In general, a POPLA appeal expands on the grounds you outlined in your initial appeal, albeit in more detail. The general advice is to assume no prior knowledge on the part of the POPLA assessor, and walk them through each of your points clearly and in detail, leaving as little room for misinterpretation/disagreement as possible.
A couple of them would benefit from another look/clarification:
- Failed to provide the required period of parking 9 (2) (a)
The notice you've uploaded does seem to specify a period of parking
- Failed to provide the Landowner Authority Contract between Private Parking Solutions (London) LTD and the landowner
There's no obligation for them to at the point they issue the original PCN, although you can put them to proof at POPLA.
(d). As this is a dock area, this location is covered by bylaws, whereby only the driver is liable. You cannot, therefore, transfer liability for the alleged charge from the driver at the time to me, the registered keeper.
If you haven't already, be sure to check the byelaws to make sure the area where the car was parked is indeed within the area covered by the byelaws. Assuming it is, you may wish to include a copy of the boundary map to demonstrate this point to the assessor. Page 30 would appear to contain a map of the boundaries covered by the byelaws: https://londonsroyaldocks.com/wp-content/uploads/2021/09/Bye_laws_London_Docklands.pdf (https://londonsroyaldocks.com/wp-content/uploads/2021/09/Bye_laws_London_Docklands.pdf)
(e). PPS has failed to provide the required signs to designate this as a 'red route'. Furthermore, on the photographs you provide in your PCN, there are no distinguishable 'red route lines' at this location.
The allegation from PPS is that the driver exceeded the maximum stay period, it doesn't seem to mention anything about a red route?
(f). It is clear from your photographs that this alleged contravention occurred on a dark, wet night. Hence both road markings and parking signage would have been extremely difficult to see - as your camera evidence (un)clearly shows.
The notice suggests the vehicle was parked between 16:52 and 17:23 on 10th March - sunset in London on that day was at around 6pm, so I'm not sure you can accurately say that it was a "dark night" when the vehicle was parked. The photos appear to show the vehicle parked directly underneath a sign detailing the terms and conditions. If you intend to argue poor signage/markings, you'll need to get your own photos to back this up.
(g). The signage in the car park is of a “forbidding” nature. It is limited to vehicles displaying a valid permit only and therefore the terms cannot apply to vehicles without a permit because the signage does not offer an invitation to park on certain terms.
POPLA won't go for this point, but if the signage is forbidding you can still include this. However, in their rejection, PPS say their signs state:
FREE SHORT STAY PARKING
MAX STAY 20 MINUTES, NO RETURN WITHIN 2 HOURS
That doesn't make any mention of permits? If the signage has different wording to what they claim, you should get some photos to demonstrate this.