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       #Post#: 91768--------------------------------------------------
       F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: joebloggs90
       Date: September 27, 2025, 2:10 pm
       ---------------------------------------------------------
       The Bewl Water FAQ itself says parking is charged from 08:00:
  HTML https://www.bewlwater.co.uk/faq/
       Registered keeper has now received a £100 PCN from First Parking
       LLP for Bewl Water.
       The notice says the car entered at 06:46 and left at 09:17 (151
       minutes). The allegation is that payment wasn’t made for the
       full duration.
       The alleged driver has a Ringo receipt showing payment from
       08:03–09:03. The car left at 09:17.
       So it looks like 3 minutes late to start and 14 minutes over at
       the end. But surely there should be a grace period either side?
       It’s highly confusing – the website itself shows 08:00, which is
       exactly why payment wasn’t made before then. Registered keeper
       has no idea what this clear signage is outside Bewl Water about
       private land that letter aludes to. Keeper is only aware that
       there is on grounds parking which begins at 08:00 which was
       largely respected.
       To make things worse, the letter is dated 17/09/2025, but it was
       only found on the doormat this morning (27/09/2025). It says the
       £100 full charge must be paid by 01/10/2025 at 11:42am, which
       doesn’t leave much time to deal with it properly.
       How does this add up to a £100 bill? It makes no sense at all.
  HTML https://ibb.co/NgxGH8K8
       #Post#: 91782--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: jfollows
       Date: September 28, 2025, 1:13 am
       ---------------------------------------------------------
       First off, search the forum, you’re not the first, for example
  HTML https://www.ftla.uk/private-parking-tickets/f1rst-parking-pcn-late-payment-bewl-water/msg85149/#msg85149
       #Post#: 91822--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: b789
       Date: September 28, 2025, 9:42 am
       ---------------------------------------------------------
       DO NOT identify the driver. There is no legal obligation on the
       unknown (to them) driver to identify the known Keeper.
       The reservoir is subject to reservoir safety legislation,
       including the Reservoirs Act 1975, which imposes duties on the
       undertaker regarding inspection, maintenance, and emergency
       planning. While the leisure and parking operations are run by
       Salomons UK Ltd, a private company, the underlying land remains
       part of a statutory utility asset. Because the land is governed
       by a specific statutory Act and is part of a statutory water
       undertaking, it is not “relevant land” under Schedule 4 of the
       Protection of Freedoms Act 2012. This means that keeper
       liability for private parking charges cannot be enforced under
       PoFA at this location.
       See the linked thread above for how to word the appeal. Note the
       hook: PoFA Sch 4, para 3(1)(c) excludes land “on which the
       parking... is subject to statutory control.” If there are
       byelaws or other statutory controls in force at Bewl Water, PoFA
       keeper liability is unavailable.
       The Medway Water (Bewl Bridge Reservoir) Act 1968
  HTML https://www.legislation.gov.uk/ukla/1968/33/pdfs/ukla_19680033_en.pdf<br
       />is the local Act that established and governs the Bewl scheme
       and authorised land acquisition/works. It evidences that the
       reservoir forms part of a statutory water undertaking, i.e.,
       land under statutory control. Read together with the Reservoirs
       Act 1975 regime (which imposes statutory duties on the
       undertaker for inspection, maintenance and emergency planning)
       this places activities at Bewl within a statutory framework.
       Under PoFA 2012 Sch 4, land where parking is “subject to
       statutory control” is excluded from “relevant land,” so keeper
       liability cannot arise there.
       #Post#: 91825--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: b789
       Date: September 28, 2025, 9:54 am
       ---------------------------------------------------------
       Send the following email to First Parking by first class post
       and get a free certificate of posting from any post office to
       First Parking LLP, 27 Old Gloucester Street, London, WC1N 3AX:
       --- Quote ---
       > Subject: Formal complaint – Breach of PPSCoP 8.1.1(d) and
       KADOE (Keeper liability misrepresented at Bewl Water)
       >
       > Dear First Parking LLP Complaints Team,
       >
       > I write as the registered keeper in relation to Parking Charge
       Notice [PCN ref], issued at Bewl Water on 17/09/2025.
       >
       > Your Notice to Keeper (NtK) states or implies that you are
       able to hold me (the Keeper) liable under Schedule 4 to the
       Protection of Freedoms Act 2012 (PoFA). That statement is
       incorrect for this location and places you in breach of the
       Private Parking Single Code of Practice (PPSCoP), section
       8.1.1(d). As you know, a breach of the PPSCoP is also a breach
       of your DVLA KADOE contract.
       >
       > Why PoFA keeper liability cannot apply at Bewl Water
       > PoFA Sch 4 excludes “relevant land” where parking is “subject
       to statutory control” (Sch 4, para 3(1)(c) and 3(3)).
       >
       > Bewl Water is a statutory reservoir/undertaking created and
       governed by specific legislation, including:
       >
       > [indent]• Medway Water (Bewl Bridge Reservoir) Act 1968 (local
       Act establishing the scheme; authorising works and land
       acquisition).
       > • Reservoirs Act 1975 (statutory safety regime imposing duties
       on the undertaker for inspection, maintenance and emergency
       planning).[/indent]
       >
       > The presence of this statutory framework means the land is
       under statutory control for PoFA purposes, irrespective of
       present operational or ownership arrangements.
       >
       > References (official sources)
       >
       > [indent]• PoFA 2012]Protection of Freedoms Act 2012, Sch 4,
       para 3(1)(c), 3(3)
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted:
       > • Medway Water (Bewl Bridge Reservoir) Act 1968 (1968 c.
       xxxiii)
  HTML https://www.legislation.gov.uk/ukla/1968/33/pdfs/ukla_19680033_en.pdf<br
       />(official PDF available)
       > • Reservoirs Act 1975: legislation.gov.uk
  HTML https://www.legislation.gov.uk/ukpga/1975/23[/indent]
       >
       > Breach of PPSCoP and KADOE
       > PPSCoP 8.1.1(d) requires that operators must not state or
       imply that keeper liability applies where Schedule 4 does not.
       By asserting PoFA keeper liability at Bewl Water, your NtK
       misrepresents the legal position. This is a Code breach and,
       consequently, a breach of the DVLA’s KADOE terms, which require
       adherence to the applicable Code as a condition of data access.
       >
       > Required remedies
       > As this is a formal complaint, please confirm within 14 days
       how you will rectify this compliance failure. At minimum, I
       expect you to:
       >
       > [indent]1. Cancel PCN [PCN ref] and confirm in writing that no
       keeper liability is pursued at Bewl Water.
       > 2. Cease and correct all NtK templates and website wording for
       sites under statutory control to remove any assertion (or
       implication) of PoFA keeper liability.
       > 3. Conduct an immediate audit of outstanding NtKs issued for
       Bewl Water (and any other sites under statutory control) and
       notify affected keepers accordingly.
       > 4. Provide details of staff guidance/training updates to
       prevent recurrence.[/indent]
       >
       > If you do not provide a satisfactory response, I will escalate
       this complaint to the British Parking Association and to the
       DVLA for investigation of a PPSCoP/KADOE breach.
       >
       > Your published complaints policy states complaints must be
       submitted by post. For the avoidance of doubt, I will only
       accept your response by post or by email (your choice). Do not
       require telephone contact, web portals or third-party platforms
       for complaint handling or evidence review. Please treat this
       email as a formal complaint and provide your written response by
       [date – 14 days from today].
       >
       > Yours faithfully,
       >
       > [Full name]
       >
       > [Postal address]
       > [Email]
       > Registered Keeper of vehicle [VRM]
       > PCN: [reference]
       --- End Quote ---
       #Post#: 96651--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: joebloggs90
       Date: November 3, 2025, 11:27 am
       ---------------------------------------------------------
       Hi,
       Registered Keeper followed the sticky advise and first emailed
       the managing agent of Bewl Water to tell them about this charge
       to dispute and request cancellation. They replied to say they
       would look into it but never got back.
       Now just today I have received this letter from DCBL...
       What do I do? Stressing me out.I still dont even understand what
       this charge is about based on thread above.
       Pic link here:
  HTML https://ibb.co/cXvg7TWF
       #Post#: 96654--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: jfollows
       Date: November 3, 2025, 11:39 am
       ---------------------------------------------------------
       Did you appeal as in Reply #3 and the link given in Reply #1?
       In the meantime, ignore DCBL, do not contact them in any way.
       DCB Legal, on the other hand, should not be ignored.
       #Post#: 96678--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: b789
       Date: November 3, 2025, 2:18 pm
       ---------------------------------------------------------
       You can safely ignore any debt recovery letters. Debt collectors
       are powerless to do anything except to try and intimidate the
       low-hanging fruit on the gullible tree to pay up out of
       ignorance and fear. You can safely shred those letters and use
       them as hamster bedding for all anyone cares. Stop stressing.
       Did you send the formal complaint as advised to First Parking?
       #Post#: 96717--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: joebloggs90
       Date: November 4, 2025, 12:25 am
       ---------------------------------------------------------
       Thanks for your answers. Apologies but I did not send the letter
       above. I opted for another forum advice of first contacting Bewl
       Water themselves and asked them to cancel this as it was
       predatory. They said they would look into it and never got back
       to me then I received this letter yesterday.
       On the next letter I receive from DCBL, I will post the letter
       above to them. Or do you think I should just post it now before
       they contact again?
       Thank you for your help.
       #Post#: 96718--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: jfollows
       Date: November 4, 2025, 1:29 am
       ---------------------------------------------------------
       To repeat: do not contact DCBL in any way, do not call them, do
       not send them a letter, ignore them.
       The reason they wrote to you is because you did not take our
       advice and appeal on the basis of non-compliance with PoFA 2012
       because it is not “relevant land”.
       However you would have ended up here anyway, it’s just that you
       would have stated your position and submitted a valid appeal
       which would have been rejected anyway.
       Wait for a Letter of Claim from DCB Legal and come back here
       when you do. In the meantime, search the forum to see that in
       >99.9% of similar cases DCB Legal will eventually discontinue
       rather than pay the court fee. You will be given advice on the
       process between now and then.
       #Post#: 96778--------------------------------------------------
       Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still
       charged £100
   DIR By: b789
       Date: November 4, 2025, 9:23 am
       ---------------------------------------------------------
       It was a formal complaint that I took time to research for you.
       Thank you for wasting my time. I hope someone else doesn't waste
       their time trying to assist you, if you can't be bothered
       following the advice given.
       I saw your thread on MSE and you have decided to follow their
       advice instead, where they didn't even know about the status of
       the land in question, even after I had already given it to you.
       Good luck. I'm not going to bother with this thread from now on.
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