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       #Post#: 101015--------------------------------------------------
       ParkingEye invoice
   DIR By: Brenda_R2
       Date: December 4, 2025, 10:27 am
       ---------------------------------------------------------
       First post here so please be gentle if I've messed anything up
       :)
       Upon entering the hospital site, the driver dropped their
       partner off for their appointment, entered the car park, found a
       space, parked up, and waited for their partner to re-emerge.
       Today, the document attached was received.
       Ironically, this was a follow up appointment to a private
       hospital for a knee replacement op (cost £13k) so I am somewhat
       miffed that they're trying to shaft the registered keeper for
       £100 for 15 minutes parking.
       Any of you good people able to help me out?
       Page 1:
  HTML https://ibb.co/XPjcNrb
  HTML https://ibb.co/XPjcNrb
       Page 2:
  HTML https://ibb.co/YFN0fcNn
  HTML https://ibb.co/YFN0fcNn
       Thanks in advance.
       #Post#: 101021--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: b789
       Date: December 4, 2025, 11:05 am
       ---------------------------------------------------------
       DO NOT, EVER, redact the dates, times or the location on the NtK
       if you want advice!
       Plan A... what have the hospital management said (in writing)
       when you complained about an extra invoice from a third party,
       unregulated private parking firm on top of the already expensive
       bill? If it is also an NHS Trust location, what have PALS said
       about getting it cancelled?
       As their Notice to Keeper (NtK) is not fully compliant with all
       the requirements of PoFA 2012, the driver MUST NOT be
       identified. They have no idea who the driver is as long as the
       Keeper doesn't not blab it to them, inadvertently or otherwise.
       Show us the front of the NtK without any dates, times or
       locations redacted.
       #Post#: 101092--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: Brenda_R2
       Date: December 5, 2025, 5:09 am
       ---------------------------------------------------------
       Apologies, revised documents
       HERE
  HTML https://www.imagebam.com/view/GAGUVD
       I am currently waiting on the hospital's response.
       Thank you for taking the time to respond, I do appreciate it.
       #Post#: 101118--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: ixxy
       Date: December 5, 2025, 7:19 am
       ---------------------------------------------------------
       Good luck with the argument that the NTK is not compliant, it'll
       have to go all the way to court before that argument can be
       made.
       Signage on the entrance looks pretty clear in GSV, patients
       only, register in reception. Did the driver do that? Looks like
       a private hospital as well, so probably no PALs. Assuming the
       driver didn't register how is the private parking company
       supposed to know the driver is a patient (or at least driving a
       patient). The hospital will have contracted the private parking
       company to ensure there is parking for patients, it's not a paid
       for car park like NHS ones so there's no incentive to go through
       the hassle of contracting with a private parking company if
       there is no need.
       If you want this go away quickly you'll need to appeal on the
       basis the driver was a legitimate user but failed to comply with
       the terms, i.e. forgot to register. Proof of the appointment
       would help. If you're lucky it might get cancelled or the keeper
       might be offered a reduce rate, depends on what the hospital has
       agreed with the contractor. You can try appealing on the grounds
       the NTK isn't POFA complaint but Parkingeye will definitely not
       agree with you and it's unlikely POPLA will either. So if you
       are happy with receiving months of increasing threatening
       letters and then probably having to engage with the start of a
       court process (It will probably be discontinued before the court
       hearing if you file a defence) then appeal on that technical
       basis, if they reject your appeal based on the fact the driver
       was there legitimately you're no worse off if they reject the
       appeal.
       #Post#: 101135--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: b789
       Date: December 5, 2025, 9:09 am
       ---------------------------------------------------------
       The point is that the odds of this going all the way to a
       hearing in court over an alleged debt, is very low. If
       Parkingeye think that they are on shaky ground with an appellant
       who is not low-hanging fruit on the gullible tree, they will
       likely farm it out to DCB Legal to deal with and that is a
       guaranteed strike out or discontinuation as long as it is even
       rudimentary defended.
       The simple fact is that the NtK is NOT fully compliant with all
       the requirements of PoFA. Irrespective of whether the operator
       or POPLA agree, it is a valid argument if it ever went to a
       hearing (very unlikely).
       So, once you exhaust all the other options of Plans A, B
       (initial appeal) and C (POPLA), Plan D will become the route to
       getting this dealt with, once and for all.
       #Post#: 101140--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: Brenda_R2
       Date: December 5, 2025, 9:29 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       >
       > The simple fact is that the NtK is NOT fully compliant with
       all the requirements of PoFA. Irrespective of whether the
       operator or POPLA agree, it is a valid argument if it ever went
       to a hearing (very unlikely).
       >
       >
       --- End Quote ---
       Thank you for your input, I'm definitely not going to roll over
       and play ball over this.
       Please forgive my naivety; if the NtK is defective insofar as it
       doesn't fully comply with all the requirements of PoFA, how/why
       would POPLA reject it when it comes before them?
       I fully get ParkingEye pursuing this regardless; that's how they
       make their money, after all.
       But POPLA must have some sort of guidelines that they adhere to
       when adjudicating?
       Or am I misunderstanding their raison d'être?
       #Post#: 101158--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: ixxy
       Date: December 5, 2025, 10:30 am
       ---------------------------------------------------------
       Because it's b789s personal opinion that it's not fully
       compliant, even some of the other experienced posters disagree
       in so much as they are not sure b789s interpretation is correct.
       B789 tends to give people the impression they have a rock solid
       defence and it may have some merit but it will need to go to
       court for your parking charge to be reviewed on that basis.
       Parkingeye will consider the PCN fully POFA compliant, the
       wording change b789 thinks is required in minimal, POPLA won't
       get into the fine detail of legal arguments as to whether or not
       the wording is exactly right. If they think the PCN has been
       correctly issued (for example to someone who breached the car
       park Ts and Cs by not registering at reception and the PCN has
       been issued in the correct time frame, which it appears it has
       and no other grounds of appeal have been made such as missing or
       poor signage) they will conclude the PCN has been correctly
       issued and reject the appeal.
       He is right, it is unlikely to get court but before it finally
       fizzles out you will get loads of letters which you can
       generally ignore. At some point though you will probably get a
       letter of claim which you cant ignore. You will need to engage
       with the  court system, file a defence amongst other things,
       attend a mediation session and then usually it gets dropped or
       it might not. Parkingeye are known to take a lot of people to
       court and they win.
       If you decide to challenge this the forum will help guide you
       but you need to be prepared to put the work it. The appeal
       grounds b789 has given are not a sure fire at getting this
       resolved quickly. He's relying on you fighting this all the way
       and entering a proper defence when it gets to the court stage.
       If you don't file a defence or muck it up (you will get help
       here to avoid doing that) it probably will end up in court with
       a judgement against the keeper.
       You still haven't explained why you think the PCN shouldn't have
       been issued,its not fair or I don't like private parking
       companies isn't a valid reason.
       #Post#: 101163--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: b789
       Date: December 5, 2025, 10:49 am
       ---------------------------------------------------------
       It’s not “my personal opinion” in the sense
       [member=4074]ixxy[/member] is suggesting. It is a
       straightforward reading of Schedule 4, and it happens to be
       shared by one of the longest-serving District Judges in England.
       He and I went through the actual wording of 9(2)(e)(i) and the
       ParkingEye template together; his view was clear – if Parliament
       requires the notice to invite the keeper to pay and the notice
       does not actually contain such an invitation, then it does not
       comply with PoFA. If that point were argued in front of him, he
       would find non-compliance as a matter of fact.
       Whether ParkingEye “consider” their paperwork compliant, whether
       POPLA can be bothered to grapple with the detail, or whether
       [member=4074]ixxy[/member] personally dislikes the argument is
       legally irrelevant. Compliance with a statutory gateway is not
       decided by the parking industry or by a trade-body appeals
       service; it is decided by judges applying the statute. The fact
       that this particular defect hasn’t yet been ventilated in a
       reported judgment doesn’t somehow make it invalid – every
       “leading case” started life as someone insisting that the words
       Parliament actually used mean what they say.
       I am also very careful about what I promise people. I have never
       told anyone that any single point is a magic wand or a
       guaranteed win. What I do say is that a PoFA defect which
       prevents keeper liability is a strong defence point if the
       keeper has not identified the driver. That remains true whether
       or not POPLA chooses to engage with it, and regardless of how
       inconvenient that is for ParkingEye’s business model or for
       commentators who would rather wave it away as “just b789’s
       opinion”.
       #Post#: 101164--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: Brenda_R2
       Date: December 5, 2025, 10:54 am
       ---------------------------------------------------------
       Thank you again.
       So my appeal letter (if the hospital aren't prepared to call
       their hounds off) should look like what?
       My first stab would be
       To whom it may concern,
       I acknowledge receipt of your invoice.
       The Notice to Keeper is defective as it fails to comply with the
       requirements of Schedule 4, paragraph 9(2)(e)(i) of the
       Protection of Freedoms Act 2012. As the registered keeper, I
       will not be naming the driver.
       Any further correspondence of a speculative or threatening
       nature will be treated as harassment. Should you choose to
       pursue this matter via legal channels, please be aware that I
       will defend the claim robustly and will require strict proof of
       your assertions.
       Regards, or otherwise
       As an aside, if I were a private company issuing invoices then
       I'd make damned sure they were bombproof.  Are ParkingEye
       relying on people *and* POPLA rolling over in the face of
       appeals?
       This is my first exposure to this kind of thing and it would
       appear to me that the entire industry needs an overhaul?
       #Post#: 101167--------------------------------------------------
       Re: ParkingEye invoice
   DIR By: b789
       Date: December 5, 2025, 11:15 am
       ---------------------------------------------------------
       POPLA is not a court, not a tribunal and not some stand-alone
       public body. “POPLA” is just the brand name that Trust Alliance
       Group uses for the parking product line delivered by its
       subsidiary Flexible Resolution Services Limited (company no.
       14000839). The BPA – i.e. the private parking trade association
       – contracts and funds FRS to run POPLA “on behalf of” its member
       operators. Independent?
       POPLA 'assessors' are not judges, they are not barristers, and
       in the vast majority of cases they have no meaningful legal
       training at all. They’re low-level box-ticking staff in a
       private company that’s paid by the very industry it’s supposedly
       “regulating”. Independent?
       You can see it in the decisions: they work off crib sheets and
       templates, cutting and pasting stock paragraphs, often without
       even bothering to properly address the actual points put to
       them. Nuanced arguments about the precise wording of Schedule 4,
       or the difference between keeper liability and driver liability,
       often simply sail straight over their heads. If the notice
       “looks about right” to them and the operator says it’s
       compliant, they rubber-stamp it. That’s the level we’re dealing
       with.
       So yes, I’m perfectly happy to say that, in general, POPLA
       assessors are legal lightweights – glorified form-fillers –
       whose “reasoning” carries no more authority than the template on
       their screen. They are not arbiters of what PoFA means. The
       person who actually decides that is a District Judge, in a
       court, applying the statute properly. POPLA’s view is worth
       precisely nothing once it gets to that stage. Why do you think
       that an unsuccessful POPLA decision is not binding on the
       appellant?
       As for your initial appeal (Plan B), I wouldn't even bother
       putting much effort into that. It is almost unheard of for any
       initial appeal to any private parking operator being successful.
       Where is the money in that for them?
       AS Parkingeye are a BPA operator, you at least get the
       opportunity to make a secondary appeal (Plan C) to POPLA, for
       what it's worth. If, as it is unlikely to be successful (but you
       never know) you then move on to Plan D where it is likely to go
       to litigation after the useless debt recovery stage. It is at
       this stage that you have the best chance of seeing this off.
       Even if a claim is issued, even if it progressed all the way to
       a hearing, you get to argue your side of the story in front of
       the only truly impartial arbiter, a District Judge who will
       decide whether a debt is owed for an alleged breach of contract
       by the driver.
       For your Plan B appeal I would just use:
       --- Quote ---
       > I am the keeper of the vehicle and I dispute your 'parking
       charge'. I deny any liability or contractual agreement and I
       will be making a complaint about your predatory conduct to your
       client landowner.
       >
       > As your Notice to Keeper (NtK) does not fully comply with ALL
       the requirements of PoFA 2012, you are unable to hold the keeper
       of the vehicle liable for the charge. Partial or even
       substantial compliance is not sufficient. There will be no
       admission as to who was driving and no inference or assumptions
       can be drawn. Parkingeye has relied on contract law allegations
       of breach against the driver only.
       >
       > The registered keeper cannot be presumed or inferred to have
       been the driver, nor pursued under some twisted interpretation
       of the law of agency. Your NtK can only hold the driver liable.
       Parkingeye have no hope at POPLA, so you are urged to save us
       both a complete waste of time and cancel the PCN.
       --- End Quote ---
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