Non-Compliance with Section 9(2)(a): PoFA 9(2)(a) requires that the NtK
must specify the “relevant land” on which the vehicle was parked. In your notice, the location is simply listed as "Lidl, Ashford". This description is insufficient to meet the statutory requirement, as pointed out in my appeal, there are two different towns named Ashford, each with its own Lidl store. The failure to specify the exact location creates ambiguity, which means the NtK does not comply with PoFA 9(2)(a).
Non-Compliance with Section 9(2)(e)(i): PoFA 9(2)(e)(i) requires that the NtK explicitly
invites the keeper to pay the parking charge if they were not the driver. The wording in your letter, however, does not contain any such invitation. Instead, it states:
“You have already been notified that under section 9(2)(b) of Schedule 4 of the Protection of Freedoms Act 2012 that the driver of the motor vehicle is required to pay this parking charge in full. As we do not know the driver’s name or current postal address, if you were not the driver at the time, you should tell us the full name and the current postal address of the driver.
You are warned that if, after 29 days from the Date of Issue, the parking charge has not been paid in full and we do not know both the name and current address of the driver, we have the right to recover any unpaid part of the parking charge from you, the registered keeper.”
As with the original NtK, this wording does not contain any
invitation for the keeper to pay the charge if they were not the driver. Nor does it impose an obligation on the keeper to pay. Instead, it merely warns that, if the charge remains unpaid after 29 days and ParkingEye does not have the name and address of the driver, you may seek to recover the charge from the keeper. This language is insufficient to meet the statutory requirement, which mandates a clear and unambiguous invitation to the keeper to pay the charge if they were not the driver. By omitting this specific invitation, your NtK fails to comply with PoFA 9(2)(e)(i).
Warning under Section 9(2)(f): The warning you provided under section 9(2)(f) is only valid if
all conditions of PoFA are met. Since your NtK does not comply with sections 9(2)(a) and 9(2)(e)(i), this warning does not have effect, as keeper liability cannot be established.