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       #Post#: 101998--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: b789
       Date: December 11, 2025, 6:42 am
       ---------------------------------------------------------
       Excel’s reply is a standard stalling tactic. They are avoiding
       dealing with the substance of the appeal and are trying to
       manoeuvre you, the Keeper, into naming the driver. You must not
       do that.
       Excel are perfectly capable of processing a Keeper appeal and
       they know it. The Notice to Keeper was issued under Schedule 4
       of the Protection of Freedoms Act 2012 and includes the
       statutory wording enabling them to hold the Keeper liable. They
       cannot now refuse to consider the appeal unless the Keeper
       identifies the driver. Nothing in PoFA or contract law requires
       the Keeper to supply a driver’s name and address. Their letter
       is just an attempt to flush out the driver to make enforcement
       easier.
       You should simply reply once, briefly, and tell Excel that the
       appeal has already been submitted, that no driver identification
       will be provided, and that they must make a decision on the
       appeal. After that, you should ignore any further phishing
       expeditions. The next meaningful document should be either a
       rejection with IAS details or cancellation.
       A suitable response would be along these lines:
       --- Quote ---
       > I am the Registered Keeper and have already submitted my
       appeal. I will not be identifying the driver. You must now
       consider the appeal as required by Schedule 4 of the Protection
       of Freedoms Act 2012 and issue either a cancellation or a formal
       rejection with details of the independent appeals process. Any
       further demands for driver information are unreasonable and will
       not be responded to.
       --- End Quote ---
       Once that is sent, Excel will reject it, because they always do.
       The rejection will contain IAS details. The IAS rarely upholds
       consumer appeals, so the next step will be deciding whether to
       submit an IAS appeal for the record or simply prepare for the
       long game, bearing in mind that your strongest point is that
       Excel’s own payment system failed and caused the alleged breach.
       All the evidence you already have will carry significant weight
       if this ever reached court, which is not very likely.
       Save everything from the banking app and any screenshots from
       the parking app. These will matter later.
       #Post#: 102228--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: DrGazza
       Date: December 12, 2025, 12:43 pm
       ---------------------------------------------------------
       Many thanks again b789.
       It's also interesting that they keep trying to find ways to
       catch you out, by sending you a pdf letter by email, but
       requiring that you go through their appeals portal in the hope
       that you give conflicting information.
       #Post#: 103687--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: DrGazza
       Date: December 23, 2025, 11:47 am
       ---------------------------------------------------------
       Got a reply from Excel Parking late last week. In summary: we
       only logged one payment, pay up. No logs (or any other
       information) provided as per the GDPR request in the original
       appeal (thanks b789). Also interesting is the threat that if you
       appeal to the IAS the fine will automatically go up to £100.
  HTML https://i.ibb.co/6JtD4PwC/appeal-reply-44175383-pg1.jpg
  HTML https://i.ibb.co/5xTHKhsL/appeal-reply-44175383-pg2.jpg
  HTML https://i.ibb.co/ms2Wsc2/appeal-reply-44175383-pg3.jpg
       #Post#: 103694--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: b789
       Date: December 23, 2025, 12:51 pm
       ---------------------------------------------------------
       This is Excel’s formal rejection. It is a standard template and
       does not mean they have properly considered the facts you
       raised.
       They are now asserting keeper liability under Schedule 4 of the
       Protection of Freedoms Act 2012 and trying to reduce the
       situation to “you only paid for one hour so the stay was not
       covered”. That misrepresents what actually happened and ignores
       the central issue, which is the failure of their own payment
       system.
       You were right not to name the driver. There is no obligation on
       a registered keeper to identify the driver. Excel’s earlier
       letters demanding driver details were simply an attempt to make
       enforcement easier for them. They are now proceeding on the
       basis that they may pursue you as keeper, which they were always
       going to do regardless.
       Use the following as your IAS appeal:
       --- Quote ---
       > I am the Registered Keeper. I appeal to the IAS against Excel
       Parking Services Ltd’s decision to reject my representations. I
       do not admit to being the driver and I will not be identifying
       the driver.
       >
       > 1. Preliminary matters: burden and standard of proof
       > The Operator bears the burden of proving, on the balance of
       probabilities, that a legally enforceable parking charge is
       owed. It is not sufficient to assert that the Operator’s
       internal records show “no valid payment” or “payment did not
       cover the entire duration”. Where the central dispute concerns
       the reliability of the Operator’s own payment systems, the
       Operator must produce cogent, contemporaneous evidence, not mere
       conclusions.
       >
       > 2. Failure to engage with the substance of the representations
       > The rejection letter is essentially formulaic and fails to
       grapple with the actual point advanced. The representations were
       not of the “I forgot to pay” variety. The issue is that the
       driver attempted to pay in good faith via the payment methods
       imposed by the Operator, and that the Operator’s payment journey
       (app/website/processor/session logging) failed in a manner not
       apparent to the motorist at the material time. The rejection
       simply restates the allegation (“payment did not cover the
       entire duration”) without addressing the payment-system failure
       point at all.
       >
       > 3. Operator’s payment system failure and its legal
       consequences
       > Where a trader mandates that payment must be made by
       particular remote means (web/app/phone) and those means
       malfunction such that payment is not properly processed or
       recorded despite the consumer being led to believe that payment
       has been made or a session is active, any alleged breach is
       properly attributed to the trader’s system failure, not consumer
       default.
       >
       > In those circumstances, several established principles arise:
       >
       > [indent](a) Consumer Rights Act 2015
       > The provision of a payment facility is part of the service the
       Operator supplies to consumers using the site. Under the
       Consumer Rights Act 2015, services must be performed with
       reasonable care and skill. A system which presents a parking
       session as having been created/authorised/active, but
       subsequently fails to complete or record the transaction, is
       prima facie inconsistent with that statutory standard. It is not
       fair or reasonable to penalise a consumer for a defect in the
       trader’s own service architecture.
       >
       > Further, any term which has the object or effect of permitting
       the trader to impose a punitive charge where the consumer has
       taken reasonable steps to comply but is thwarted by the trader’s
       system, is liable to be regarded as unfair. The IAS is invited
       to consider whether the Operator’s position, as stated in the
       rejection letter, is consistent with statutory consumer
       fairness, particularly where the Operator has not produced the
       granular transaction/session evidence that would allow an
       independent tribunal to test the reliability of the Operator’s
       assertions.
       >
       > (b) Frustration/prevention principle
       > A party cannot rely on a condition where that party’s own act
       or default prevents performance. If the Operator removes or
       disables on-site payment options and mandates remote payment
       channels, and those channels malfunction or mislead the consumer
       as to successful completion, the Operator cannot fairly
       characterise the outcome as the consumer’s breach. The alleged
       “failure” is the foreseeable consequence of the Operator’s own
       arrangements and failures.
       >
       > (c) Estoppel/legitimate reliance
       > If the Operator’s system represents to the motorist, by the
       app interface and session status, that a parking session is
       active, the motorist is entitled to rely the system. The
       Operator should be estopped from asserting the contrary where
       the motorist’s reliance was induced by the Operator’s own
       platform. The IAS is not asked to make findings on estoppel in
       the abstract; rather, the point is that the Operator must prove,
       with proper evidence, that no such “active session”
       representation was made and/or that it was reasonable for the
       motorist to disregard it.[/indent]
       >
       > 4. Code compliance: consideration and grace are not optional
       > The Private Parking Single Code of Practice requires a
       consideration period on arrival and a grace period at the end.
       This is important because it recognises that motorists need time
       to read terms and, crucially, to attempt compliance with payment
       requirements. Time spent attempting to pay via the Operator’s
       mandated but malfunctioning payment system is time spent
       attempting compliance, not evidence of avoidance.
       >
       > The Operator’s rejection letter does not address these
       requirements at all. It simply asserts that signs are “large,
       prominent and legible” and that a helpline number exists.
       Neither assertion answers the question: what allowance was made
       for consideration time and for payment difficulties arising from
       the Operator’s systems, and how does the Operator reconcile a
       punitive charge with the Code’s requirements?
       >
       > 5. Strict proof required: disclosure of transaction and
       session evidence
       > This appeal turns on objective records. The Operator is put to
       strict proof, by producing unredacted contemporaneous logs, of
       the following:
       >
       > [indent](a) Full payment processor logs for the VRM and date
       in question, including authorisations, reversals, completions,
       and any incomplete, failed or cancelled transactions. It is not
       adequate to provide a screenshot stating “no payment”. The
       adjudicator requires the underlying transaction trail.
       >
       > (b) Full app/session logs for the VRM and date in question,
       showing whether a session was created, what start time was
       recorded, what status was displayed to the user, and whether the
       session was cancelled or failed at any point.
       >
       > (c) Evidence that the payment channels were operational at the
       material time, including any incident reports, system uptime
       logs, error rates, or known faults affecting motorists’ ability
       to pay. If the Operator asserts that the motorist should have
       used the helpline, then the Operator should produce evidence of
       the helpline’s functionality and its ability to resolve payment
       failures at the material time.[/indent]
       >
       > Absent these materials, the Operator’s case reduces to “our
       system says you did not pay” whilst simultaneously refusing to
       disclose the system records that would allow that assertion to
       be tested. That is not a safe basis on which to uphold a charge.
       >
       > 6. Distinguishing ParkingEye v Beavis
       > The Operator will no doubt rely implicitly on the general
       proposition that a parking charge may be commercially
       justifiable. However, ParkingEye v Beavis concerned clear
       contractual terms and deliberate overstay in a retail car park
       with a legitimate interest in space turnover. This case is
       materially different because the dispute is not about a consumer
       choosing to breach the terms; it is about the Operator’s own
       payment systems and whether it is fair or lawful to impose a
       punitive charge where the consumer attempted to comply and was
       misled or thwarted by the trader’s defective service.
       >
       > 7. Conclusion
       > The Operator has not discharged its burden of proof. Its
       rejection letter fails to address the core contention: that the
       alleged breach is attributable to a payment/system failure for
       which the Operator is responsible, and that the consumer acted
       reasonably in attempting to comply. The Operator has also failed
       to provide the transaction/session evidence necessary to
       determine the dispute fairly.
       >
       > For the reasons above, the appeal should be allowed and the
       charge cancelled. In the alternative, if the IAS is minded to
       dismiss the appeal, I request that it first directs the Operator
       to produce the strict proof evidence identified in section 5,
       because without it there is no proper evidential basis to prefer
       the Operator’s conclusory assertions over the objective banking
       indicators consistent with an attempted payment/session
       initiation.
       --- End Quote ---
       #Post#: 105437--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: DrGazza
       Date: January 11, 2026, 12:48 pm
       ---------------------------------------------------------
       Yet again many thanks for the comprehensive reply and sorry for
       the belated thank you.
       If you have time, a quick question. The response calls for the
       PCN to be cancelled. In the appeal to IAS is there any value in
       making a without prejudice offer to pay the uncollected fee as
       full and final settlement even though the fault is with Excel's
       own payment system?
       #Post#: 105475--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: DWMB2
       Date: January 12, 2026, 4:00 am
       ---------------------------------------------------------
       No - the purpose of an IAS appeal is to challenge the parking
       charge, not to negotiate a settlement. You could if you wanted
       to make such an offer at a later date, carefully worded
       (although I'd be minded to do so on a without prejudice save as
       to costs basis if you did).
       Do you have written confirmation from your bank about the
       pre-authorisation for the first 'amount'? If not, I'd try to get
       this, as it demonstrates the technical failure (about which you
       were entirely unaware until after the fact)
       #Post#: 105930--------------------------------------------------
       Re: Excel Parking PCN - Failure to purchase within time allowed
   DIR By: DrGazza
       Date: January 14, 2026, 3:06 pm
       ---------------------------------------------------------
       OK so a response from the operator with several attachments. The
       majority relate to the correspondence already shown and pictures
       of the terms and signage (T's & C's etc.), plus a medley of
       undated photographs of the car park showing a working payment
       machine.
       Excel have failed to provide actual system data showing logs and
       instead have made disclaiming statements as per point 3 ("we
       don't operate that payment system") and point 13 ("if you don't
       disclose who the driver was, we won't disclose the data").
       Further they have not addresssed the point that their own
       website was not operating.
       Full transparency, after a lot of hassle with the bank I managed
       to get time stamps for the authorisation requests, which I
       included in the appeal. The first was, as they state, for £0.00
       when I was setting up an account, I did immediately purchase 3
       hours and the app showed the countdown (see point 9). Of course,
       I have no evidence of this, but Excel's position, is that it's
       their 3rd party providers problem and not theirs. I did think it
       was a bit weird that I had to authorise the second payment for
       £0.75, but put it down to my account being pretty finicky on
       these sort of transactions. Also re. point about no evidence of
       calling the helpline, the reason for not calling it is that
       another driver was having exactly the same problem and they told
       me not bother calling the helpline because it just went to an
       automated message although I suspect were only referring to the
       pay by phone number provided and not their helpline. Since I
       thought I had managed to pay there, I naturally thought there
       was no need to call the helpline.
       It is also worth noting the contradictory statement of point 2
       with that of point 11 - If I'd realised there was a mistake and
       paid for 4 hours rather than additional 1 I would not have been
       issued with a PCN.
       Operator response to IAS appeal:
       The operator made their Prima Facie Case on 14/01/2026 14:31:31.
       The Operator Reported That...
       The appellant was the keeper.
       The operator is seeking keeper liability in accordance with
       PoFA..
       ANPR/CCTV was used.
       The Notice to Keeper was sent on 20/11/2025.
       A response was received from the Notice to Keeper.
       The ticket was issued on 20/11/2025.
       The Notice to Keeper (ANPR) was sent in accordance with PoFA.
       The charge is based in Contract.
       The Operator Made The Following Comments...
       1. The Parkgate Car Park Darlington Tyre & Auto Care is private
       land and motorists are allowed to enter to park their vehicle
       provided that they abide by any displayed conditions of parking.
       2. The signage (supplied) in this area states: ‘24 Hour Pay Car
       Park' and ‘After a vehicle has entered the car park, a maximum
       period of 5 minutes is allowed to purchase the required parking
       tariff'. The adjudicator will note that the EPS signage onsite,
       including its size, wording and positioning has been audited by
       the IPC, has passed audit, complies with the IPC Code of
       Practice and is deemed fit for purpose.
       3. Pay by Phone facilities are available at this car park via
       Connect Cashless Parking (CCP). This is third party software for
       which we are not responsible.
       4. Management of the car park is conducted by ANPR cameras,
       which take photographs of vehicle registration numbers as
       vehicles enter and leave the car park. The VRM images are
       compared with tickets purchased at the P&D machines and any
       vehicle that remains on the car park and fails to purchase a
       valid P&D ticket or make payment by phone is issued a Parking
       Charge Notice (PCN).
       5. As registered keeper, we are holding the appellant liable for
       the Charge Notice under Schedule 4 of the Protection of Freedoms
       Act 2012, details of which were explained in the formal Notice
       sent on 20/11/2025. We note that the appellant has also declined
       to name the driver of their vehicle at the time of the incident
       in question. It is important that we make the adjudicator aware
       that we will rely on the keeper liability provisions within
       Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) and as
       such, do not require those details.
       6. The ANPR cameras record the time of a vehicle's entry and
       exit from the car park and the images supplied show that the
       appellant's vehicle entered the car park at 17:52:00 and exited
       at 21:38:12; a parking duration of 3hr 46min 12sec.
       7. Payment data supplied shows only a single valid payment of
       the one hour tariff was made for the appellant's VRM on the day
       in question. This is not disputed by the appellant. The data
       also shows that other motorists made payments while the
       appellant's vehicle was on site.
       8. The supplied payment data further shows that no failed CCP
       payments were recorded. This is corroborated by the appellant's
       own evidence, which shows that only a zero-value authorisation
       charge had been approved on the app in addition to a payment of
       the one hour tariff (plus convenience charge). As such, the
       evidence indicates a user rather than system error, namely a
       failure to complete a purchase after approving the zero-value
       authorisation charge required to register a payment card on the
       app.
       9. It is important to note that when payment is made via
       Connect, a confirmation is issued once the payment has been
       successfully processed and the parking session has commenced.
       Unless and until such confirmation is received, a motorist has
       no reasonable basis to assume they are authorised to park.
       10. Where a motorist is unable to make payment using the
       available payment methods, or were at all unsure whether a
       payment had been made, a helpline is provided for assistance.
       The appellant has provided no evidence of calling the helpline.
       11. The appellant's underpayment does not mitigate their
       liability for the charge. A consideration period is provided to
       allow motorists to read the Terms and Conditions and either make
       a valid payment or leave site. However, in accordance with the
       recent changes to the IPC Single Code of Practice relating to
       ANPR-operated car parks, had a valid payment been made prior to
       the vehicle exiting the car park, covering the full duration of
       the stay, no Parking Charge would have been issued. As confirmed
       by the supplied payment data, no such payment was made on the
       date in question and no evidence has been provided showing that
       the motorist was unable to pay the required tariff.
       12. The contract between the appellant and EPS was formed when
       the motorist entered the car park. When entering this private
       land, a motorist freely enters into an agreement to abide by the
       conditions advertised in return for permission to enter. It is
       the motorist's responsibility to ensure that they abide by any
       clearly displayed terms and conditions. We reiterate that the
       appellant had the opportunity to leave the site if they could
       not comply with the terms and conditions.
       13. We would note that the appellant has no entitlement to the
       data they have requested as it is not personal to themselves. As
       this data is private and/or commercially sensitive, and/or
       relates to other motorists and is ultimately irrelevant with
       regards to the motorist's liability for a charge, it will not be
       supplied.
       14. The charge is in no way punitive. Any motorist who
       familiarised themselves with the signage on site would be
       notified of the relevant charges. By accepting the terms and
       conditions of parking on this private land, a motorist freely
       accepts to pay the advertised charge in event of breaching the
       contract.
       15. The adjudicator will appreciate that no motorist is entitled
       to park for free, particularly when payment facilities were
       available and operational. We maintain that the Terms and
       Conditions of parking were sufficiently brought to the
       appellant's attention at the time of parking.
       16. The appellant became liable for the charge as per the Terms
       and Conditions displayed by failing to make a valid payment to
       cover the entire duration of their stay.
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