Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: Grant Urismo on June 22, 2024, 11:59:01 am

Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: H C Andersen on July 25, 2024, 07:15:11 pm
The creditor is a member of BPA's Approved Operator scheme.

IMO, Page 45, Appendix E of their Code of Practice (flowchart for Recovery of Unpaid Parking Charges) gives referring to 'Debt Recovery Process' a legitimacy and it is not for the keeper to demand of the creditor that this stage is omitted. I also believe that courts - which are already under strain - would not take kindly to a defendant who, being so sure of their case, shunned adjudication and mediation(which is another pre-court phase open to parties) simply to burden the courts, even less if they believed that this was simply a tactic adopted by a defendant who was not certain of their case but was using 'take me to court' as a tactic to bluff the creditor into dropping their claim.

https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/Version91.2.2024Highlight.pdf
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on July 25, 2024, 12:21:44 pm
Well it does have a bearing if you win at POPLA.

Obviously. However, an unsuccessful appeal has no bearing on any future action.

By all means, go ahead and appeal to POPLA. It's your time and energy and, as you point out, you may be successful. Please keep us unformed.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on July 25, 2024, 12:16:37 pm
In my personal view, it's usually worth a crack at POPLA. Even if simply to show you're well informed.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 25, 2024, 12:09:07 pm
DRA = Debt Recovery Agent or debt collector.

Thanks, I'm definitely starting to get more of a feel for things now.

Going through the appeals process is worthwhile in some instances with POPLA. However, not engaging in the appeals process will have no bearing on any claim.

Well it does have a bearing if you win at POPLA.

POPLA publish some interesting appeal statistics on their members. According to the most recent report from 2021 they received 2558 appeals against the operator in this case (Premier Park), of which 705 were not contested by the operator, 168 were successful and 1435 were refused. So about 1/3 of cases are won at POPLA against this operator.

I think there's a good chance that I can write a strong enough appeal for the operator to fold, because I think I can identify half a dozen points where they are not complying with the BPA code. The POPLA stats show they fold 27.5% of the time and lose another 6% of the time. I'll post the proposed appeal here once I've written it.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on July 23, 2024, 06:39:22 pm
DRA = Debt Recovery Agent or debt collector.

Going through the appeals process is worthwhile in some instances with POPLA. However, not engaging in the appeals process will have no bearing on any claim. Going straight to the claim process means that they should not pass your data to a third party DRA and they would simply send the keeper a Letter of Claim (LoC) as required by the PAP and you can respond or not to the LoC. Either way, they are going to issue a claim and again, it makes no difference to the court process.

There are several cases where the defendant has successfully counterclaimed against PPCs for GDPR data breaches and there are a few for distress and anxiety cause by harassment over on the MSE forum. It is not normally advised to counterclaim as it is often more complex and requires more effort and cost. However, there is nothing to stop you threatening it.

Not specific to PPC but relevant for GDPR breaches:

Quote
Article 12 of the UK GDPR legally requires data controllers to store and process personal data accurately: clearly, any data controller issuing an invoice to you because it has wrongly recorded that you parked in breach of the alleged contract between you and the landowner (or, as in this case, an agent of the landowner) is processing your personal data unlawfully.

The precedents for claiming damages and compensation for such unlawful processing are the decisions of the Court of Appeal in Zeta Jones & Douglas v Hello! Magazine [2003] EWHC 786 and Halliday v Creation Consumer Finance Ltd (CCF) [2013] EWCA Civ 333, both being binding on all County Courts in England and Wales.  In the latter claim, Mr Halliday was awarded compensation of £750 at what the Court regarded was the lowest level of award, and although this was a claim under Section 13 of the Data Protection Act 1998, similar provisions - amended to take account of a decision by the EU Grand Chamber that the 1998 Act did not properly implement EU law into UK domestic legislation - replaced the old Section 13 provisions with Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018.

In short, you ought to give 21 days notice (the pre-action protocol only really requires 14 days but hey, you can be charitable!) to the data controller of your intention to seek (say) £100 nominal damages and compensation under Article 12 of the UK GDPR and Section 168 of the Data Protection Act 2018 for their unlawful processing of your personal data: you could say that you will not file your claim with the County Court if they confirm in writing that all references to this alleged debt have been deleted within (say) 14 days. Clearly mark your letter as a "Letter before County Court proceedings".

Anyone who is fairly confident can claim as a litigant-in-person in Part 27 proceedings in the County Court (commonly but wrongly described as "the Small Claims Court").  Each party is responsible for their own legal costs whether they win or lose and the claim for £100 can be issued online for a fee of £35 at moneyclaimonline.gov.uk which also gives useful advice if you want to have a look at what is involved.  Your claim will automatically be listed as being for a total of £135, i.e. the successful party gets their Court fees back.

After long discussion over the weekend and today with a long serving district judge about this and the MSE forum and the roboclaimers, I was told to tell anyone who would listen:

What the defendants should strive to achieve, is to make life:
  As easy as possible for the Judge
  And as difficult as possible for the claimant

The result of which is a new "short" defence (single side of A4) and a draft order that the allocation judge can use, that is almost certainly going to lead to a discontinuation or a failure to fully comply with the order.

In the case your planned POPLA appeal, I predict that it will be unsuccessful because the operator issued the PCN correctly. I hope I'm proved wrong.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 23, 2024, 06:37:00 pm
Have you got a POPLA code? If so, don't engage with Premier any further and draft up a POPLA appeal.

Yes. I'm trying to understand more about how all this works in order to draft the best possible POPLA appeal.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on July 23, 2024, 06:25:43 pm
Have you got a POPLA code? If so, don't engage with Premier any further and draft up a POPLA appeal.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 23, 2024, 05:58:19 pm
To be honest, it is getting wearisome going through the futile motions of time wasting appeals. The best way to get this seen off is to tell them to stop faffing about and either cancel or go straight to a county court claim.

I'm inclined to agree, but I believe courts are very keen on parties exhausting dispute resolution processes before 'going legal', so I don't know how to 'go straight to a county court claim' without putting my friend at a disadvantage, and to be honest I think POPLA would have to be a complete kangaroo court not to accept any of the angles on this one.

They should not pass your details to any third party DRA otherwise they become liable for harassment under the Protection from Harassment Act 1997 and a breach of GDPR under the Data Protection Act 2018.

I'm sorry but I don't know what a "third party DRA" is, and it seems Google doesn't either.

Do you have any examples of claims under the Protection from Harassment Act 1997 and/or GDPR bing made successfully against private parking companies? The only way I can think of to do this would be to catch them in a data breach, I might float an idea on how to do this in the flame pit.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on July 23, 2024, 11:04:54 am
To be honest, it is getting wearisome going through the futile motions of time wasting appeals. The best way to get this seen off is to tell them to stop faffing about and either cancel or go straight to a county court claim. They should not pass your details to any third party DRA otherwise they become liable for harassment under the Protection from Harassment Act 1997 and a breach of GDPR under the Data Protection Act 2018.

If they are sure they have a case, they will issue a claim and it can be very easily defended. If they are unsure of their legal position, they can decide to drop the matter.

Either way, the only true arbiter of whether you owe a debt will be a judge. Knowing how poorly these claims are pleaded, it is almost certain that it would never get to a hearing and would likely be struck out.

There is a minuscule risk that it could go all the way to a hearing and you cold lose the claim. In the very worst case scenario, it would cost ~£200 in total with no risk of a CCJ on your credit record. With that in mind, you have to make the decision whether you are prepared to fight this all the way. We are here to help and advise with many years of experience in dealing with these matters.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 23, 2024, 10:47:03 am
What appeal did the keeper submit?

PP's response is clear that they inferred that the keeper was the driver. If this cat is out of the bag then PoFA is redundant. Also, they claim that the driver admitted to entering the 'incorrect vehicle registration'

On this occasion, as you have admitted you paid for the incorrect vehicle registration, we were unable to allocate your payment.


The appeal was very carefully worded to keep the distinction between keeper and driver intact, and there was no admission of the driver entering the incorrect vehicle registration. Their reply seems to us to be either deliberately misinterpreting the appeal, or a low-effort last ditch cut and paste trying to get £20 out of the keeper.

Here's what was sent, as per earlier in the thread:

=================

I am appealing  Parking Charge Notice number xxxxxxx, issued for "Whole Period Of Parking Not Paid for”, because the driver paid the parking charge in full, and retained the ticket that irrefutably proves this.

I attach a scan of the ticket, which proves that you accepted a payment of £1.50 and issued a ticket that allowed parking until 11:33 on the day in question. As your own evidence shows the driver left the car park well before this at 10:56, it is clear that no further payment is due.

I note that despite the driver entering the full VRM into your machine, the ticket you issued only shows it's first four characters, which may be why you have not correctly allocated the payment you accepted.

I look forward to receiving confirmation that you have cancelled this Parking Charge Notice.

You have requested that I supply the following information:

My Name is xxxxxxxxxx
My Address is xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
The Vehicle Registration Number is EX18xxx
The Parking Charge Reference is xxxxxxxx
I confirm that am the registered keeper of the vehicle, however I am under no legal obligation to identify the driver and will not be doing so.

=================

I find their phrase "we were unable to allocate your payment." interesting. Firstly it's in the past tense so I assume they have now allocated it. I know that for council PCNs they only get one go at getting the right contravention code, is this the case for private ones, or can they flip from "whole period of parking not paid" to 'keying error'?

Secondly, why would they be "unable" to allocate it from the first 4 characters? Did they make a reasonable effort to do so? It strikes me that allocating in this case ought to be trivial, especially given that the car park only has 30 spaces. If they have so many problems in that allocation isn't trivial then surely that implies a faulty keypad?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: H C Andersen on July 21, 2024, 04:20:18 pm
What appeal did the keeper submit?

PP's response is clear that they inferred that the keeper was the driver. If this cat is out of the bag then PoFA is redundant. Also, they claim that the driver admitted to entering the 'incorrect vehicle registration'

On this occasion, as you have admitted you paid for the incorrect vehicle registration, we were unable to allocate your payment.

Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on July 20, 2024, 10:47:38 pm
The alleged 'parking charge' is the £100 (or £20 if they're offering that) ParkingEye are demanding, not the tariff due on the day.

One of your arguments is instead that because the tariff was paid in full, the parking charges demanded are not due at all. If the driver owes nothing, then there's nothing to transfer using PoFA anyway as per 1(a).

(That's not to say that you don't raise other PoFA issues in your POPLA appeal of course as additional reasons nothing is owed)
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 20, 2024, 10:31:51 pm
Thanks, everyone. We're still working out what to do but I think my friend will put up a fight!

It all depends on how aggrieved your friend feels about being scammed. If your friend is sure they entered the full VRM and wants to fight this, then they should. If they feel that paying £20 to the scammers is worth not having to contest and fight it, then so be it.

The NtK does not mention anything about an incorrect VRM. It simply states that the whole period of parking was not paid for. There is evidence to show that it was.

It may or may not be upheld at POPLA. However, should it ever proceed all the way to a county court claim, It is highly likely that a judge would see that the defendant can show that they did pay for the whole period.

I've dug into the legislation (being a dilligent sort) and it seems to me that because the fee was paid in full, there's no legal mechanism for transferring liability for a keying issue from the diver to the keeper. Schedule 4 of the Protection of Freedoms Act 2012 starts:

SCHEDULE 4
Recovery of unpaid parking charges
Introductory
1(1)This Schedule applies where—
(a)the driver of a vehicle is required by virtue of a relevant obligation to pay parking charges in respect of the parking of the vehicle on relevant land; and
(b)those charges have not been paid in full.


So because 1(1)(b) is not satisfied the rest of Schedule 4 does not apply. Surely the keeper cannot therefore be held liable? Or is there another piece of legislation that would apply?

What do the signs with the terms say? Can we see some pictures of them?

Unfortunately this happened while the driver was on holiday, going back hundreds of miles to take photos isn't realistic.

...There is also CRA 2015 issues with this too.

If you could tell us what those issues are, it would be greatly appreciated!
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: slapdash on July 19, 2024, 07:19:44 am
Small keypads are notoriously bad devices due to the way they work.

Many problems with damp and debris can occur which can result in keys being missed. In any event they don't fail gracefully generally.

I don't doubt that the correct number of keys were pressed. (In any event what sensible adult would knowingly enter a partial, they may miskey of course).

The problem is that the operator will assert "it's all ok because only this one was wrong". That does become difficult to rebut.

Did the machine have a screen and what did it show, how was the transaction confirmed.

Many UIs on these sorts of payment devices are extremely poor and error prone, often registrations are not shown and there is "no way back" either.

However, should the victim want to go all they way, and they win it will cost them time, travel oats, day off for court.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on July 18, 2024, 01:25:48 pm
As above, really. Bear in mind that if this were to go 'all the way' and court was on the cards, it would be your friend who would be required to attend. Whether they are up for the fight is their call to make, not yours.

Quote
1) Is there a way to pay £20 and still contest this?
No - if payment is made, the matter is essentially closed.

Quote
2) What are the chances of winning at POPLA?
Hard to predict. Challenging this will involve a certain element of rolling the dice. There are a few possible reasons as to why only a partial VRM was registered, but the most likely ones that spring to mind are:

If going to POPLA, your friend could challenge the operator to produce a copy of the payment logs for that day. If explanation #1 is right, the logs will show this, and would strongly suggest a system issue, as it would be less likely that every/several users made identical inputting errors in a short period of time. If #2 is right, this might be more tricky, as the logs wouldn't provide much/any evidence of system failure, so it would essentially be your friend's word against Premier Park's, as far as POPLA goes.

As b789 notes, their original allegation was not that an error was made, but that the whole period of parking was not paid for, when it actually was, although they could clarify their position by the time they made a court claim if going that far. I'm not aware of any cases where defendants have rejected the £20 'major keying error' offer to refer you to for reading, others may be.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on July 18, 2024, 12:58:29 pm
It all depends on how aggrieved your friend feels about being scammed. If your friend is sure they entered the full VRM and wants to fight this, then they should. If they feel that paying £20 to the scammers is worth not having to contest and fight it, then so be it.

The NtK does not mention anything about an incorrect VRM. It simply states that the whole period of parking was not paid for. There is evidence to show that it was.

It may or may not be upheld at POPLA. However, should it ever proceed all the way to a county court claim, It is highly likely that a judge would see that the defendant can show that they did pay for the whole period.

What do the signs with the terms say? Can we see some pictures of them?

Your friend will put PP to strict proof that the driver did not pay for the full period. This will include payment logs that show any other vehicle with the same initial 4 characters was at the car park at that time and also paid.

There is also CRA 2015 issues with this too.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on July 18, 2024, 12:45:24 pm
My friend has now received an interesting response (by email, which is why this isn't a scan):

===============================

PCN REFERENCE NUMBER: xxxxxx
POPLA CODE: xxxxxx
DATE OF PARKING EVENT: 14th June 2024
PAYMENT DUE DATE: 31st July 2024
TOTAL AMOUNT DUE: £20.00
 
Dear xxxxxxxxx,

Thank you for your appeal against the above Parking Charge Notice (PCN). We have carefully considered your appeal, however on this occasion the appeal has been rejected for the following reason;

As you have admitted payment was made for "EX18" instead of the vehicle parked "EX18xxx." Whilst we note your comments, we must advise that the signage clearly states, "Enter your full registration number." As this car park is monitored by Automatic Number Plate Recognition (ANPR) cameras which capture time and date stamped images on entry and exit, it is imperative that you make payment for the full vehicle registration to ensure we can match your payment to the vehicle parked. On this occasion, as you have admitted you paid for the incorrect vehicle registration, we were unable to allocate your payment. Therefore, we can confirm that this PCN has been issued correctly.

We are on this occasion prepared to accept the reduced amount shown above, this is to ensure we comply with section 17.4 Keying Errors of the British Parking Association (BPA) Code of Practice. Please note this offer is without prejudice save as to costs.

Please be advised that the terms and conditions advise that the full registration number must be entered on each occasion and/or the correct location paid for.

We can confirm that any further PCNs issued to you for this reason will not be reduced and this is a one-off offer.

You have now reached the end of our internal appeals procedure and therefore you now have two options; you can either pay or appeal to POPLA - you cannot do both:

You can pay the total amount due as shown above via the following payment options;

Call us on: 01302 513232
Pay online: www.pcnpayments.com
Send a postal order: Premier Park Ltd, PO Box 624, Exeter, EX1 9JG
 
Or, you can appeal to an Independent Appeals Service, POPLA (Parking on Private Land Appeals) using the POPLA reference code provided above. Please note, should you decide to appeal to POPLA and your appeal is subsequently rejected or you withdraw your appeal, the option to pay a discounted amount will no longer be available and the full amount of the PCN will become due. Please note, if you pay the PCN prior to appealing to POPLA, your appeal will be withdrawn as you will have accepted liability in full.

If you decide to appeal to POPLA, you will need to visit their website, www.popla.co.uk where further details of how to appeal (either online or by downloading the relevant forms) can be found. If you are unable to access their website, please call us for further information on how to obtain the forms. Please ensure your POPLA Reference Number, as noted above, is quoted on all correspondence to POPLA. You have 28 days from the date of this email to submit an appeal to POPLA. If you appeal to POPLA we will suspend recovery activity on the PCN and the charge will not increase until the appeal has been determined.

By law we are also required to inform you that Ombudsman Services (www.ombudsman-services.org) provides an alternative dispute resolution service that would be competent to deal with your appeal. However, we have not chosen to participate in their alternative dispute resolution service. As such should you wish to appeal then you must do so to POPLA, as explained above.

If you do not make payment or submit an appeal to POPLA within the relevant timeframe, the outstanding PCN may be passed to our appointed debt collection agency for further action. All costs associated with this process will be added to the amount outstanding.


===============================

So, it's down from £100 to £20. My friend is keen to pay up to make this go away fairly cheaply, but I'm not so sure, mainly because they are claiming that "you have admitted payment was made for "EX18" instead of the vehicle parked "EX18xxx." when no such admission was made, the appeal actually stated "I note that despite the driver entering the full VRM into your machine, the ticket you issued only shows it's first four characters".

So, I have some questions:

1) Is there a way to pay £20 and still contest this?

2) What are the chances of winning at POPLA?

3) Are there any other lies in their response (it seems absurd that they legally have to mention the ombudsman can't help, for example)?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on July 01, 2024, 12:29:06 pm
Whether or not you choose to be more courteous is your decision and a matter of personal style - I sometimes take a less blunt approach to my suggested appeals than b789 does, for example. This isn't necessarily better or worse, just a matter of personal approaches. What is important however, is that whatever style you go for, the points you make are the correct ones, and are not watered down by a desire not to be direct.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on July 01, 2024, 12:23:30 pm
No one is forcing you to do anything. Feel free to try it your way. If you think that a more courteous approach to the PPC will make them see sense and cancel the PCN, I’ll gladly eat humble pie.

As for the technical flaw in the NtK, I explained it already:

Quote
Upon closer review of the NtK I see that it does not contain an "invitation" (nor any synonym of the word) for the keeper to pay the charge. PoFA paragraph 9(2)(e)(i) states that the notice must contain an invitation for the keeper to pay the charge. If Premier Park want the ability to be able to transfer the liability for the charge from the unknown driver to the known keeper, they must fully comply with the requirements of PoFA. Partial or even substantial compliance is not enough.

It will not get the PPC to cancel it but it may get POPLA to do so, or a judge. If you need more detail, feel free to have a read of PoFA here:

https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: slapdash on July 01, 2024, 07:54:23 am
You are possibly making an error of judgement.

Do not confuse the parking company with any form of normal rational reasonable commercial enterprise.

The only entity that can force them to desist is the landowner. An issue that can occur is the contact between the landowner and the PPC will have some limiting terms around cancellation (usually).

These will sometimes depend on what work (and thus cost) the PPC has incurred to date.

By engaging with the PPC at this point there some chance you could prejudice landowners ability to instruct cancellation under the terms of their contract.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 30, 2024, 09:01:12 pm
Absolutely not! You always pursue Plan A first.

What benefit is there to doing this first, and what problems would it cause to do it in parallel?

Use the wording I gave you for the appeal. It is 99% likely to be rejected no matter what you put. However, you will have a record of steps taken should this ever progress all the way to a court claim.

I'm sorry, but you've suggested an incredibly aggressive approach, I will have extreme difficulty getting my friend to say "There are technical flaws in your NtK that mean that you have failed to fully comply with all the requirements of PoFA. If you are unable to understand what those flaws are, I am more than happy to identify them to the court should you be inclined to take this matter before the only truly independent arbiter, a judge." without myself having a clear understanding of what those flaws are, and as much confidence as you have. Given that you are 99% sure it won't make any difference, I see no harm in being more polite at this stage.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 30, 2024, 08:43:56 pm
Absolutely not! You always pursue Plan A first. You email Savills with a complaint along these lines about how their agent has issued a PCN even though the driver paid for parking as can be proved. Because their payment machine is defective, the driver who was a patron of the businesses at the location should not be penalised by an unregulated private parking company contracted by them.

If they do not get their agent to cancel the PCN you, your family and friends will let all the businesses know that they will be losing patronage in future as none of you will be prepared to risk receiving a speculative invoice for £100 each time you visit the location.

Use the wording I gave you for the appeal. It is 99% likely to be rejected no matter what you put. However, you will have a record of steps taken should this ever progress all the way to a court claim.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 30, 2024, 08:32:11 pm
Thanks, I had no idea how to find that out, so that's really useful. I think the approach my friend will take is to send a firm but fair appeal that doesn't identify the driver but does clue them in that we know our stuff, and if they continue to  pursue this then approach Savills with a polite but firm 'you're going to be jointly and severally liable for my legal costs if you don't back down now I've proved the fee was paid and you have no actionable loss'.

Here's what I'll get the keeper to send, unless anyone has a good reason to change it:

--------------

I am appealing  Parking Charge Notice number xxxxxxx, issued for "Whole Period Of Parking Not Paid for”, because the driver paid the parking charge in full, and retained the ticket that irrefutably proves this.

I attach a scan of the ticket, which proves that you accepted a payment of £1.50 and issued a ticket that allowed parking until 11:33 on the day in question. As your own evidence shows the driver left the car park well before this at 10:56, it is clear that no further payment is due.

I note that despite the driver entering the full VRM into your machine, the ticket you issued only shows it's first four characters, which may be why you have not correctly allocated the payment you accepted.

I look forward to receiving confirmation that you have cancelled this Parking Charge Notice.

You have requested that I supply the following information:

My Name is xxxxxxxxxx
My Address is xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
The Vehicle Registration Number is EX18xxx
The Parking Charge Reference is 7720289
I confirm that am the registered keeper of the vehicle, however I am under no legal obligation to identify the driver and will not be doing so.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 30, 2024, 07:53:17 pm
If the managing agent is Savills, they are generally amenable to tell their agent to cancel the PCN. The OP should actively pursue this plan and contact Savills.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Thequickbrownfox on June 30, 2024, 07:43:51 pm
The car park is not owned by Premier Park. They are contracted by whoever owns the car park or their managing agents.  Whoever contracted Premier Park is jointly and severally liable for the actions of their agents. They can tell their agent, Premier Park to cancel the PCN.

Plan A is always find out who owns/manages the land and get them to order their agent cancel it. It is by far the least difficult way to get a PCN cancelled.
Found this which may help - https://search.savills.com/property-detail/gb0457s200121 (https://search.savills.com/property-detail/gb0457s200121)



Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 27, 2024, 06:02:39 pm
The car park is not owned by Premier Park. They are contracted by whoever owns the car park or their managing agents.  Whoever contracted Premier Park is jointly and severally liable for the actions of their agents. They can tell their agent, Premier Park to cancel the PCN.

Plan A is always find out who owns/manages the land and get them to order their agent cancel it. It is by far the least difficult way to get a PCN cancelled.

Upon closer review of the NtK I see that it does not contain an "invitation" (nor any synonym of the word) for the keeper to pay the charge. PoFA paragraph 9(2)(e)(i) states that the notice must contain an invitation for the keeper to pay the charge. If Premier Park want the ability to be able to transfer the liability for the charge from the unknown driver to the known keeper, they must fully comply with the requirements of PoFA. Partial or even substantial compliance is not enough.

This is a technicality but should still be chased. Hence, any appeal should be as the known keeper, not the unknown driver.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 27, 2024, 05:44:53 pm
Did the keeper ever find out who the landowner or their managing agents were and request that they get their agent to cancel the PCN?

No, I have absolutely no idea how to go about this, or that this should be done at all.


...If you are unable to understand what those flaws are, I am more than happy to identify them to the court should you be inclined to take this matter before the only truly independent arbiter, a judge...

Well that's certainly a different approach to what's been discussed so far. I really don't feel confident advising my friend to send that without at the very least being able to understand myself what these flaws are. Could you be a little more explicit about this?

Also, in post 2 you say "The PCN, is as far as I can discern, PoFA compliant so any appeal may as well be as either the keeper or the driver.", but now you're saying it needs to be the keeper saying "I am the registered keeper of the vehicle. I am under no legal obligation to identify the driver and will not be doing so." Could you help me understand this? I'm advising a friend here, so I really want to be sure I understand the advice I'm giving.

I'm sorry if I'm coming across as dim, or ungrateful for the time you're putting into helping with this, but at the moment not much of this is making sense to me.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 27, 2024, 05:27:59 pm
Did the keeper ever find out who the landowner or their managing agents were and request that they get their agent to cancel the PCN?

Just do a simple appeal as the keeper. Premier Park are a nasty little vexatious bunch of ex-clamper thugs who are unlikely to accept any appeal.

The keeper just needs to go through the motions of appealing at this stage to  be able to get a POPLA code.

An appeal as the keeper along these lines is advisable:

There are technical flaws in your NtK that mean that you have failed to fully comply with all the requirements of PoFA. If you are unable to understand what those flaws are, I am more than happy to identify them to the court should you be inclined to take this matter before the only truly independent arbiter, a judge.

I am the registered keeper of the vehicle. I am under no legal obligation to identify the driver and will not be doing so.

You have issued a PCN alleging that the driver did not pay for the whole period of parking. Attached is a copy of the receipt/ticket issued for the period of parking. The evidence is irrefutable that the driver did pay. Your payment machine did not print the full VRM of the vehicle even thought driver did input it at the time.

I suggest you go through the payment logs and ANPR photos for that location on the relevant date and prove that there was some other vehicle with the VRM that your payment machine erroneously printed on the receipt that the driver received. Unless you can prove otherwise, payment was made for the full duration and I suggest you cancel the PCN.

Show us what you intend to send before you do so.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 27, 2024, 05:02:43 pm
Understood, that's very helpful, and I can start working on that in expectation of a rejection, but this isn't at the POPLA stage yet. My priority at the moment is be sure I'm giving the right advice for an initial appeal.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 27, 2024, 04:48:42 pm
For a POPLA appeal, you need to raise as many points as possible. The operator must successfully rebut each point. You only have to win on a single point.

Make a list of all the points you intent to challenge the validity of the PCN. Obviously you are challenging on the fact that you paid for the duration and have a receipt. However, they are going to challenge that the receipt does not bear the correct VRM and so could be for any vehicle. Was there any mention about inputting the correct VRM as part of the terms on the signs?

You need to also challenge the operator that the signs were fully compliant with the BPA Code of Practice (CoP). Were they prominent? Were they legible and written in Palin language. Was the charge for breaching any terms adequately brought to the attention of the driver as required by PoFA and the BPA CoP?

Is the contract that flows from the landowner to the operator valid? A statement that it is, is not acceptable and you should put the operator to strict proof that the contract exists, is valid and permits the operator to issue PCNs in their own name.

Put a list of the points and then expand on each point arguing your case.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on June 27, 2024, 04:31:12 pm
They also say I have to include VRN, full name, serviceable address, etc - is this necessary (they already have all this on the notice) or perhaps harmful as it confirms things?
If it's all information already in their possession* there can be little harm caused in confirming it.

*without you confirming it, they have no way of knowing that the person they wrote to is the person submitting the appeal - for all they know, the addressee could have given the notice to someone else.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 27, 2024, 04:25:05 pm
Ok, here's what I plan to get them to send, unless anyone has a good reason why I shouldn't...

--------

I was surprised to receive Parking Charge Notice nnnnnnnnnnn from you stating that I owe you money for "Whole Period Of Perking Not Paid for", as the whole of this parking period was paid for and I have retained the ticket issued at the time which proves this.

I attach a scan of the ticket your machine issued which shows that I paid £1.50 at 09:33 on the 14th June. As the vehicle left the car park at 10:56 (as your letter states) but the ticket you issued covered parking until 11:33, no further payment is due.

I look forward to receiving confirmation that you have cancelled this Parking Charge Notice.

------

They also say I have to include VRN, full name, serviceable address, etc - is this necessary (they already have all this on the notice) or perhaps harmful as it confirms things?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 26, 2024, 11:21:44 pm
Is the 'this has been paid so there's no loss, so it's de minimis 'angle worth mentioning in the initial response to the PCN, or is it something to bring up at the POPLA stage?
You can put whatever you want in the initial appeal, it will almost certainly be rejected. No money in it for them if they accept appeals.

Perhaps best not to reveal all your cards at this stage. Better to use those at POPLA although you must remember that they are not truly independent as their paymasters are the parking companies themselves.

The de minimis argument is unlikely to succeed at POIPKA either but I don't think has been tried and the judgment shown is only ver recent. It does no harm trying. You must make as many points as possible for your POPLA appeal. The operator must rebut every point. The operator failing to fully rebut even a single point is a win for you.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: slapdash on June 26, 2024, 11:01:01 pm
I note that despite me entering my full registration twice into your machine

That's a curiosity and suggests some sort of issue.

I don't know how the machine in question operates of course but what made the user think "something's wrong" and somehow enter it again.

It also gives a small piece of ammunition for the refusal. "Well if you knew it was wrong why didn't you ring up".

Some caution in phrasing may be appropriate.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 26, 2024, 10:55:47 pm
Is the 'this has been paid so there's no loss, so it's de minimis 'angle worth mentioning in the initial response to the PCN, or is it something to bring up at the POPLA stage?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on June 26, 2024, 10:29:43 pm
Just making sure the OP doesn't blindly cut and paste and suggest the claimant here is the same.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 26, 2024, 10:27:39 pm
Yes, the Operator in the above claim was Excel. The wording shown above was from a defence for a similar case to this where Excel issued a claim for the same reasons, minor keying error. Hence "the same Claimant" comment.

My suggestion was that this argument should be made with POPLA at this stage as it shows how ridiculous it is for them to be demanding £100 even though they were paid for the parking anyway. You never know!

At least if it does go as far as a claim, it is an extra arrow to have in the quiver.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on June 26, 2024, 10:09:08 pm
which involves the same Claimant
The claimant here is different, is it not?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 26, 2024, 09:28:02 pm
Premier Park are vexatious little pieces of excrement and would not entertain acceptance of any form of appeal. So, no surprises there.

POPLA will simply side with their paymasters and say that the PCN was issued correctly because the VRM is not correct, irrespective of whether the appellant entered it correctly or not.

there was a very recent claim that went to a hearing over the almost exact reason. The judge threw out the claim as it was de minimis. The claimant had received payment, the defendant proved that. The claimant tried to appeal but was refused leave to do so. It may be useful for the appellant to show this to POPLA but would need to handhold the assessor through the reasoning of de minimis.

No legitimate interest (the ParkingEye v Beavis case is fully distinguished)

6.  There is no legitimate interest in pursuing a Defendant who paid in full, and this Claimant knows this full well. Last week in a judgment dated 10th June 2024, His Honour Judge Pema (sitting at the County Court at Bradford) refused Excel Parking Services Ltd's attempt to appeal the decision in Case no K4QZ4Y21 which the Defendant had won in similar circumstances to the extant claim, which involves the same Claimant:

(https://i.imgur.com/Mhmrbcz.jpeg)
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 26, 2024, 08:34:03 pm
How about sending...

-------------------
I was surprised to receive a Parking Charge Notice from you stating that I owe you money for "Whole Period Of Perking Not Paid for", as the whole of this parking period was paid for and I have retained the ticket issued at the time which proves this.

I attach a scan of the ticket your machine issued which shows that £1.50 was paid at 09:33 on the 14th June. As the vehicle left the car park at 10:56 (as your letter states) but the ticket covered parking until 11:33, no further payment is due.

I note that despite me entering my full registration twice into your machine, the ticket I was issued only shows the first part of my numberplate, which may be why you have not correctly allocated the payment you accepted.

I look forward to receiving confirmation that you have cancelled this Parking Charge Notice.
-------------------

...and then come back here if that doesn't get the job done?

I'm familiar with the Council PCN process from Pepipoo and here, but I don't really know my way around the private parking side - am I right in thinking the 'only one bite of the cherry' rule that prevents councils changing their mind about the reason for a PCN doesn't apply here, and that this might have to go to POPLA instead of the adjudicators, who might not be as persuadable in their interpretation of the rules?
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: DWMB2 on June 22, 2024, 09:30:28 pm
Any initial appeal should raise the point about the issues entering the VRM.

If this was a recurrent issue, it should be reflected in the VRM logs for that day, although you're unlikely to be able to get hold of those easily (they may produce them at some stage to 'prove' that the correct VRM wasn't entered)
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 22, 2024, 08:45:13 pm
What arrangements are there for entry of the VRM ?

Thanks for replying (and that goes for b789 too). The driver tells me they had 2 tries at typing the whole VRM, but only the first 4 characters were accepted by the machine.

Is EX18 on the ticket the start of the VRM that was entered.

Yes

Is the VRM on the PCN correct (possible misread).

Yes

Quite likely, in terms of reason for issues, there is a mismatch between the entry on the payment machine and the camera picture. Either through user error or machine error.

A keying error should see a reduction to £20 (I am not saying you should avail of that, merely that it is an option).

There are likely other defences to the validity of the charge which others will mention.

Thanks, the driver will hold off on doing anything until a consensus is reached here. A reduction to £20 isn't something they would be happy with, considering they paid in full.

GSV isn't much help with the signage, unfortunately: https://www.google.com/maps/@51.1076364,-4.1604457,3a,19.4y,182.52h,87.65t/data=!3m6!1e1!3m4!1sbkYFPmMgjXyl4zast4B8aw!2e0!7i13312!8i6656?coh=205409&entry=ttu
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: b789 on June 22, 2024, 02:07:06 pm
As above, we need to know whether the “EX18” on the ticket refers to part of the vehicles VRM. Whether it is or isn’t , doesn’t alter the fact that the driver has a receipt showing that they paid for the duration of the stay.

Once the question has been answered, we can move forward with this. In any case, the driver should not pay a penny to these ex-clamper thugs. The PCN, is as far as I can discern, PoFA compliant so any appeal may as well be as either the keeper or the driver.
Title: Re: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: slapdash on June 22, 2024, 01:50:08 pm
What arrangements are there for entry of the VRM ?

Is EX18 on the ticket the start of the VRM that was entered.

Is the VRM on the PCN correct (possible misread).

Quite likely, in terms of reason for issues, there is a mismatch between the entry on the payment machine and the camera picture. Either through user error or machine error.

A keying error should see a reduction to £20 (I am not saying you should avail of that, merely that it is an option).

There are likely other defences to the validity of the charge which others will mention.
Title: Premier Park PCN - Not Paid (but can prove they did pay) - Exeter Road Car Park, Braunton
Post by: Grant Urismo on June 22, 2024, 11:59:01 am
Posting for a friend, I'm neither the driver or keeper for this PCN.


The diver diligently parked in a public car park, paid for their parking, displayed the ticket it in their windscreen and left before the paid for time expired. They are therefore somewhat unhappy  to have received a demand for £100 for "Whole Period of Parking Not Paid", and relieved that their habit of always keeping tickets to prove they paid appears to have been vindicated.


I've scanned the letter (both sides) as well as the ticket (on the second scan), covered up things I think are identifying (happy to unredact if I've overdone this).


No appeal has been made yet, this is not a hire car and the driver's diligence extends to keeping their V5C up to date. Pictures of the signage are not available as this was a holiday to a place hundreds of miles away.


(https://i.imgur.com/M5Ot4am.jpeg)

(https://i.imgur.com/44UrefP.jpeg)