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       #Post#: 94853--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: October 20, 2025, 11:52 am
       ---------------------------------------------------------
       A bit thin on the operators standing to operte' I usually use
       the following:
       --- Quote ---
       > Strict proof of a valid, contemporaneous contract or lease
       flowing from the landowner that authorises the operator to
       manage parking, issue PCNs, and pursue legal action in its own
       name. I refer the operator and the POPLA assessor to Section 14
       of the PPSCoP (Relationship with Landowner), which clearly sets
       out mandatory minimum requirements that must be evidenced before
       any parking charge may be issued on controlled land.
       >
       > In particular, Section 14.1(a)–(j) requires the operator to
       have in place written confirmation from the landowner which
       includes:
       >
       > [indent]• the identity of the landowner,
       > • a boundary map of the land to be managed,
       > • applicable byelaws,
       > • the duration and scope of authority granted,
       > • detailed parking terms and conditions including any specific
       permissions or exemptions,
       > • the means of issuing PCNs,
       > • responsibility for obtaining planning and advertising
       consents,
       > • and the operator’s obligations and appeal procedure under
       the Code.[/indent]
       >
       > These requirements are not optional. They are a condition
       precedent to issuing a PCN and bringing any associated action.
       Accordingly, I put the operator to strict proof of compliance
       with the entirety of Section 14 of the PPSCoP. Any document that
       contains redactions must not obscure the above conditions. The
       document must also be dated and signed by identifiable persons,
       with evidence of their authority to act on behalf of the parties
       to the agreement. The operator must provide an agreement showing
       clear authorisation from the landowner for this specific site.
       --- End Quote ---
       And this for signs, although you can add to it your points:
       --- Quote ---
       > Strict proof of clear, prominent, and adequate signage that
       was in place on the date in question, at the exact location of
       the alleged contravention. This must include a detailed site
       plan showing the placement of each sign and legible images of
       the signs in situ. The operator must demonstrate that signage
       was visible, legible, and compliant with the BPA Code of
       Practice that was valid at the time of the alleged
       contravention, including requirements relating to font size,
       positioning, and the communication of key terms.
       --- End Quote ---
       And the following points for good measure:
       --- Quote ---
       > Strict proof that the Notice to Keeper complies with the
       Protection of Freedoms Act 2012 (PoFA), if the operator is
       attempting to rely on keeper liability. Any failure to comply
       with the mandatory wording or timelines in Schedule 4 of PoFA
       renders keeper liability unenforceable.
       >
       > Strict proof that the NtK was posted in time for it to have
       been given within the relevant period. The PPSCoP section
       8.1.2(d) Note 2 requires that the operator must retain a record
       of the date of posting of a notice, not simply of that notice
       having been generated (e.g. the date that any third-party Mail
       Consolidator actually put it in the postal system.)
       --- End Quote ---
       #Post#: 95063--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 21, 2025, 1:38 pm
       ---------------------------------------------------------
       [member=26]b789[/member] thank you for the advice :)
       This is the latest draft. Here are the summary of the changes:
       Feedback #1 (No Proof of Valid Authority) → Replaced
       Ground 4
       Feedback #2 (signage proof) → Added to Ground 2
       Feedback #3 & #4 (NtK compliance) → Created NEW Ground 5
       --- Quote ---
       >
       > As registered keeper, I challenge this PCN on the following
       grounds:
       >
       > Ground 1: No Charges Displayed at Entrance
       > Photographic evidence (Exhibits A-D) proves:
       >
       > - Entrance shows "ASDA Welcome" with no charges (Exhibit B)
       > - Street sign shows ASDA branding, no tariff (Exhibit A)
       > - Charges only visible inside car park after entry (Exhibits
       C-D)
       >
       > This violates BPA Code Section 19.3 requiring signs to "take
       into account the expected speed and direction of travel of
       vehicles approaching the entrance." The operator actively
       invited drivers to enter while concealing a complex charging
       structure (different rates by duration, Saturday rates, Sunday
       free, Asda discounts).
       >
       > Drivers cannot be expected to research website tariffs before
       entering - adequate notice must be given at the site. By the
       time charges are visible inside, the driver has already
       committed to entering and would be in "breach" if attempting to
       leave.
       >
       > No valid contract formed.
       >
       > Ground 2: Operator Cannot Prove Actual Notice
       > Vine v Waltham Forest [2000] requires operators prove the
       driver actually saw and understood terms. ParkingEye v Beavis
       [2015] UKSC 67 upheld £85 only because of 20 large, prominent
       noticeboards throughout the site with charges in "largest font
       size."
       >
       > Mercury fails this standard:
       >
       > - no charges at entrance decision point;
       > - signs inside car park too late.
       >
       > I put the operator to strict proof of:
       >
       > - Clear, prominent, and adequate signage that was in place on
       16th August 2025, at the exact location of the alleged
       contravention
       > - A detailed site plan showing the placement of each sign and
       legible images of the signs in situ
       > - Evidence that signage was visible, legible, and compliant
       with the BPA Code of Practice that was valid at the time of the
       alleged contravention, including requirements relating to font
       size, positioning, and the communication of key terms
       > - Charges were visible at entrance before entry commitment
       > - Signage met the Beavis standard of being "reasonably large,
       prominent and legible"
       > - Photographic evidence showing entrance signage configuration
       on 16th August 2025
       >
       >
       > Ground 3: PoFA Schedule 4 Paragraph 5 Not Satisfied
       > Protection of Freedoms Act 2012 Schedule 4 Paragraph 5
       requires "the driver must have been given adequate notice of the
       parking charges" - a mandatory condition. Paragraph 4(2): keeper
       liability "applies only if conditions in paragraphs 5, 6, 11 and
       12 are met."
       > Exhibits A-D prove Paragraph 5 not satisfied. Former POPLA
       Lead Adjudicator: "If not complied with then keeper liability
       does not generally pass."
       > The operator cannot pursue the keeper regardless of Notice to
       Keeper compliance with other procedures.
       >
       > Ground 4: No Proof of Valid Authority
       > Strict proof of a valid, contemporaneous contract or lease
       flowing from the landowner that authorises the operator to
       manage parking, issue PCNs, and pursue legal action in its own
       name. I refer the operator and the POPLA assessor to Section 14
       of the PPSCoP (Relationship with Landowner), which clearly sets
       out mandatory minimum requirements that must be evidenced before
       any parking charge may be issued on controlled land.
       >
       > In particular, Section 14.1(a)–(j) requires the operator to
       have in place written confirmation from the landowner which
       includes:
       >
       > • the identity of the landowner,
       > • a boundary map of the land to be managed,
       > • applicable byelaws,
       > • the duration and scope of authority granted,
       > • detailed parking terms and conditions including any specific
       permissions or exemptions,
       > • the means of issuing PCNs,
       > • responsibility for obtaining planning and advertising
       consents,
       > • and the operator’s obligations and appeal procedure under
       the Code.
       >
       > These requirements are not optional. They are a condition
       precedent to issuing a PCN and bringing any associated action.
       Accordingly, I put the operator to strict proof of compliance
       with the entirety of Section 14 of the PPSCoP. Any document that
       contains redactions must not obscure the above conditions. The
       document must also be dated and signed by identifiable persons,
       with evidence of their authority to act on behalf of the parties
       to the agreement. The operator must provide an agreement showing
       clear authorisation from the landowner for this specific site.
       >
       > Ground 5: Notice to Keeper Non-Compliance
       > I put the operator to strict proof that:
       >
       > - The Notice to Keeper complies fully with the Protection of
       Freedoms Act 2012 Schedule 4, if the operator is attempting to
       rely on keeper liability. Any failure to comply with the
       mandatory wording or timelines in Schedule 4 renders keeper
       liability unenforceable.
       > - The Notice to Keeper was posted in time for it to have been
       given within the relevant period. The Private Parking Code of
       Practice (PPSCoP) section 8.1.2(d) Note 2 requires that the
       operator must retain a record of the date of posting of a
       notice, not simply of that notice having been generated.
       Evidence must show the date any third-party Mail Consolidator
       actually put it in the postal system.
       >
       > The operator must provide actual postal records, not just
       system-generated dates.
       >
       > Conclusion
       > This PCN should be cancelled because:
       >
       > - No adequate notice - "ASDA Welcome" invitation concealed
       charges until after entry
       > - Operator cannot prove driver saw/understood terms
       (Vine/Beavis standard not met)
       > - PoFA Schedule 4 Paragraph 5 not satisfied - keeper liability
       cannot exist
       > - No proof of valid authority from landowner
       > - Notice to Keeper compliance not proven
       >
       > The photographic evidence proves drivers entering this car
       park see only invitational ASDA-branded signage with no
       indication of charges.
       >
       > I respectfully request this appeal be allowed.
       --- End Quote ---
       #Post#: 95068--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: October 21, 2025, 2:00 pm
       ---------------------------------------------------------
       It's only POPLA. Give it a go. If it doesn't succeed, the
       decision is not binding on you and you do not pay anything.
       #Post#: 96628--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: November 3, 2025, 9:40 am
       ---------------------------------------------------------
       @b789
       Just receieved the below email from POPLA.
       Here is the link to the entire pack and their rebuttle.
  HTML https://drive.google.com/file/d/1vCg5OYT1EbsAk0wIXAAw6t2Qoa8auJwX/view?usp=sharing
       --- Quote ---
       > Dear Mr Xxxxx,
       >
       > Your parking charge appeal against Horizon Parking Ltd - EW.
       >
       > Horizon Parking Ltd - EW has now uploaded its evidence to your
       appeal. This will be available for you to view by clicking here
       >
       > Please note: some evidence may not show immediately, if it is
       not currently available on your account please check back later
       before contacting us.
       >
       > You have seven days from the date of this correspondence to
       provide comments on the evidence uploaded by Horizon Parking Ltd
       - EW.
       >
       > Please note that these comments must relate to the grounds of
       appeal you submitted when first lodging your appeal with POPLA,
       we do not accept new grounds of appeal or evidence at this stage
       >
       > Any comments received after the period of seven days has ended
       will not be considered and we will progress your appeal for
       assessment. Therefore, if you have any issues with the evidence
       uploaded by Horizon Parking Ltd - EW such as being unable to
       view it online, please contact POPLA immediately via phone -
       0330 1596 126, or email - info@popla.co.uk, so that we can look
       to rectify this as soon as possible.
       >
       > After this period has ended, we will aim to issue our decision
       as quickly as possible. The decision we reach is final and
       binding. When the decision is reached there is no further option
       for appeal.
       >
       > Yours sincerely
       >
       > POPLA Team
       >
       > ET6114/003
       --- End Quote ---
       #Post#: 96630--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: November 3, 2025, 9:46 am
       ---------------------------------------------------------
       Here is an extract of their rebuttle taken from Section B in the
       evidence pack (link above)
       --- Quote ---
       >
       > The appellant has raised several points in their appeal to
       POPLA.
       >
       > In response to Point 1, as shown in Section E, there is ample
       signage throughout the car park clearly displaying the terms and
       conditions that must be adhered to. Al signs state al the
       specific parking terms and parking charges ni the event of a
       breach. nI accordance with The Private Parking Sector Single
       Code of Practice, al signage on site is conspicuous, legible and
       written in intelligible language. By entering this car park and
       choosing to remain on site, the Appellant has entered into a
       contract with Horizon Parking and has consented to comply with
       the terms and conditions set out on the signs in that car park
       which are clearly visible.
       >
       > In response to Point 2, again all signs state all the specific
       parking terms and parking charges in the event of a breach. In
       accordance with The Private Parking Sector Single Code of
       Practice, al signage on site si conspicuous, legible and written
       in intelligible language. There are signs located at the
       entrance to, and within the car park, that state the terms and
       conditions that apply when parking. As clearly stipulated on
       signage within the car park, payment is required for parking.
       >
       > In response to Point 3, The Parking Charge fuly adheres to the
       strict requirements of the Protection of Freedom Act 2012 and
       the Registered Keeper was advised of this on both pages of the
       letter they have received - please see below.
       >
       > (POFA). The Appellant is the Registered Keeper and they have
       not confirmed whether they were the driver or who was the
       driver. Therefore, because the charge is fully compliant with
       POFA, the Registered Keeper is held liable for the Parking
       Charge their vehicle has been issued.
       >
       > In response to Point 4, Horizon Parking Limited has the
       authority of the legal occupier of the land to provide parking
       management services in accordance with the stated terms and
       conditions of parking. This is evidenced simply by the existence
       of Horizon's equipment being on the legal occupier's land. Such
       equipment could not be on the land without the consent of the
       legal occupier. Regardless of these facts, it is settled law
       that only a third party with a higher proprietary interest in
       the land can challenge Horizon's authority to act. In absence of
       such higher proprietary interest, Horizon is under neither a
       duty nor obligation to disclose commercial documents between
       Horizon and its clients.
       >
       > In response to Point 5, the vehicle breached the car park
       terms and conditions on 16/08/25 and the Parking Charge was then
       issued, and the letter sent on 26/08/25.Therefore, we have sent
       the Parking Charge letter within the timeframe set out in the
       Private Parking Sector Single code. It must be noted that once
       the Parking Charge is issued it is not within the control of
       Horizon Parking about the delivery of the letter. It is up to
       the local post office to deliver the letter to its destination
       on time. If the Appellant has any issue regarding the delivery,
       they wil have to take it up with their local post office.
       >
       > When entering a car park located on private land and choosing
       to remain on site, the motorist enters a valid contract and
       agreed to abide by the car park's terms and conditions which are
       detailed on signs, which are on display at various points within
       the car park itself. The signage displayed throughout the site
       advises the terms and conditions of use and one of the
       conditions is that a £85.00 Parking Charge will be issued when
       the terms and conditions are breached.
       >
       > It is the keeper's responsibility when parking on private land
       to ensure they familiarize themselves with the terms and
       conditions on site via the signage, this ensures they are aware
       of the charge should they breach the terms and conditions on
       site.
       >
       > By parking the vehicle on the site, the appellant entered a
       valid contract and agreed to abide by its terms and conditions.
       The signage displayed throughout the site advises the terms and
       conditions of use. One of the conditions is that a £85.00
       Parking Charge wil be issued when the terms and conditions are
       breached.
       >
       > Our position remains that this Parking Charge was issued
       correctly. We maintain the appellant entered a valid contract
       and should pay the valid parking charges as per the signage on
       the site.
       >
       >
       >
       --- End Quote ---
       #Post#: 96634--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: DWMB2
       Date: November 3, 2025, 9:59 am
       ---------------------------------------------------------
       --- Quote from: bigred247 link ---
       >
       > In response to Point 4, Horizon Parking Limited has the
       authority of the legal occupier of the land to provide parking
       management services in accordance with the stated terms and
       conditions of parking. This is evidenced simply by the existence
       of Horizon's equipment being on the legal occupier's land. Such
       equipment could not be on the land without the consent of the
       legal occupier. Regardless of these facts, it is settled law
       that only a third party with a higher proprietary interest in
       the land can challenge Horizon's authority to act. In absence of
       such higher proprietary interest, Horizon is under neither a
       duty nor obligation to disclose commercial documents between
       Horizon and its clients.
       >
       --- End Quote ---
       I've not read the full evidence pack, but your response should
       go to town on this point. They've failed to demonstrate they
       have authority to issue parking charges on the site by failing
       to disclose their contract. Their position is essentially "trust
       us, we put up some signs".
       Their suggestion that the existence of their equipment shows a
       valid contract is nonsense - it might suggest that such
       permission existed at some point, but that's not proof that they
       had such permission at the time of this parking event. For all
       we know their contract could have expired the week before, for
       example.
       #Post#: 96649--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: November 3, 2025, 11:19 am
       ---------------------------------------------------------
       Indeed — Horizon’s response to Point 4 is not just weak, it’s
       legally indefensible and contrary to the very purpose of Section
       14 of the Private Parking Single Code of Practice (PPSCoP). A
       strong rebuttal could read as follows (for POPLA comments or
       subsequent formal complaint):
       --- Quote ---
       > Comments on Point 4 – Authority to Operate:
       >
       > Horizon’s response is an exercise in deflection and
       demonstrates either a complete misunderstanding of the legal
       concept of authority or a deliberate attempt to conceal the
       absence of it. Their claim that the presence of “equipment being
       on the land” constitutes proof of authority is legally
       meaningless. It might indicate that permission existed at some
       point in time, but it cannot possibly establish that such
       authority was valid and extant on 16 August 2025 — the date of
       the alleged event. Contracts expire, are terminated, or
       replaced, and physical signage or cameras are often left behind.
       Horizon’s reasoning is therefore not evidence of authority; it
       is pure conjecture dressed up as fact.
       >
       > Section 14 of the Private Parking Single Code of Practice
       (PPSCoP) exists precisely to prevent this sort of evasive
       behaviour. It requires operators to hold — and to be prepared to
       produce — a written agreement with the landowner specifying the
       boundaries, duration, rights granted, and authority to issue
       parking charges in their own name. Those requirements are not
       discretionary, and they are not met by simply asserting “trust
       us”.
       >
       > Horizon’s further suggestion that only someone with a “higher
       proprietary interest” can challenge their authority is equally
       flawed. The question before POPLA is not one of competing
       property rights, but whether Horizon had standing to form or
       enforce a parking contract. POPLA’s role includes assessing
       whether a parking operator has demonstrated that it has the
       legal capacity to contract with motorists — not to take the
       operator’s word for it.
       >
       > If any assessor were to accept Horizon’s argument at face
       value, it would represent a fundamental failure to apply basic
       principles of contract law and the very Code they are bound to
       uphold. The operator has produced no evidence whatsoever of
       authority, merely a circular claim that their own signs prove
       their entitlement. In any legal setting, such reasoning would be
       laughed out of court. Should this point alone not give reason to
       cancel this PCN, in court is exactly where this will be
       challenged and ridiculed.
       >
       > Absent a dated, signed, and contemporaneous agreement
       conferring authority from the landholder, Horizon’s claim to
       issue or enforce this Parking Charge is without legal
       foundation. The appeal must therefore be allowed.
       --- End Quote ---
       You can also go to town on their point #5 with the following:
       --- Quote ---
       > Point 5 – “We sent it on time; delivery is the post office’s
       problem”
       >
       > This is a masterclass in buck-passing. PoFA Schedule 4 doesn’t
       care about Horizon’s “issue date”, internal print logs, or their
       feelings about the post. It requires the Notice to Keeper to be
       given within the relevant period. For ANPR cases, that means:
       >
       > - Para 9(4): the notice must be given within 14 days of the
       alleged parking event.
       > - Paras 9(5)–9(6): when sent by post, service is presumed on
       the second working day after posting — but only if the operator
       proves the date of posting.
       >
       > Three fatal problems for Horizon:
       >
       > 1.  “We issued it” is not “we posted it”.
       > A template print date or a back-office “generated” timestamp
       proves nothing. The clock runs from entry into the postal
       system, not when Horizon’s mail-merge spat out a PDF. If they
       use a consolidator (Whistl, Citipost, UK Mail, etc.), “handed to
       consolidator” is still not “posted”. The presumption in PoFA
       9(6) only arises from actual posting.
       >
       > 2. The burden of proof is on the operator, not Royal Mail.
       > PoFA places the duty squarely on Horizon to evidence
       compliance. The Private Parking Single Code of Practice (PPSCoP)
       section 8.1.2(d) Note 2 requires operators to retain a record of
       the date of posting. Not “date of generation”, not “we think it
       went out”, but the day it was put into the postal system. If
       Horizon can’t produce a postal manifest, DSA/OBA handover
       record, or equivalent third-party log proving posting, they
       don’t get to wave the statutory presumption around like a
       comfort blanket.
       >
       > 3. Their “not within our control” line is legally illiterate.
       > Horizon chose to rely on keeper liability via post. With that
       choice comes the statutory risk of proving service. If they
       won’t (or can’t) evidence posting, PoFA fails. End of story.
       Telling the keeper to “take it up with the post office” is the
       corporate equivalent of shrugging and hoping POPLA fills in the
       gaps for them. That isn’t law; it’s laziness.
       >
       > PoFA 9(6) — what it actually says and what it means (for the
       avoidance of any doubt)
       >
       > “(6) A notice sent by post is to be presumed, unless the
       contrary is proved, to have been delivered (and so ‘given’ for
       the purposes of sub-paragraph (4)) on the second working day
       after the day on which it is posted; and for this purpose
       ‘working day’ means any day other than a Saturday, Sunday or a
       public holiday in England and Wales.”
       >
       > Plain meaning:
       >
       > - The presumption of delivery only starts after the day of
       posting, and only on the second working day thereafter.
       > - The words “unless the contrary is proved” make this a
       rebuttable presumption. It is not automatic. It can be displaced
       by evidence.
       > - To benefit from the presumption at all, the operator must
       first prove the predicate fact: that the notice was posted on a
       specific date.
       > - Therefore, the burden of proof sits with the operator to
       produce independent evidence of posting (e.g., Royal Mail
       manifest, DSA/OBA handover, consolidator’s final handover to
       Royal Mail). Internal “generated” dates or PDF metadata are not
       proof of posting.
       >
       > What the assessor must apply:
       >
       > - No posting proof means no presumption under 9(6).
       > - No presumption means the operator cannot show the notice was
       “given” within 14 days per 9(4).
       > - Failure on this single statutory limb collapses keeper
       liability in its entirety.
       >
       > Horizon’s argument is not only wrong but embarrassingly
       ignorant of the very statute they claim to rely on. Their line
       that “it’s up to the post office” shows a complete failure to
       grasp what PoFA 9(6) actually says or means. The law could not
       be clearer: the notice is only presumed to be “given” on the
       second working day after posting, unless the contrary is proved.
       >
       > That phrase makes it a rebuttable presumption, not an
       automatic one. It exists only if the operator can first prove
       the predicate fact that the notice was actually posted on a
       specific date. Without that proof, the presumption never arises.
       >
       > Producing a copy of the NtK proves nothing about when or how
       it entered the postal system. Horizon was put to strict proof of
       postal evidence, such as a Royal Mail or consolidator handover
       record, proof of first-class or equivalent postage, and a clear
       reconciliation showing that—after applying working-day rules—the
       notice was “given” within 14 days of the alleged event. They
       provided none of this.
       >
       > Instead, they tried to shift responsibility to the postal
       service, which is legally absurd. Horizon chose to use the
       postal route to create keeper liability, so the burden of
       proving service is theirs alone. Their excuse that delivery is
       “not within our control” is a confession that they have no proof
       of compliance. This is not a minor oversight; it is a complete
       failure of a statutory condition precedent.
       >
       > Keeper liability therefore fails, and the appeal must be
       allowed.
       --- End Quote ---
       #Post#: 96756--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: November 4, 2025, 7:45 am
       ---------------------------------------------------------
       [member=26]b789[/member] [member=103]DWMB2[/member]
       Thank you for the feedback :)
       I'll reply in the motorists response section on the POPLA
       website.
       #Post#: 104815--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: January 6, 2026, 1:16 pm
       ---------------------------------------------------------
       POPLA rejected my appeal. See screen print below.
  HTML https://i.postimg.cc/BnKkX713/Screenshot_2026_01_06_at_19_12_16.png
  HTML https://i.postimg.cc/LskWVqTy/Screenshot_2026_01_06_at_19_12_30.png
  HTML https://i.postimg.cc/YSNPx43d/Screenshot_2026_01_06_at_19_12_48.png
       #Post#: 104817--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: January 6, 2026, 1:21 pm
       ---------------------------------------------------------
       Copied the text from the case notes below.
       --- Quote ---
       >
       > Decision
       > Unsuccessful
       >
       > Assessor Name
       > Gayle Stanton
       >
       > Assessor summary of operator case
       > The operator has issued the Parking Charge Notice (PCN)
       because the appellant’s vehicle was parked on the site and the
       driver failed to pay for the full duration of stay.
       >
       > Assessor summary of your case
       >  The appellant has raised the following grounds of appeal: •
       There was no adequate notice of the terms and conditions of the
       car park and the operator cannot prove that the driver say and
       understood the terms. • The PCN does not comply with - PoFA
       Schedule 4 Paragraph 5 and keeper liability cannot exist. • No
       proof of valid authority from landowner In the comments the
       appellant has reiterated and expanded on their grounds of
       appeal. They state that the operator has not provided sufficient
       evidence that it has authority to issue PCNs on the land. They
       add that the PCN was not delivered in time. The appellant has
       provided four images of the signage as evidence to support their
       appeal.
       >
       > Assessor supporting rational for decision
       >  When assessing an appeal POPLA considers if the operator has
       issued the parking charge notice correctly and if the driver has
       complied with the terms and conditions for the use of the car
       park. The Private Parking Sector Single Code of Practice (The
       Code) sets the standards its parking operators are required to
       comply with. Section 3.1.1 of the Single Code of Practice
       explains that an entrance sign is not mandatory in areas where
       drivers would not reasonably assume parking was permissible or
       where it’s not practicable, such as small shop forecourts or
       where planning restrictions prohibit signs. The images of the
       entrance signs advise that terms and conditions apply and that
       there are signs in the car park. Section 3.1.3 of the Single
       Code of Practice contains the requirements for signs displaying
       the terms and conditions. The signs must be placed throughout
       the site, so that drivers have the opportunity to read them when
       parking or leaving their vehicle. The terms and conditions must
       be clear and unambiguous, using a font and contrast that is be
       conspicuous and legible. The operator and the appellant have
       provided evidence of the signage on the site and this advises
       that payment is required and that failing to pay will result in
       a PCN being issued. Due to the above I am satisfied that the
       signage on the site complies Section 3.1.1., 3.1.3 of The Code.
       I note that the appellant states that they were unaware of the
       terms and conditions, however, it is important to note that the
       driver of the vehicle does not need to have read the terms and
       conditions of the contract to accept it. There is only the
       requirement that the driver is afforded the opportunity to read
       and understand the terms and conditions of the contract before
       accepting it. It is the driver’s responsibility to seek out the
       terms and conditions, and ensure they understand them, before
       agreeing to the contract and parking. Reviewing the photographic
       evidence of the signage on display at the site and the site map,
       I am satisfied that the driver would have walked or driven past
       at least one of the operator’s signs and as such, was afforded
       this opportunity. The appellant has stated that they question
       whether the operator has authority to issue PCNs on the site.
       The operator has advised in the case file that it has
       authorisation from the landowner to operate the land. I have
       also taken into consideration the fact there are signs in situ
       and if authority had since been removed, it is likely that the
       landowner would remove the signage at the same time. I am
       therefore satisfied that the operator has sufficient authority
       at the site on the date of the parking event. Furthermore, if
       authority had since been removed, it is likely that the
       landowner would remove the signage at the same time. Not many
       landowners would look on quietly while someone operates on their
       land without their permission. The appellant states that the PCN
       is not PoFA compliant. In this case, it is not clear who the
       driver of the appellant’s vehicle is, so I must consider the
       Protection of Freedoms Act (PoFA) 2012, as the operator issued
       the Parking Charge Notice (PCN) to the keeper of the vehicle.
       The operator has provided me with a copy of the notice to keeper
       sent to the appellant. I have reviewed the notice to keeper
       against the relevant sections of PoFA 2012 and I am satisfied
       that it is compliant. At POPLA, we accept all evidence from both
       parties in good faith, and unless proven otherwise, we assume it
       to be correct. While I do not refute the appellant’s version of
       events, it is entirely possible that the Notice to Keeper did
       not arrive due to a third- party issue concerning the
       appellant’s postal the delivery service. It is outside of
       POPLA’s remit to assess any aspect of a third- party issue. As
       such, I will work on the basis that the operator issued the
       Notice to Keeper and posted this to the appellant’s address. The
       site operates Automatic Number Plate Recognition (ANPR) cameras,
       which capture vehicles entering and exiting the site to
       calculate the time a vehicle has remained in the car park. This
       data captured is then compared with the online transaction
       record, and therefore if no payment can be located for the
       correct vehicle registration, a PCN is issued. After considering
       the evidence from both parties the vehicle was parked on the
       site and the driver did not pay for parking and therefore did
       not comply with the terms and conditions of the site. Based on
       the evidence provided, I am satisfied the parking charge has
       been issued correctly therefore, I must refuse the appeal. This
       means the appellant is required to pay the full parking charge
       to the operator.
       --- End Quote ---
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