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       #Post#: 99772--------------------------------------------------
       Euro Car Parks - Appeal rejected for overstaying max time
   DIR By: Jppg
       Date: November 25, 2025, 11:56 am
       ---------------------------------------------------------
       Sorry in advance about the formatting of this post, I have tried
       to make it more legible, but can't seem to improve it.
       I received a NtK for overstaying 90mins at Morrisons, Solihull.
       I didn't identify the driver and sent off a generic reply
       stating that I wouldn't be identifying the driver and hence
       would not be paying.
       Predictably the appeal was rejected:
  HTML https://i.postimg.cc/3Rv9cw2q/ECP-appeal-refused-001.png
  HTML https://i.postimg.cc/SxSTxkpP/ECP-Nt-K.png
       Hope these images work, as I've never used this service before.
       From reading other posts on the forum ECP appear to threaten
       court action, regardless of any appeal to POPLA? But I was
       wondering if the following (which I have copied from the forum)
       is worth sending to them anyway:
       [left][/left]"The Notice to Keeper (NtK) fails to comply with
       multiple mandatory provisions of Schedule 4, Paragraph 9 of the
       Protection of Freedoms Act 2012 (“PoFA”), and therefore no
       keeper liability can arise. The operator may only pursue the
       driver for payment, not the registered keeper. The deficiencies
       are as follows:
       1. Failure to specify the period of parking (Paragraph 9(2)(a))
       PoFA requires the NtK to “specify the vehicle, the relevant land
       on which it was parked and the period of parking to which the
       notice relates.”
       This NtK contains no “period of parking.” It merely states that
       a parking charge was issued for “failed to make a valid payment”
       and refers to a date of issue. ANPR systems record entry and
       exit times, but those are not synonymous with a period of
       parking because they do not show when the vehicle was
       stationary. The vehicle may have spent time queuing,
       manoeuvring, or exiting. The Department for Transport’s
       statutory guidance and persuasive appeal decisions (e.g. Brennan
       v Premier Parking (2023)) make clear that a period of parking
       must refer to an actual time parked, not merely camera
       timestamps. This omission renders the NtK non-compliant with
       9(2)(a).
       2. Failure to properly invite the keeper to pay or name the
       driver (Paragraph 9(2)(e)(i))
       PoFA 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—(i) to pay the
       unpaid parking charges; or (ii) if the keeper was not the
       driver, to provide the name of the driver and a current address
       for service for the driver.”
       The NtK does not invite the keeper to pay. Instead, it commands:
       “If you were not the driver... please inform us of the name and
       current postal address of the driver and pass this notice on to
       them.”
       This is a material deviation from the statutory wording.
       Parliament intended the keeper to be given the option either to
       pay or to name the driver. A command to “inform us” is not an
       invitation to pay. The omission defeats one of PoFA’s key
       procedural safeguards and invalidates keeper liability.
       3. Defective warning of keeper liability (Paragraph 9(2)(f))
       PoFA requires the warning to state that the keeper will become
       liable if “after the period of 28 days beginning with the day
       after that on which the notice is given” the charge remains
       unpaid and the operator does not know the driver’s identity.
       The NtK instead says liability will arise “after 28 days from
       the date given (which is presumed to be the second working day
       after the Date Issued).”
       This re-wording changes the statutory time calculation. The Act
       specifies that the 28-day period begins the day after the notice
       is given, not “from the date issued.” The operator’s version
       shortens the period by at least two days, thereby failing to
       reproduce the mandatory wording prescribed by Parliament. This
       departure is not a minor error: Schedule 4 imposes strict
       conditions that must be met exactly before keeper liability can
       be invoked.
       4. Failure to unambiguously identify the creditor (Paragraph
       9(2)(h))
       PoFA requires the NtK to “identify the creditor and specify how
       and to whom payment or notification to the creditor may be
       made.”
       The NtK merely asserts that the land is “managed by Euro Car
       Parks Ltd (the creditor).” It omits the full legal entity name,
       company number and registered address. Without a full legal
       identity, the keeper cannot know who the creditor actually is,
       making the notice defective under 9(2)(h).
       5. Ambiguous dating and delivery wording (Paragraphs 9(2)(i) and
       9(4))
       PoFA requires the notice to “specify the date on which the
       notice is sent (given)” and defines when it is deemed “given.”
       The NtK refers only to a “Date Issued” without confirming when
       or how it was sent or delivered. This vagueness prevents a
       reliable calculation of statutory deadlines and is another
       failure to meet PoFA’s strict requirements.
       Conclusion
       PoFA Schedule 4 is a strict liability framework: every
       requirement must be met before any right to recover a parking
       charge from a vehicle’s keeper arises. The NtK in this case
       fails to meet at least paragraphs 9(2)(a), 9(2)(e) and 9(2)(f),
       and is further undermined by non-compliance with 9(2)(h) and
       9(2)(i). As a result, Britannia Parking cannot transfer
       liability from the unknown driver to the keeper. The operator
       may only pursue the driver, whose identity has not been
       provided. The appeal should therefore be allowed.
       In Addition
       I require 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."
       I appreciate all the time and effort put into the forum and give
       my thanks in advance for any advice given.
       [/left]
       #Post#: 99836--------------------------------------------------
       Re: Euro Car Parks - Appeal rejected for overstaying max time
   DIR By: Dave65
       Date: November 26, 2025, 4:28 am
       ---------------------------------------------------------
       With ECP PPN`s the usual advice by b789 is you will not pay
       anything to ECP.
       It most likely will go all the way to a court claim first.
       #Post#: 99839--------------------------------------------------
       Re: Euro Car Parks - Appeal rejected for overstaying max time
   DIR By: jfollows
       Date: November 26, 2025, 4:32 am
       ---------------------------------------------------------
       I though Morrisons had a process for cancelling these?
       See
  HTML https://www.ftla.uk/private-parking-tickets/eurocarparks-pcn-overstay-morrisons-shop-swansea/msg36495/#msg36495
       --- Quote ---
       > If you were customer of Morrisons, the first thing you do is
       go to their customer service website and give them details of
       the PCN so that they can get it cancelled. They have a specific
       form for this:
       >
       >
  HTML https://www.morrisons.com/help/form/contact-us/in-store-experience/car-parks/i-have-received-a-parking-charge-for-parking-in-your-car-park
       --- End Quote ---
       #Post#: 99882--------------------------------------------------
       Re: Euro Car Parks - Appeal rejected for overstaying max time
   DIR By: b789
       Date: November 26, 2025, 6:57 am
       ---------------------------------------------------------
       You can still try the Morrisons dedicated PCN form to get it
       cancelled but you should really have done that before appealing.
       You can try your POPLA appeal but don't be surprised if it is
       not successful. Invariably all ECP claims are handled by DCB
       Legal and I can assure you with greater then 99.9% certainty
       that if defended, will either be struck out of discontinued just
       before the claimant has to pay the £27 trial fee.
       #Post#: 99892--------------------------------------------------
       Re: Euro Car Parks - Appeal rejected for overstaying max time
   DIR By: Jppg
       Date: November 26, 2025, 7:36 am
       ---------------------------------------------------------
       Thanks for the replies - I really appreciate you taking the
       time.
       I will send POPLA my appeal, just to keep them occupied - who
       knows, they might learn something.........
       I will return when DCB Legal turn up with their guff.
       Once again, thanks for the replies.
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