the statutory requirement for clarity
       and renders the notice invalid for the purpose of keeper
       liability.[/indent]
       >
       > Given these clear statutory failures, you must cancel this
       charge immediately. If you choose to reject this appeal, I will
       escalate to POPLA and include these points, along with a
       complaint to the DVLA regarding your misuse of keeper data
       without lawful basis under PoFA.
       --- End Quote ---
       [/quote]
       #Post#: 85945--------------------------------------------------
       Re: ECP - Walsall Waterfront Carpark - PCN
   DIR By: jayudd
       Date: August 16, 2025, 9:37 am
       ---------------------------------------------------------
       Thank you so much Dave and b789.
       [member=26]b789[/member] - shall I put the appeal in now? or
       wait?
       Thanks
       Jahad
       #Post#: 85948--------------------------------------------------
       Re: ECP - Walsall Waterfront Carpark - PCN
   DIR By: b789
       Date: August 16, 2025, 9:48 am
       ---------------------------------------------------------
       No need to wait.
       #Post#: 85956--------------------------------------------------
       Re: ECP - Walsall Waterfront Carpark - PCN
   DIR By: jayudd
       Date: August 16, 2025, 2:56 pm
       ---------------------------------------------------------
       Thank you b789.
       I have sent the representation off via ECP website, and have
       received an acknowledgement email for it.
       Will keep you posted.
       JayUdd
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