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PCN Eternity Fire and Security LTD Parking without clearly displaying a valid ticket. Mumbles Pier

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#16
Would this work as a Popla Appeal?

I am appealing this parking charge notice as the hirer and long-term lessee of the vehicle. The operator has failed to satisfy the strict statutory conditions required by the Protection of Freedoms Act 2012 (PoFA) Schedule 4 to transfer liability from the registered keeper to the hirer.Failure to Provide Mandatory Hirer Documentation:Under PoFA Schedule 4, Paragraph 14(2), a Notice to Hirer is only valid if it is accompanied by specific mandatory documents. Specifically, Paragraph 14(2)(a) and (b) require the operator to provide the hirer with a copy of the hire/lease agreement and a copy of the statement of liability signed by the hirer.The operator's Notice to Hirer consisted of a single piece of paper. None of these statutory documents were supplied. Because the operator has failed to comply with the mandatory provisions of Paragraph 14, they have no lawful right to transfer liability to me as the hirer.No Driver Identified:The operator has only established that the vehicle was present, but has not identified the driver. PoFA Schedule 4 does not place any legal obligation on a keeper or hirer to identify who was driving, and I am choosing not to confirm who was driving at the material time.Because the operator cannot establish hirer liability due to their non-compliance with Schedule 4, and the driver has not been identified, there is no legal basis upon which to hold me liable for this charge.As the operator has failed to meet the strict legal criteria to enforce this charge against a hirer, I respectfully request that POPLA directs the operator to cancel this Parking Charge Notice.