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       #Post#: 95376--------------------------------------------------
       APCOA PCN - No payment - TfW Newport Station
   DIR By: icedspurs83
       Date: October 24, 2025, 3:33 am
       ---------------------------------------------------------
       Background:
       - Parked on evening of 23 October
       - Thought payment had gone through in app (it had not - totally
       my mistake)
       - Realised at 4pm the day after. Made payment immediately on
       app. Returned to car at 7pm to see ticket (issued at 10am)
       - Notice left on vehicle on return (images below). £85 charge -
       reduced to £50 if paid within 14 days
       - Notice left on vehicle on return (images below). £85 charge -
       reduced to £50 if paid within 14 days
       - Car is on a a salary sacrifice lease from my employer. So I am
       not the registered keeper. If a notice gets sent to them, I get
       charged an administration fee (and it takes a long time to go
       through their internal process)
       ---------------------------------------------------------
       Notice received is as follows:
  HTML https://i.ibb.co/mCFvhWC8/IMG-9701.jpg
  HTML https://i.ibb.co/11b91kX/IMG-9702.jpg
  HTML https://i.ibb.co/84zFgtsZ/IMG-9703.jpg
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       Signage in car park
       Apologies - I have not had a chance to go back out to the car
       park. I will do so to take pictures of the signage.
       The street view (
  HTML https://maps.app.goo.gl/ZnzJLeR9a94Vazqm7)
       has
       some blurry images of the signage.
       Request
       This was ultimately my mistake. And if the answer is to just pay
       up then so be it.
       But £50 feels somewhat extortionate and I just wonder whether
       there is anyway to mitigate my cost.
       Thanks
       #Post#: 95377--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: jfollows
       Date: October 24, 2025, 3:37 am
       ---------------------------------------------------------
       How much is the administration fee? That might influence your
       decision.
       #Post#: 95384--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: Dave65
       Date: October 24, 2025, 4:22 am
       ---------------------------------------------------------
       What does it say in any paperwork you have about the lease
       company charging admin fees?
       #Post#: 95452--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: b789
       Date: October 24, 2025, 12:52 pm
       ---------------------------------------------------------
       As the car is leased to you, and you are not the Keeper, you are
       the Hirer, the way the lease company should deal with this for
       them to receive the Notice to Keeper (NtK) and then they
       transfer liability to you by providing APCOA your details and a
       copy of the lease and liability declaration. You then receive a
       Notice to Hirer (NtH) from APCOA which is very easy to deal with
       and you won't be paying a penny to APCOA as long as you do not
       identify the driver.
       As for the admin fee from the lease company, you may not be
       obliged to owe it to them, depending on the wording in your
       lease agreement and references to invoices from private parking
       firms. This is NOT a "fine" or a "penalty" issued by any sort of
       "authority". It is simply a speculative incline from an
       unregulated private parking firm for an alleged breach of
       contract by the driver.
       As you cannot respond to that Notice to Driver (NtD) as the
       Keeper, you are kind of stuffed unless you admit to being the
       driver and pay the charge. The only saving grace is that if you
       don't pay it, apart from loads of useless debt recovery
       threatening letters, nothing will happen because APCOA do not
       litigate. You can safely ignore all debt collectors as they are
       powerless to do anything except to try and intimidate the
       low-hanging fruit on the gullible tree into paying out of
       ignorance and fear.
       If you can persuade the lease company to give you a Letter of
       Authority (LoA) to act on their behalf as the Hirer, then you
       could appeal it as the Hirer. However, unless you get that LoA,
       you cannot do anything until you receive an NtH.
       It is very easy to appeal once you have either an NtH or LoA
       because the driver is not identified (no legal obligation to do
       so to an unregulated private parking firm) and they cannot
       transfer liability from the unknown driver to the known Hirer as
       the location of the alleged contravention is on land that is not
       relevant for the purposes of PoFA 2012.
       This would be the appeal if you were the Keeper or to receive an
       NtK or NtH:
       --- Quote ---
       > I am the Hirer. APCOA cannot hold a Hirer liable for any
       alleged contravention on land that is under statutory control.
       As a matter of fact and law, APCOA will be well aware that they
       cannot use the PoFA provisions because TfW Newport Station is
       not 'relevant land'.
       >
       > If the TfW wanted to hold owners or keepers liable under
       Railway Bylaws, that would be within the landowner's gift and
       another matter entirely. However, not only is that not pleaded,
       it is also not legally possible because APCOA is not the
       landowner and your 'parking charge' is not and never attempts to
       be a penalty. It is created for APCOA’s own profit (as opposed
       to a bylaws penalty that goes to the public purse) and APCOA has
       relied on contract law allegations of breach against the driver
       only.
       >
       > The Hirer cannot be presumed or inferred to have been the
       driver, nor pursued under some twisted interpretation of the law
       of agency. Your NtH can only hold the driver liable. APCOA 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#: 95669--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: icedspurs83
       Date: October 26, 2025, 3:20 pm
       ---------------------------------------------------------
       Thank you all.
       The lease company has a charge of £15 - so not end of the world.
       And as you say - I may be able to defend.
       I note the point you've made about them transferring liability
       and it being easy to appeal on the basis the driver is not
       identified.
       A few questions from me:
       (1) I think the lease company can provide me with a LoA. Do I
       need to wait until APCOA send the notice to them and they
       transfer liability to me, or can I take any proative steps to
       appeal this in the meantime?
       (2) Also - can I just check, once in motion - will APCOA accept
       this appeal and remove the charge? Or will I need to go through
       POPLA?
       #Post#: 95680--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: b789
       Date: October 26, 2025, 5:16 pm
       ---------------------------------------------------------
       APCOA usually concede for a no PoFA case. I doubt you'll get an
       LoA. All the lease company has to do is pass liability to you as
       the Hirer and then APCOA will send you a new Notice to Hirer
       (NtH) which you will appeal.
       #Post#: 95814--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: icedspurs83
       Date: October 27, 2025, 4:52 pm
       ---------------------------------------------------------
       Thanks.
       Sorry if this is made clear above, but do I need to wait 28 days
       for APCOA to send the notice to the lease company (and for them
       to transfer liability to me)? i.e. I cannot appeal now as I am
       not the keeper?
       If that is the case, should I proactively reach out to the lease
       company to inform them I have an incoming ticket? When I
       previously received a fine (see here
  HTML https://www.ftla.uk/private-parking-tickets/premier-park-pcn-not-parked-wholly-within-bay-capital-shopping-park-cardiff/msg84809/#msg84809),<br
       />the lease company automatically paid it and I had to fight
       them
       for months to get them to repay me etc.. I could certainly go
       down that path but it would be more helpful if I could deal with
       it now and have the matter closed.
       The lease company did send me a LoA (despite paying it...) last
       time, so maybe they would send me one this time. If I had one
       prior to the 28 day period, could I fight this and close it down
       before it even gets to the lease company (again, to save a
       further fight for the admin fee?).
       Thanks
       #Post#: 95819--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: b789
       Date: October 27, 2025, 5:04 pm
       ---------------------------------------------------------
       So, you have a moronic lease company that has no understanding
       of the law. Unless you have an LoA that covers this PCN, you
       cannot respond to the NtK. So, you can proactively approach the
       lease company but you need to make it very clear that they MUST
       NOT pay a PCN as it is nothing but an invoice for an alleged
       breach of contract by the driver and NOT a "fine" or "penalty"
       as no "offence" has been committed.
       All they have to do when they receive the NtK, is transfer
       liability to the Hirer (you) as instructed on the NtK. Once they
       have transferred liability, they will o longer have any
       liability and it will all have been transferred to you, the
       Hirer.
       Once liability is transferred, the parking operator must issue a
       new Notice to Hirer (NtH) to you, in your name and you can
       easily see this off.
       If the lease company pays it, you can ONLY try and persuade them
       to not charge you for their mistake or, if necessary, sue them.
       #Post#: 95870--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: icedspurs83
       Date: October 28, 2025, 5:24 am
       ---------------------------------------------------------
       Ok so could you please confirm my understanding:
       - If I can receive a LoA (specific to this PCN) ahead of APCOA
       issuing the notice to the lease company:
       > I can respond to the PCN and appeal.
       > The consensus is that APCOA should allow the appeal and
       the matter should be closed.
       - If I can't recieve the LOA ahead of APCOA issuing the notice
       to the lease company:
       > I should ensure the lease company do not pay (contact them
       ahead of time) and instead, all they should do is follow the law
       and transfer liability to me.
       > I can challenge the lease company for any admin fee on the
       basis this is not a "fine".
       > Once I receive the NtH, I can respond to the PCN and
       appeal.
       > Again, the consensus is that APCOA should allow the
       appeal and the matter should be closed.
       For the appeal in either scenario - I can use the wording above
       (i.e. "APCOA cannot hold a Hirer liable for any alleged
       contravention on land that is under statutory control...").
       Is that correct?
       #Post#: 95881--------------------------------------------------
       Re: APCOA PCN - No payment - TfW Newport Station
   DIR By: InterCity125
       Date: October 28, 2025, 6:30 am
       ---------------------------------------------------------
       Your ability to challenge the lease company will depend on the
       precise wording in your contract. If they only use the wording
       "fine" or "Penalty" then you'd be on pretty solid ground.
       However, if they use further terminology which could be
       interpreted to mean a private parking charge then you'd be on
       thin ice.
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