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       #Post#: 113126--------------------------------------------------
       Re: EuroCar Parks PCN for three minute overstay
       By: Albamc Date: March 13, 2026, 7:07 am
       ---------------------------------------------------------
       Thank you! Very much appreciated.
       Best
       Al
       #Post#: 113135--------------------------------------------------
       Re: EuroCar Parks PCN for three minute overstay
       By: InterCity125 Date: March 13, 2026, 8:48 am
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       [font=Sans-serif]Euro Car Parks POPLA Appeal
       I am the Registered Keeper of the vehicle in question and, since
       the driver is not known to the operator, I will be making my
       representations purely as keeper.
       I understand that, under 'POPLA Rules', I must set out my appeal
       points and the parking operator must rebut them?
       Non compliance with PoFA 2012.
       The parking operators NtK fails to comply with PoFA and, as a
       result, liability cannot be passed from driver to keeper.
       In particular, the NtK fails to satisfy the legal requirements
       of PoFA Schedule 4 Paragraph 9(2)(e), 9(2)(e)(i) and
       9(2)(e)(ii).
       This non compliance is immediately fatal to the operators
       reliance on PoFA.
       Paragraph 9(2)(e), 9(2)(e)(i) and 9(2)(e)(ii) sets out the
       following;
       THE NOTICE MUST 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 of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver;
       So, in order to establish compliance, we must examine the
       operators NtK.
       An examination of the legislation surrounding 9(2)(e) reveals
       that compliance is achieved by the setting out of the statutory
       wording immediately followed by a two limbed 'invitation to the
       keeper' to either 'pay the unpaid parking charges' or 'nominate
       another driver'.
       So, to make this really easy, in the first instance, we are
       looking for the specific statutory wording set out in 9(2)(e)
       itself.
       The legislation specifies that THE NOTICE MUST STATE, "that the
       creditor does not know both the name of the driver and a current
       address for service for the driver"
       An examination of the operators NtK reveals that the statutory
       wording is not present.
       This is immediately fatal to the operators reliance on PoFA.
       However, to demonstrate my appeal point further, the NtK is then
       required to present a two limbed 'invitation to the keeper'
       which 'invites the keeper' to either 'pay the unpaid parking
       charges' or 'if the keeper was not the driver of the vehicle, to
       notify the creditor of the name of the driver and a current
       address for service for the driver and to pass the notice on to
       the driver'
       Please again note the exact wording of the statute;
       That the notice must 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— blah blah blah
       I have capitalised  the word AND for good reason since the word
       AND demonstrates that compliance is only achieved if the
       operator is able to demonstrate that both legs of the AND logic
       have been satisfied.
       Please note (and I apologise for sounding like a Junior School
       Teacher) that a 'warning to the keeper' is not 'an invitation to
       the keeper' - The words 'warn' and 'invite' have very different
       meanings and it is important that the correct wording is
       understood and applied when examining the NtK since other terms
       of the legislation require that 'a warning' be set out on the
       NtK - I understand that some POPLA assessors have become
       confused on this issue in the past and have inadvertently
       applied the reversed meanings - to be clear, a warning is not an
       invite.
       So, back to the two limbed invitation to the keeper - when the
       NtK is examined the two limbed invitation is not present.
       Nor is there an 'invitation to the keeper to pay the unpaid
       charges' - this is also the specific requirement of 9(2)(e)(i).
       So, as I am sure you can see, there are multiple compliance
       issues on the operators NtK.
       So,
       APPEAL POINT ONE - That the operators NtK does not contain the
       legally required mandatory wording required by 9(2)(e), namely;
       "the creditor does not know both the name of the driver and a
       current address for service for the driver" - I therefore ask
       the operator to specifically rebut this appeal point by
       supplying a copy of the relevant NTK, to the POPLA Assessor,
       with an orange rectangle around the wording, "the creditor does
       not know both the name of the driver and a current address for
       service for the driver" - for total clarity, please do not
       include any other notations on the provided NtK - just the
       orange rectangle.
       APPEAL POINT TWO - That, subsequent to the statutory wording
       required by 9(2)(e), the operators NtK does not set out the
       mandatory two legged invitation to the keeper to either pay the
       unpaid parking charges or nominate another driver - Once again,
       I ask the operator to specifically rebut this appeal point by
       supplying a copy of the NtK which clearly sets out, in an orange
       rectangle, the two legged legal invitation which the legislation
       requires in order to be compliant.
       APPEAL POINT THREE - That, in accordance with 9(2)(e) and
       subsequently 9(2)(e)(i), the NtK must 'invite the keeper to pay
       the unpaid parking charges' - Once I again I ask the operator to
       prove that the NtK complies with this requirement - please
       demonstrate the 'invitation to the keeper to pay the unpaid
       charges' - Please do not confuse this 'invitation' with any
       'warning to keeper' contained in the requirements of 9(2)(f).
       If both the Parking Operator and the POPLA Assessor could use my
       numbered points then this would be very useful and should ensure
       that all appeal points are correctly addressed.
       APPEAL POINT FOUR - That I believe that adequate time was
       purchased for the parking event which is causing this dispute -
       The Car Park in question is quite an awkward and large
       multistorey - the alleged overstay is 11 minutes and, when the
       minimum grace period is considered, the contractual dispute
       amounts to 1 minute - the operator's own evidence shows that the
       driver entered at 22.22 and left at 19.33 the following day -
       the 'time on site' was 21 hours and 11 minutes - 21 hours were
       paid for but 22 hours would have cost no more.
       Many thanks and best wishes,
       xxxxxxx xxxxxxxxxx[/font]
       #Post#: 113504--------------------------------------------------
       Re: EuroCar Parks PCN for three minute overstay
       By: Albamc Date: March 17, 2026, 6:30 am
       ---------------------------------------------------------
       Once again, thank you very much for this. I am removing the bit
       about the complex multi-storey as it isn't, but otherwise am
       submitting verbatim.
       Just one other query - I'm not sure what grounds to appeal to
       POPLA on? I have said 'I did not exceed the free period' and
       'Other'. Is that ok?
       Best
       Al
       #Post#: 113514--------------------------------------------------
       Re: EuroCar Parks PCN for three minute overstay
       By: DWMB2 Date: March 17, 2026, 7:35 am
       ---------------------------------------------------------
       Given one of your points is about keeper liability, and relies
       on you not saying who was driving, choosing an option thsy says
       "I did ___" would be unwise. Just choose "Other", the text of
       your appeal lays out your reasons.
       #Post#: 113523--------------------------------------------------
       Re: EuroCar Parks PCN for three minute overstay
       By: Albamc Date: March 17, 2026, 9:02 am
       ---------------------------------------------------------
       Good point! And thank you. 👍
       Appeal submitted with last paragraph edited as follows:
       APPEAL POINT FOUR - That I believe that adequate time was
       purchased for the parking event which is causing this dispute -
       according to Just Park's own information entering the car park
       early is acceptable if the car is not actually parked in the
       space. So, the alleged overstay is in fact three minutes. Even
       considering a minimum grace period of ten minutes, the
       contractual dispute amounts to 1 minute - the operator's own
       evidence shows that the driver entered at 22.22 and left at
       19.33 the following day - the 'time on site' was 21 hours and 11
       minutes - 21 hours were paid for but 22 hours would have cost no
       more. Additionally, EuroCar Parks state in their correspondence
       that £12:80 was paid to JustPark when it was in fact £14.29.
       (Please see attached receipt.)
       _________
       Thank you all again and watch this space!
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