Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: Chaseman on August 10, 2023, 06:06:52 pm

Title: Re: Private PCN St Michael's Court
Post by: Chaseman on February 05, 2024, 11:32:06 am
Fair enough, as I often say, it's your money at stake, so your call to make.

In the interests of clarity, my goal isn't to influence a particular course of action over another, just to point out both the options for success, and conversely any potential risks involved, so that people can make an informed decision on that basis.

In which you have been fair and balanced.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on February 05, 2024, 10:35:38 am
Fair enough, as I often say, it's your money at stake, so your call to make.

In the interests of clarity, my goal isn't to influence a particular course of action over another, just to point out both the options for success, and conversely any potential risks involved, so that people can make an informed decision on that basis.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on February 04, 2024, 01:22:25 pm
I should perhaps have said "go to court" rather than "take to court". I was partly influenced by earlier posts that referred to PE's litigious nature and thought that having had my appeal to POPLA effectively turned down twice (although PE likely not aware of the second) that they were likely to pursue all the way and thought not worth risking £220 as per DWMB on 12 Jan. I will know another time to look out for correspondence from DKB legal.
Title: Re: Private PCN St Michael's Court
Post by: Nosy Parker on February 04, 2024, 12:58:57 pm
I have paid PE as it seemed too much hassle to take to court for the amount involved.

Well you are free to donate to any cause you consider worthy of your charitable good nature - but Parkingeye doesn't strike me as a worth cause - especially as it would not be you taking it to court.  You didn't need to do anything. Parkingeye would have been the one that needed to take it to court ...
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on February 04, 2024, 12:37:24 pm
It sounds to me as though if Amy Smith had been considering my case I might well have succeeded. She only had to consider two Lidls in St Neots with the PCN not making clear which it was whereas the adjudicator in my case concluded that St Michaels Court was an adequate identification of relevant land despite no street, no town, no postcode and the fact that I had found 9 St Michael's courts in England.

In the response to my complaint about the way the assessor reached her decision Ms Bethany Young said:

Quote
Whilst I note your point regarding nine other St Michael’s Court car parks being in the country, the driver would know which St Michael’s Court they used on the day - at the time in question. Hence, the parking operator gives you, as the registered keeper, the opportunity to provide the driver’s details to transfer liability to them.

Effectively saying "you could ask the driver which car park they used on the day" which would seem to completely undermine the POFA requirement for strict compliance with Schedule 4 para 9. Assessor bingo as you say.

I have paid PE as it seemed too much hassle to take to court for the amount involved. I was not aware of the DCB Legal angle at the time I paid but will be better informed next time.
Title: Re: Private PCN St Michael's Court
Post by: b789 on January 30, 2024, 03:25:49 am
I've just been through this thread and it is a classic example of how wrong POPLA can get it sometimes. Assessor bingo is certainly an apt description. In this case you probably got the "tea-boy' filling in on that day.

As noted, POPLA will never reverse a decision even when it admits to the assessors being wrong. Luckily, the assessors decision is not binding. The only way you get justice is to let a judge decide whether you owe a debt to PE.

Interestingly, just today, Monday 29th January 2024 (I'm currently 6 hours west of you in the UK so still Monday) I received a successful POPLA appeal decision for a very similar case involving PE!

Before I show you the details of the POPLA decision and how I went about appealing it, you should be aware that if PE think they're on shaky ground pursuing this case, after all the reminders, they will assign it to a debt collector/robo-claim solicitor, usually DCB Legal. This is a clear sign that they have little faith that this would stand up in court and so rely on the scam tactic of trying to scare the victim into paying up with a dodgy claim.

As I have pointed out elsewhere on this forum earlier today, if DCB Legal are involved, as long as a robust defence is submitted, there is a 99/9% likelihood that they will discontinue before any hearing.

The OP needs to wait and see if PE make their own claim or whether they pass it on to DCB Legal. Also, recently, PE have begun adding £20 on top of the £100 charge when they file their own claims which is a "bonus" in the sense that it weakens their claim by increasing the original charge beyond what is stated in their terms.

Now, here is the case that I helped a friend overturn a PE PCN (NtK) that did not clearly identify the relevant land.

The vehicle was parked in a Lidl car park in St Neots whilst the driver and passengers went to a nearby restaurant, not realising that out of store hours, there was only an invitation to park if £100 was paid. The NtK stated the location as "Lidl, St Neots". Nothing else about the location. No street name. No post code.

Upon doing a Google Maps search for "Lidl, St Neots" two separate Lidl's were shown. One was "Lidl, Cedar House, Cambridge St, Saint Neots PE19 1JL" and there other was "Lidl, 29 Great N Rd, Eaton Socon, Saint Neots PE19 8EN". Ambiguous, yes?

This was pointed out in the initial appeal to PE whilst pointing out that this was a breach of PoFA by not clearly identifying the "relevant land" but they refused the appeal without addressing the issue. A POPLA code was issued and the following was the POPLA appeal filed (PDF):

https://www.dropbox.com/scl/fi/f7kkc340y7p22p7my0vir/POPLAappeal-copy.pdf?rlkey=v7c6aqqevtl4mm34t2jpar937&dl=0

It is important to point out that in a POPLA appeal, you should make as many appeal points as possible, even if they seem far fetched. The operator must rebut every point. Failure to rebut a single point will mean that the appellant will be successful with the appeal.

PE submitted their own "operators response", again, failing to address the core issue of the failure to comply with the PoFA "relevant land" issue. The rebuttal again highlighted the operators lack of response to the core issue about "relevant land" which meant that the NtK was not PoFA compliant and so the keeper could not be held liable for the charge.

Here's the successful POPLA response received earlier today:

Operator Name

Parking Eye Ltd including Car Parking Partnership (CPP) - EW

Operator Case Summary

OP Case Summary

Decision

Successful

Assessor Name

Amy Smith

Assessor summary of operator case

The operator issued the Parking Charge Notice (PCN) for remaining at the site for longer than the stay authorised or without authorisation.

Assessor summary of your case

The appellant has raised the following points from their grounds of appeal:


After reviewing the operator’s evidence, the appellant reiterates their grounds of appeal. The appellant has provided evidence of the signs at both sites and the PCN as evidence to support their appeal. This evidence will be considered in making our determination.

Assessor supporting rational for decision

I am allowing this appeal, with my reasoning outlined below:

The driver of the vehicle has not been identified. Therefore, the operator is pursuing the registered keeper for the PCN.

For the operator to transfer liability for unpaid parking charges from the driver of the vehicle to the registered keeper of the vehicle, the regulations laid out in the PoFA 2012 must be adhered to. The operator must meet schedule 4 paragraph 9 (2) (a) which states:

“(2)The notice must— (a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;”

In this case the PCN states Lidl St Neots, however the appellant has told us there is 2 Lidls in St Neots and the PCN does not confirm the Post Code.

Whilst the operator has confirmed it has a contract in place for enforcement for Lidl St Neots, there is no evidence of which store this is. Therefore, due to the lack of rebuttal from the operator I cannot categorically advise the appellant which store the PCN was issued at.

POPLA’s role is to assess if the operator has issued the PCN in accordance with the conditions of the contract. As the PCN does not state the relevant land I am not satisfied that the operator has issued the PCN correctly, and accordingly the appeal is allowed.

The appellant has raised other grounds in their appeal, but as I am allowing the appeal, it is not necessary for me to address these.
Title: Re: Private PCN St Michael's Court
Post by: Nosy Parker on January 13, 2024, 08:20:55 am
But the discount is irrelevant, unless you intend to pay. And if you intend to pay, why bother appealing?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on January 12, 2024, 10:54:29 pm
They can't escalate much in the County Court as costs are capped (unless the behaviour of either party is deemed unreasonable - the bar for this is very high so it is very rarely met).

The £70 of debt collector fees can generally be successfully challenged regardless of the outcome of the rest of the claim. A loss on a single ticket is generally in the region of £220 I believe.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on January 12, 2024, 10:51:29 pm
They proudly trumpet the Beavis case in their letter. Presumably as a deterrent. Presumably the costs can escalate quite a lot if you go to Court so I doubt it's worth it.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on January 12, 2024, 08:22:54 pm
I've never personally recommended the paying under duress idea, as, frankly it'd be difficult to claim you were under duress. It's not like the old days where cars were clamped and you had to pay if you wanted to drive away, nobody is forcing you to pay, only a judge can do that.

If you want to fight them you can wait to see if they sue then defend the matter in court - if you intend to do that you're better off waiting for them to sue you, rather than paying and then trying to sue them for the money back.

ParkingEye are one of the more litigious firms, they took (and won) one case as far as the Supreme Court (ParkingEye vs  Beavis).

As for what you do, that's your call, as it's your money at stake.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on January 12, 2024, 07:56:18 pm
Well it was too good to last. PE are now chasing me. What is not true is their statement that "You have been advised that the amount payable is £100 and you were provided with 28 days from the decision date to make payment". Well POPLA certainly did not say this and I did not hear a word from PE following the decision. They are now giving me a further 14 days to pay up. 14 days from when? Date of their letter? Clearly this is not a statutory period. Anything I can do here other than just pay up? Word seems to be that PE does aggressively pursue non-payers. I believe I can state that I am paying under duress and then claim the amount back via the Small Claims Court but frankly it's a hassle and I can't really see the judge ruling against both POPLA and a POPLA "appeal".

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Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on December 20, 2023, 11:04:00 pm
A more detailed reply than I expected them to bother providing, although the result was as expected!

On the bright side, I have not heard another word from PE about getting the parking penalty out of me.
Fingers crossed they've put you in the 'too much effort' pile - but keep your eye out for any correspondence, they have 6 years to make a claim, although ParkingEye aren't usually the type to wait until the last minute to issue a claim.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on December 20, 2023, 11:00:04 pm
Here's the reply to my complaint about the way in which the assessor came to her verdict:

Your complaint about POPLA case 6062593108.

Thank you for your letter dated 17 November 2023. This has been passed to me by the POPLA Team as I am responsible for handling complaints.

I note from your correspondence that you are unhappy with the decision reached by the assessor in your appeal against Parking Eye.

POPLA is an impartial and independent appeals service and we do not act either for the parking operator or the appellant. It is important to explain that it is not our remit to source evidence and documents from either party in support of their submission and our decisions are based on the evidence received from both parties at the time of the appeal. We cannot consider further evidence after the appeal has been completed.

POPLA is a one-stage process, and we would not change a decision because either party disputes the assessor’s decision. However, we may consider an appeal if there has been a procedural error, for example – if we failed to allow a motorist to comment on a parking operator’s evidence pack.

Having read your complaint, I have noted your following points and will address each one individually:

•   The crux of your complaint is that you appealed as the registered keeper of the vehicle, and you were not the driver of the vehicle at the time of the parking event. You believe the assessor has confused the registered keeper and the driver on the day. The parking operator sent a second PCN that did not refer to the Protection of Freedoms Act (PoFA) 2012.

After reviewing your complaint and the assessor’s decision, I note you have quoted the following:

“A payment report has been provided which shows that the appellant purchased 2 hours parking time that day. The appellant has overstayed the parking time by 35 minutes.”

I acknowledge the assessor has made an administrative error as these statements should have referred to the ‘driver’ and not ‘the appellant’. However, having read the entire rationale, I am satisfied the assessor considered keeper liability under PoFA and did not refuse your appeal on the basis that you were the driver of the vehicle:

“As such, PoFA 2012 has been met and the appellant as the registered keeper can now be held liable for any unpaid parking charges.”

Therefore, I am satisfied these administrative errors do not impact the outcome of the decision.

In addition, I must confirm that POPLA assesses the validity of the original PCN that was issued when determining if it complies with PoFA. There is no requirement for any PCN reminders that are subsequently issued to also contain the relevant information under PoFA.

•   You raise that the PCN did not state which ‘St Michael’s Court’ car park the notice related to. You advise there are nine car parks with this name across the country, and question how you were to know which one was used on the day in question.

Regarding the relevant land specified on the PCN, the assessor’s report stated:

“The parking operator has failed to specify the location of the relevant land as required in paragraph 9 of PoFA 2012. They say a google search shows that there are 9 different ‘St Michaels courts’.

Whilst I appreciate their concerns, within PoFA 2012 under schedule 4, paragraph 9 it states;

“The notice must—

(a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates”.

By stating relevant land, it does not require a full site address including postal code. Therefore, I am satisfied that ‘St Michaels Court’ does identify the car park where the appellant parked and meets PoFA 2012 paragraph 9.”

The assessor is correct that PoFA does not explicitly require the notice to provide a full address when specifying the relevant land where the vehicle was parked. Whilst I note your point regarding nine other St Michael’s Court car parks being in the country, the driver would know which St Michael’s Court they used on the day - at the time in question. Hence, the parking operator gives you, as the registered keeper, the opportunity to provide the driver’s details to transfer liability to them.

It is your right to do so, but by choosing not to identify the driver, you have accepted liability for the charge as the registered keeper. As the car park is named on the PCN, the relevant land has been specified for the purpose of POPLA’s assessment.

As all the evidence provided has been considered, no procedural error has occurred and therefore, the outcome will not change. As POPLA is a one-stage process, there is no opportunity for you to appeal the decision.

If you still doubt the legitimacy of the parking charge, POPLA’s decision does not prevent you from disputing your issue through other channels, such as the courts, if you wish to do so. For independent legal advice, please contact Citizens Advice at: www.citizensadvice.org.uk or call 0345 404 05 06 (English) or 0345 404 0505 (Welsh).

To conclude, I am sorry that you have not had a positive experience when using our service. POPLA’s involvement with your case has now ended, and my response closes our complaints process. I must advise there will be no further review of your complaint and any further correspondence on the matter will not be responded to.

Yours sincerely,
Bethany Young
POPLA Complaints Team


The one thing Bethany Young does not address is the supposed "typographical error" whereby PE said they were not pursuing me under POFA 2012, which in different ways they said or referred to three times. She effectively says "the original PCN stands and we can ignore anything they said subsequently" ....such as a second PCN which was "a reminder" and the fact that PE told POPLA directly that they were not pursuing me under POFA.

On the bright side, I have not heard another word from PE about getting the parking penalty out of me.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on December 18, 2023, 10:11:26 pm
It will be quite hard for them to say "we see nothing wrong with the service" without addressing the points I raise.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on December 18, 2023, 09:32:13 pm
See what comes back!

As they don't technically offer a formal means to challenge their verdicts as such, that's probably why their response makes reference to their service (although one might argue that them reaching a verdict is part of the 'service').
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on December 18, 2023, 09:24:05 pm
Well they do seem to be taking it seriously. It hasn't been turned down flat. But I wasn't "unhappy with [POPLA's] service", just with the verdict!

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Title: Re: Private PCN St Michael's Court
Post by: Chaseman on December 15, 2023, 07:03:53 pm
You have answered my question - ball in PE court.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on December 11, 2023, 09:48:54 pm
Am I safe just to keep my head down and say nothing?
Depends what you mean by 'safe' - in theory they have up to 6 years to take court action, although ParkingEye tend not to waste too much time.

Your options remain as they were previously, and as regards to whether it ends up in court, the ball remains in ParkingEye's court. They may have put you in the 'too much hassle' pile, or may simply not have got around to escalating your case yet.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on December 11, 2023, 10:33:28 am
Well this is odd. It’s almost a month on and I haven’t heard a thing from Parking Eye. Am I safe just to keep my head down and say nothing? I have also heard nothing from John Gallagher at POPLA either.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on November 16, 2023, 06:20:44 pm
The Lead Adjudicator is 'John Gallagher' I believe, unless there's been a change recently - I don't have a direct email for him. I imagine for obvious reasons it's not widely publicised. I would therefore use whatever complaints procedure they have available.

I think your letter covers the main points you wish to raise - I wouldn't expect them to change their minds. I don't say this because I don't think you have a point, but because I don't want to raise any false hopes. Particularly as the key error of consequence (i.e. the one that sunk your appeal), is one that requires a degree of judgement, rather than something more clear-cut (such as a notice that was inarguably delivered outside of the relevant period for PoFA, for example).
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on November 16, 2023, 04:02:00 pm
I have drafted up a letter to send to POPLA. I am thinking it should go to the Chief Adjudicator. Does anyone have a name? I will send it by post as any attempt to send it on-line will probably be met with a "case closed" automated reply. Whether they do anything with it is up to them.

Does anyone have any insight into the process/procedure if I was to allow PE to take me to court for non-payment? I would represent myself. What other costs might I be up for and could  the £100 penalty be increased (I presume yes)?

The more I think about it the more I am gobsmacked that the assessor could come up with such a one-sided verdict, ignoring all mistakes, inconsistencies, untruths and obtuseness from PE while layering on her own inability to tell the difference between the RK as appellant and the driver.

All thoughts welcome!



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Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on November 15, 2023, 10:50:02 am
The issuing of more than one notice etc. was indeed a bit of a ****show. If it does go to court, I think the issue it will largely boil down to will be whether the location is specific enough to meet the requirements of PoFA.

Can't hurt.
Indeed.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on November 15, 2023, 12:15:11 am
Quote
The main issue seems to be one of judgement rather than fact (I.e. The assessor judged that the location was specific enough for PoFA liability to apply)

She also judged that the issue of a new PCN with no reference to POFA, and to which the log obtained from PE referred to as "non-POFA" was a "typo" which is a hell of a leap  of judgement! I think it must be worth me writing to POPLA and pointing out this plus the fact that the assessor continually refers to the appellant as though he (i.e. me/I) was the driver which shows a basic lack of understanding of a) the facts and b) my whole argument. Can't hurt.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on November 14, 2023, 08:23:35 pm
Quote
But it seems there is no possibility of a formal review of the decision as there would be with London Tribunals
Correct, although unlike with them, the final decision is not binding on you, leaving open the possibility to argue your case in court. The main issue seems to be one of judgement rather than fact (I.e. The assessor judged that the location was specific enough for PoFA liability to apply), which means POPLA are very likely not to change their minds.

Quote
If I do want to take it further is it me initiating the court case or do I sit back, not pay, and wait for PE to take me to court?
It is for ParkingEye to initiate, they are the ones with the alleged claim against you. They have up to 6 years to make a claim, but they're usually relatively prompt in going to court.

They're likely to send chasing letters before doing so, and of course there's no guarantee that they will sue. But my advice is to always assume a company will sue, so that you're prepared if they do.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on November 14, 2023, 07:57:36 pm
But it seems there is no possibility of a formal review of the decision as there would be with London Tribunals. I can obviously write to POPLA and point out the holes in the judgment but are they likely just to say "this is not appealable to us so it's going in the bin?"

If I do want to take it further is it me initiating the court case or do I sit back, not pay, and wait for PE to take me to court?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on November 14, 2023, 07:48:57 pm
You can complain to POPLA if you wish, but don't expect them to change their minds.

As I noted elsewhere in the thread, POPLA's decision is not binding in you, only a court can 'force' you to pay up. ParkingEye take a lot of people to court, so I would work on the assumption that they will. It's up to you as to whether you take the £100 'hit', or take your chances in court.

If you weren't the driver and can say as much in court under penalty of perjury, then this does make a PoFA defence more viable. From memory I can't think of any cases I'm aware of that have gone to court on this point, so little to go on in terms of past success rates etc.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on November 14, 2023, 07:36:06 pm
Do you mean that if I don't pay up PE would pursue me through the courts? I was really meaning was there anything further I could do to challenge the decision? It really seems perverse - all this Ashlea has concentrated on is "did the car exceed the time paid for?" and the answer is yes. I have never disputed that. And no I wasn't the driver and I have exercised my right not to say who was.

But to say that it's fine for PE just to put the name of the car park on the PCN with no other form of address and that counts as  "specifying the relevant land" is bizarre! What about if  the address of the car park was High Street Anytown and all they put down was High Street, there would be hundreds of them! And as for the issue of a second PCN this time expressed not to be under POFA, the whole thing was a typo? Did she ask PE if it was a typo?

And the adjudicator herself has mixed up  the driver and the registered keeper. Note this:

the appellant purchased 2 hours parking time that day. The appellant has overstayed the parking time by 35 minutes

Oh no I didn't. I am the appellant and the registered keeper but I did not park the car in the car park nor pay for a ticket! And as for sympathising with me that PE never addressed the question of location "but there's nothing we can do about that because we don't act for the operator" this is just wholly disingenuous. As well as dismissing what the previous head of POPLA said about the need for strict compliance with POFA. Frankly the whole judgment is just so riddled with holes that it makes me wonder whether there was a backhander involved  >:(

And I would not be going to court on the grounds of "prove it was me that was driving" because PE has been given the thumbs up by POPLA to pursue me as the registered keeper because "the notice has met the requirements laid out in POFA" and so they don't have to show I was the driver. Despite saying they hadn't issued the notice under POFA!

Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on November 14, 2023, 06:51:03 pm
That's unfortunate... We've seen POPLA take motorists side on this issue quite a few times of late, but it can be a case of 'Assessor bingo', seems like you got a less amenable one.

In terms of next steps, the call is yours to make. ParkingEye are litigious, so a court claim is fairly likely. In my personal view, going to court solely on a PoFA argument of "prove it was me driving" is risky, if indeed you were the driver.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on November 14, 2023, 04:44:51 pm
Got the result today - Appeal Unsuccessful! This seems to fly in the face of the evidence. Here is the semi-literate reasoning from the assessor:

Quote
Decision
Unsuccessful

Assessor Name
Ashlea Forshaw

Assessor summary of operator case
The parking operator has issued a Parking Charge Notice (PCN) to the motorist for failing to purchase the appropriate parking time.

Assessor summary of your case
The appellant has raised the following grounds of appeal: • Registered keeper/ driver • Failure to comply with PoFA • Understanding keeper liability • Rejection of appeal In support of this appeal the appellant has evidence the following: • A word document elaborating on their grounds of appeal I will take the above into account. The appellant has commented on the parking operators case file reiterating their grounds of appeal and expanding on those.

Assessor supporting rational for decision
When assessing an appeal POPLA considers if the parking operator has issued the parking charge notice correctly and if the driver has complied with the terms and conditions for the use of the car park. The signs at this site advise that parking tariffs apply. Up to 3 hours is £3.00. Failure to comply with the terms and conditions will result in a £100 PCN being issued. The parking operator has evidenced the appellant’s vehicle parked on site for the duration of 2 hours and 35 minutes. A payment report has been provided which shows that the appellant purchased 2 hours parking time that day. The appellant has overstayed the parking time by 35 minutes. No payment was made for the additional overstay. I note the appellant has raised a number of grounds of appeal and so, I will be addressing each ground individually.

• Registered keeper/ driver/ Understanding keeper liability They say they are the registered keeper and was not the driver of the vehicle on the date of the event. They raise the Protection of Freedoms Act (PoFA) 2012. When a parking operator does not know who the driver of the vehicle was at the time of the alleged offence, it will look to pursue the registered keeper using PoFA 2012. When doing so, schedule 4 paragraph 9 of PoFA must be followed. Paragraph 9 states; 9(1) A notice which is to be relied on as a notice to keeper for the purposes of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met. (4)The notice must be given by— (5)The relevant period for the purposes of sub-paragraph (4) is the period of 14 days beginning with the day after that on which the specified period of parking ended. I have reviewed the notice to keeper and I can see that the date of the contravention was 27 July 2023 and the PCN was issued on 1 August 2023. This was within the 14 day time limit. As such, PoFA 2012 has been met and the appellant as the registered keeper can now be held liable for any unpaid parking charges.

The appellant has referred to a statement made by a barrister [who is the former head of POPLA] in regards to keeper liability. As stated above the notice has met the requirements laid out in PoFA 2012 [except it hasn't] and so I will not comment on the information noted by the barrister. Within their comments, they say the parking operator has stated, “Please be advised, this Parking Charge was not issued under the Protection of Freedoms Act 2012”. They say this contradicts what is on the PCN itself as it states it has been issued under PoFA. I understand the confusion caused however it is my view that a typographical error has been made in the case file. It can be seen that the PCN was issued under PoFA. [And what about the second PCN issued three weeks later stated not to be under POFA? Was the whole thing a typo?]

• Failure to comply with PoFA. The parking operator has failed to specify the location of the relevant land as required in paragraph 9 of PoFA 2012. They say a google search shows that there are 9 different ‘St Michaels courts’. Whilst I appreciate their concerns, within PoFA 2012 under schedule 4, paragraph 9 it states; “The notice must— (a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates”. By stating relevant land, it does not require a full site address including postal code. Therefore, I am satisfied that ‘St Michaels Court’ does identify the car park where the appellant parked and meets PoFA 2012 paragraph 9. • Rejection of appeal They say that the parking operator has failed to respond to the key points of their appeal regarding the location of the car park. I do understand how frustrating this may be not having received a detailed response to their appeal from the parking operator however POPLA does not work for or on behalf of the parking operator’s and so, we cannot become involved in any complaints regarding failures in its service. The appellant would need to raise this to the parking operator directly- [which of course I did on  several occasions]. On reviewing this case, I am satisfied that the PCN was issued correctly as insufficient time was purchased for their stay. This appeal has been refused.

So all that matters is whether the vehicle overstayed the time purchased it seems. It matters not a jot whether the PPC is pursuing the keeper or the driver, it matters not a jot whether the PPC gives an identifiable address for the "relevant land" [suppose it had just said High Street?], it does not matter whether they meet the strict requirements of POFA 2012, it does not matter if they issue the PCN under POFA and then contradict themselves by saying it is not issued under POFA because this is just a typo [did the assessor go back to Parking Eye and ask them if it was a typo?]. To my mind this has all the hallmarks of an "independent" adjudicator that is firmly in the pocket of the private parking industry. I feel pretty confident that the London Tribunals would have thrown this one out if it had been a LA behaving like this. Anything further I can do here?
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on October 08, 2023, 06:05:51 pm
It's 10,000. Further evidence submitted. The auto reply said they would take a decision within 2-4 weeks.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on October 08, 2023, 03:14:16 pm
Looks to cover the key points.

Have you checked it fits in the character limits? There used to be a 2,000 character limit for POPLA comments. I think it was increased to 10,000 at some point, although it's thankfully been a while since I've had to submit a POPLA appeal myself so not 100% sure.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on October 07, 2023, 10:42:23 pm
I will have to send off my final submission tomorrow so any last comments welcome.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on October 06, 2023, 07:37:19 pm
Thanks DW and you have I think uncovered part of the mystery surrounding the issue of the second PCN on 30 August.

It's in the Case History "Letter Issued - Driver details non POFA" that you draw attention to. That second PCN did indeed omit any reference to POFA but did make some very confusing and plain incorrect statements about what I had told them about the identity of the driver (answer, nothing) - supposedly with my registered keeper hat on I informed PE that I was the driver, but then going on to say that as they don't  know the identity of the driver could I (with my driver hat on) please inform them who it was! I now think this was a recognition that they weren't going to get anywhere down the POFA route and would have a second go at getting me to reveal who the driver was on a non-POFA basis.

Anyway, here's a re-worked submission to POPLA. See what you think of this

Quote
The great majority of Parking Eye’s submission is simply a reproduction of past notices and correspondence which does not require further comment. I comment on the further material put forward by Parking Eye as follows, together with a summary of the main thrust of my appeal which remains unaddressed by Parking Eye (“PE”).

1. I am the registered keeper of the car XXXXXX which was the subject of a Parking Charge Notice (“PCN”) for a parking event on 27 July as recorded on PE’s cameras. I was not the driver and I have stated this clearly to PE in my appeal. On the back of the PCN is a paragraph under the heading “Protection of Freedoms Act” which asserts PE’s rights and intentions to hold the keeper liable if it cannot identify the driver.

The implied contract is between the driver and the landowner, acting through PE as its agent. PE’s redress for breach of contract is against the driver. Only in the case where PE has complied strictly with the requirements of Schedule 4 of POFA, and where the driver has not been identified, can PE transfer liability to me as the registered keeper, relying on the provisions under POFA that they quote as above. As stated, this is what they warned me they would do.

However, under the heading Additional Information appearing on page 4 (pdf page count) of PE’s submission to POPLA they say:

Please be advised, this Parking Charge was not [my emphasis] issued under the Protection of Freedoms Act 2012

This clearly contradicts what they said on the PCN but as this is their final word on the subject I have to take it as such and accordingly they have no basis on which to transfer any liability for a parking charge from the driver (who has not been identified) to me as registered keeper. As such my appeal must be upheld.

It is also noteworthy that in the Case History in PE’s submission is included:

30/08/2023 Letter Issued - Driver Details Required non POFA

Which seems to suggest they were proceeding at that stage on the basis that they were not under POFA notwithstanding what the PCN said. What they issued on 30 August was a second PCN detailing the same parking event as the original PCN but without reference to POFA on the back. I submit they cannot legitimately superimpose a second PCN over the top of the first one on different terms and without explanation. That second PCN also made some confusing and plain incorrect statements about what I had or had not told them about the driver.

2. Prior to seeing the latest submission from PE which asserts they are not seeking to make me liable under POFA, I was appealing on the grounds that PE had not followed the strict requirements under Schedule 4 which includes a requirement to specify the “relevant land”. By stating the location as only “St Michael’s Court” with no street, town or postcode this does not specify the location uniquely or accurately. As I said in my appeal, there are 9 St Michaels Courts in England and it could have been any of them. So even if PE were to assert they are pursuing me under POFA, they have not complied with the strict requirements under Schedule 4 (note the words of Henry Greenslade, former POPLA Lead Adjudicator in 2015). PE has never replied to this point and does not do so now. It turned down my appeal, on grounds that I had never advanced, relating to signage.

3. If the PCN was issued under POFA then I contend that there is a defect which renders it non-compliant with section 9(2)(a) of POFA 2012 and as such liability cannot be transferred to me as the registered keeper. If, as PE now says, the PCN was not issued under POFA then their redress is only against the driver and I was not the driver.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on October 06, 2023, 02:24:26 pm
See if there are other views, but overall this reads well, my only worry is that it takes rather a while to get to the key point, which is their admission that they are not seeking to use PoFA to hold the keeper liable.

You don't need to repeat your points about their failure to comply with PoFA in any great detail, your main POPLA appeal does that. I'd be minded to remove 1a where you quote the PoFA paragraph - if the assessor wants to read this in their evidence he can, but don't draw unnecessary attention to it.

I'd also make reference to the entry in their 'case history' on page 1 of the doc you uploaded where they include the line:
30/08/2023 Letter Issued - Driver Details Required non POFA

My only other comment is that I'm not sure point #3 adds anything. I'd stick to the stronger arguments.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on October 06, 2023, 01:48:02 pm
Here's my proposed final submission to POPLA

The great majority of Parking Eye’s submission is simply a reproduction of past notices and correspondence which does not require further comment. I comment on the further material put forward by Parking Eye as follows, together with a summary of the main thrust of my appeal which remains unaddressed by Parking Eye (“PE”).

1. I am the registered keeper of the car XXXXXX which was the subject of a Parking Charge Notice for a parking event on 27 July as recorded on PE’s cameras. I was not the driver and I have stated this clearly to PE in my appeal. On the back of the PCN is this paragraph (abridged) under the heading “Protection of Freedoms Act”:

a. "You are notified under para 9(2)(b) of schedule 4 of the Protection of Freedoms Act 2012 [POFA] that the driver of the motor vehicle is required to pay the Parking Charge in full....you are warned that if, after 29 days from the date given....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".
b. The implied contract is between the driver and the landowner, acting through PE as its agent. PE’s redress for breach of contract is against the driver. Only in the case where PE has complied strictly with the requirements of Schedule 4 of POFA, and where the driver has not been identified, can PE transfer liability to me as the registered keeper, relying on the provisions under POFA that they quote as above. As stated, this is what they warned me they would do.
c. However, under the heading Additional Information appearing on page 4 (pdf page count) of PE’s submission to POPLA they say:
Please be advised, this Parking Charge was not issued under the Protection of Freedoms Act 2012
This clearly contradicts what they said on the PCN but as this is their final word on the subject I have to take it as such and accordingly they have no basis on which to transfer any liability for a parking charge from the driver (who has not been identified) to me as registered keeper. As such my appeal must be upheld.

2. Prior to seeing the latest submission from PE which asserts they are not seeking to make me liable under POFA, I was appealing on the grounds that PE had not followed the strict requirements under Schedule 4 which includes a requirement to specify the “relevant land”. By stating the location as only “St Michael’s Court” with no street, town or postcode this does not specify the location uniquely or accurately. As I said in my appeal, there are 9 St Michaels Courts in England and it could have been any of them. So even if PE were to assert they are pursuing me under POFA, they have not complied with the strict requirements under Schedule 4 (note words of Henry Greenslade, former POPLA Lead Adjudicator in 2015). PE has never replied to this point and does not do so now. It turned down my appeal on grounds that I had never advanced relating to signage.

3. A month after the original PCN, PE sent me a second one that asserted the same date of parking event, was not labelled as a reminder, but with wording on the back that was untrue and confusing. I set this out in my original appeal to POPLA and nor has this been addressed by PE.

4. If the PCN was issued under POFA then I contend that there is a defect which renders it non-compliant with section 9(2)(a) of POFA 2012 and as such liability cannot be transferred to me as the registered keeper. If, as PE now says, the PCN was not issued under POFA then their redress is only against the driver and I was not the driver.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on October 05, 2023, 03:39:37 pm
Please be advised, this Parking Charge was not issued under the Protection of Freedoms Act 2012
Part of me wonders if they included this line by accident. Nevertheless it is potential gold dust, and you should ensure that your response to their evidence pack draws clear attention to it.

You should point out to the assessor that ParkingEye have admitted in their evidence pack that they are not seeking to use the Protection of Freedoms Act 2012, and as such, they are unable to recover the charges from you, the keeper. Reiterate that only the driver is liable, and that they have not demonstrated that you as the appellant were the driver.

Take a look through the rest of their evidence to see if there's anything they have got wrong, or admitted that helps your case.

Feel free to show us a draft before sending.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on October 05, 2023, 02:11:43 pm
I have now been notified that Parking Eye has submitted its response to my appeal to POPLA. They submitted this on 2 October and I apparently have 7 days within which to comment on that. Their submission is 43 pages long but mainly reproduces the originals of the PCN plus reminders and all the subsequent correspondence in both directions. In other words nothing new. They also reproduce loads of photos of the signage in the car park, my car going in and out, logs of the parking ticket machine showing it was working on the day in question (and indeed that my car paid for two hours of parking which it then overran) etc - all irrelevant to the crux of my appeal and not anything I am taking issue with. What they absolutely do not address is the shortcoming in the original PCN in not identifying the car park in question beyond saying that it is "St Michaels Court". Nor do they address the matter of two PCNs having been issued for the same event and nor the implication that by not identifying the driver "My appeal may well be rejected" which I contend fetters their discretion.

I have copied and pasted into a new document the only new bit of information/evidence from PE (as attached). I have highlighted two particular sentences, one much more significant than the other. This is the important statement:

Please be advised, this Parking Charge was not issued under the Protection of Freedoms Act 2012

This left me gobsmacked! If you go back to the original PCN, which is attached as an imgur link in post #1, it says on the back under the heading Protection of Freedoms Act:

"You are notified under para 9(2)(b) of schedule 4 of [POFA] that the driver of the motor vehicle is required to pay the Parking Charge in full....you are warned that if, after 29 days from the date given....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".

It couldn't be clearer. They want to know who the driver is - because the implied contract, subject to the terms and conditions displayed, is between the driver and PE as agent of the landowner - so they can nail the driver for a breach of those terms. However, they only have the details of the registered keeper [me] and I have stated that I was not the driver [which is true]. I am under no legal obligation to name the driver and I have not. So it is only in these circumstances [and assuming that PE has complied with the strict requirements of POFA, which I contend it has not] that PE can transfer liability to me under POFA. And they have said on the original PCN that that is what they are going to do.

Now out of left field they say "this parking charge was not issued under POFA". So if it wasn't, on what basis are they seeking to make me liable? I was not the driver and I did not enter into a contract with either PE or the landowner by parking in a car park whose whereabouts I do not know!

Am I missing something here? Otherwise I propose to say exactly this to POPLA. Secondly that if the claim is being brought under POPLA that they have not complied because they have not specified the relevant land and have not addressed the key point of my appeal in their submission. Thirdly there is the confusing issue of a second PCN for the same offence bearing incoherent and incorrect statements on the back - also not addressed.

The other sentence I have highlighted in the attachment is the one that says "The car didn't have its headlights on so it obviously wasn't dark and the driver should therefore have been able to read the signs". Except the photographs show the car did have its headlights on! However I am not making any points about the signage being unclear, I'm saying they haven't even told  me where the carpark is, so what signs are displayed is irrelevant!

They finish off by saying

"Please note that insufficient evidence has been received to cancel the charge"

In other words I got a stock reply that had been crafted to rebut an appeal along the lines of inadequate signage and I had not made my case. But this was not the crux of my appeal at all. It was quite the opposite - it was that PE had produced insufficient evidence as to the address of the car park in question!

Anything else I should be saying in my final opportunity to nail this one?



[attachment deleted by admin]
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 22, 2023, 02:35:05 pm
Appeal submitted. I removed the word outrageous!
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 21, 2023, 02:28:11 pm
My personal view has always been that appeals look better when emotion is left out of them.

POPLA's job is to assess your liability for the charge, they're not bothered about your outrage, and their members would make far less money if they acted in good faith. I'd stick to the facts. It makes you look reasonable and level-headed, exactly the perception you want to create.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 21, 2023, 01:23:36 pm
my whole appeal rests on not knowing where the car park in question is.
Not quite - your appeal rests on them having failed to specify the relevant land, as required by PoFA to recover the charge from the keeper. If you don't know where it was, that doesn't mean you don't owe the money. But if they've not complied with PoFA, then that does mean you don't owe the money.

But nevertheless, I can see a decent argument for leaving out the landowner authority part.

I'd say this latest draft flows a lot better than the previous. I would remove the word 'offence', perhaps refer to a 'parking event' instead.

(I've edited your post to remove your ParkingEye Reference # and your VRM).

OK to refer to "outrageous bad faith"? I am sure that is not a designated ground for dismissal but it strikes me as breaking all rules of natural justice to threaten that you might reject an appeal if I don't do as you say (i.e. name the driver) and secondly to adduce actions to me that are simply not true. No other comments on the detail?
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 20, 2023, 08:37:44 pm
If anyone is interested this is the Pepipoo topic link and the judgment appears in post #65.

http://forums.pepipoo.com/index.php?showtopic=144900&st=60
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 20, 2023, 08:35:49 pm
That's certainly the sort of logic you want the assessor to follow. I wasn't disagreeing with your point around knowing the location - my point was more that even if you had figured out which location it was, that wouldn't mean they have automatically complied. It's their job to specify, not yours to turn detective and work out where they mean.

Unless anyone else has any contrary views, I think it covers the main points you're looking to make.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 20, 2023, 08:28:55 pm
DW, yes I see your point and I have to agree your logic, but it comes down to the same thing - they didn't specify the address of the car park in sufficient detail and hence I maintain I don't know where it is which leads to a) I can't inspect any signage and b) they have not complied with POFA. I agree that me just not knowing where the car park is does not get me off HAD THEY actually complied with POFA.

I have picked this up off Pepipoo in the Vale Road case which also hinged on imprecise location. I would hope the POPLA assessor would follow the same thinking here.


https://i.imgur.com/0DWBTykl.jpg

Are you happy that I now file that appeal? I will change "offence" to parking event.




Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 20, 2023, 08:17:53 pm
my whole appeal rests on not knowing where the car park in question is.
Not quite - your appeal rests on them having failed to specify the relevant land, as required by PoFA to recover the charge from the keeper. If you don't know where it was, that doesn't mean you don't owe the money. But if they've not complied with PoFA, then that does mean you don't owe the money.

But nevertheless, I can see a decent argument for leaving out the landowner authority part.

I'd say this latest draft flows a lot better than the previous. I would remove the word 'offence', perhaps refer to a 'parking event' instead.

(I've edited your post to remove your ParkingEye Reference # and your VRM).
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 20, 2023, 07:58:04 pm
Thanks for your comments DW. I have amended the draft along the lines you suggest. See what you think of the below. I incorporated a para (the Greenslade quote) from a POPLA appeal on MSE. PE has not alleged that I was the driver (other than obliquely in their second PCN) and are pursuing me as Reg Keeper so I concentrate on the POFA point. I have decided on reflection not to include the Landowner Authority point. The reason is that my whole appeal rests on not knowing where the car park in question is. If I start asking them for details about their contract with the landowner it might imply that I do know where the car park is or even if not, it allows PE to open up the whole question of where it is i.e. if I show this level of interest then I am derogating from my main argument.

Quote
Registered Keeper/Driver

I received a Parking Charge Notice (“PCN”) issued by Parking Eye (“PE”) to Registered Keeper ref ###### dated 1 August 2023 for vehicle VRM ###### of which I am the registered keeper, alleging a parking “offence” on 27 July. I was not the driver of the car on the date in question and I have made this clear in my appeal to PE. They are therefore pursuing me for payment of the PCN as Registered Keeper and not as the driver. This brings the PCN within the ambit of the Protection of Freedoms Act 2012 (“POFA”).

Failure to Comply with POFA

This PCN fails to comply with the requirements of Schedule 4 of POFA namely, but not limited to, failing to specify the location of the relevant land as required by section 9 (2)(a) of the Act. It is not possible to determine the location of the alleged breach of their conditions because the PCN states the address as just "St Michaels Court". A quick check on Google Maps finds at least nine St Michaels Courts in England including Aylsham, Amersham, two addresses in London, South Shields, Gloucester, Derby, Litchfield and Weybridge. PE therefore cannot transfer liability for the alleged charge from the driver at the time to me, the Registered Keeper. There is no legal requirement to name the driver at the time and I have not done so. Even if the address is more specifically noted in another medium or at a later date, the PCN itself needs to specify “the location of the relevant land” and it does not.
 
Furthermore, the vital matter of full compliance with the POFA was confirmed by parking law expert barrister, Henry Greenslade, the previous POPLA Lead Adjudicator, in 2015:

Understanding keeper liability

“There appears to be continuing misunderstanding about Schedule 4. Provided certain conditions are strictly complied with [my emphasis], it provides for recovery of unpaid parking charges from the keeper of the vehicle. There is no ‘reasonable presumption’ in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver. [...] If {POFA 2012 Schedule 4 is} not complied with then keeper liability does not generally pass.”


Therefore, no lawful right exists to pursue unpaid parking charges from me as keeper of the vehicle, where an operator cannot transfer the liability for the charge using POFA, because (as is the case here), Schedule 4 has not been strictly complied with.

Appeal to PE

The PCN set out four options as follows:

To pay the driver's alleged parking charge;
To name the driver;
To appeal;
To pay and appeal.

I elected to appeal which I did on 14 August and which then gave PE 35 days to serve their substantive response.
 
On 30 August I received a response which neither accepted nor rejected my appeal but asked again for the driver's details. It went on to say that “if this information is not provided within 28 days the appeal may well be rejected". This appeared to tie their consideration of the merits of my appeal to my willingness to supply the driver's details, which I am under no legal obligation to provide. They were effectively fettering their discretion.

Such a response is not permitted under the BPA Code of Practice and ranks alongside the fourth 'option' of paying the parking charge and appealing which is similarly proscribed under the code.

On 1 September I wrote to PE bringing this extra-procedural response to their attention. They responded by post in a letter received by me on 4 September by issuing a second PCN, bearing the same number as the original but dated 30 August in respect of the same alleged parking charge, asking for a penalty to be paid within 28 days of the [new] issue date.

On the back of the “new” PCN is a paragraph that says as follows:

“We originally wrote to the registered keeper [that is me] of the vehicle whose details were held by the DVLA at the time of the parking event and they [me again] have informed us that you [me again] were responsible for this vehicle at the time of the parking event [which I did not]…..if you were not the driver at the time [I had already told them I was not] you should tell us the name and current postal address of the driver [I am under no legal obligation to do this]”.

They had thus sent me two separate PCNs on different dates of issue for the same “offence” including a paragraph in the second which is misinformed and thoroughly confusing.

Rejection of Appeal

Finally on 16 September PE sent a letter rejecting my appeal. The reason given for the rejection was as follows:

“We have reviewed the details outlined in your appeal, but we are not in receipt of sufficient evidence to confirm that the terms and conditions were not breached. These terms are clearly displayed on the signage located throughout the above car park.”

This signally fails to address the fundamental point of my appeal which is that the PCN does not identify the location of the car park where the “offence” is alleged to have taken place and hence I have no opportunity to inspect any signage. Simply telling me it was “St Michael’s Court” does not give me sufficient detail to allow me to locate the car park in question and hence any discussion of the terms and conditions that were or were not displayed and were or were not breached is simply irrelevant. I made no reference in my appeal to such terms and conditions. PE has wilfully ignored the whole question of “location of the relevant land” which demonstrates that my appeal has not been properly considered.

Summary

I contend that there is a defect in the original PCN which renders it non-compliant with section 9(2)(a) of POFA 2012 and as such liability cannot be transferred to me as the registered keeper. No subsequent further or better specification of the address (of which there has been none) can remedy this defect.

As a secondary point of appeal I note PE’s issue of a second PCN dated 30 August but alleging the same offence date of 27 July, which bore an incoherent paragraph on the back (as set out above) claiming I had done or said things as the registered keeper that patently I had not. Taken together with the implied threat that if I did not identify the driver my appeal “may well be rejected” this is an example of outrageous bad faith that should call for the PCN to be dismissed immediately.

Finally, my appeal has been rejected in what looks like a standard form letter that fails to address the key ground for my appeal and demonstrates that it has not been properly considered at all.

I request that the appeal be upheld and the charge cancelled.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 19, 2023, 09:35:10 pm
I think this draft would benefit from more structure, and a change of focus. Your main point of argument is (or should be), the PoFA fail, but currently around 75% of your draft focuses on a timeline of who sent what when, and the issue of the 2nd PCN, which potentially acts more as a distraction than a help in its current form.

By all means mention the debacle of them sending 2 PCNs, and the request for driver's details, as examples of their poor practice, but in my opinion your appeal would be far stronger if it focuses on the key issue of PoFA compliance. After all, this is a reason why no money is owed by you as the keeper. Them sending two PCNs on the face of it, isn't.

Have you looked at the examples on the MSE post I linked to? They often include a clear structure that guides the assessor through the points. I'd recommend setting it out your reasons in a similar structure, such as:

To make the appeal more readable, and easier to follow, I'd recommend using headings and numbering your appeal points. Clear grounds of appeal in headings, with the detailed explanations underneath.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 19, 2023, 06:17:17 pm
Here is my draft appeal to POPLA. Any comments gratefully received.

Quote
I received a Parking Charge Notice (“PCN”) to Keeper ref 226902/075498 dated 1 August 2023 for vehicle VRM LF64SFY of which I am the registered keeper, alleging a parking “offence” on 27 July. I was not the driver of the car on the date in question.

This Notice failed to comply with the requirements of Schedule 4 of The Protection of Freedoms Act 2012 namely, but not limited to, failing to specify the location of the relevant land as required by section 9 (2)(a) of the Act. It is not possible to determine the location of the alleged breach of their conditions because the PCN stated the address as just "St Michaels Court". A quick check on Google Maps finds at least nine St Michaels Courts in England including Aylsham, Amersham, two addresses in London, South Shields, Gloucester, Derby, Litchfield and Weybridge. Parking Eye therefore cannot transfer liability for the alleged charge from the driver at the time to me, the keeper. There is no legal requirement to name the driver at the time and I have not done so.
 
Even if the address is more specifically noted in another medium or at a later date, the PCN needs to specify the location of the relevant land and it does not. I appealed to Parking Eye on these grounds on 14 August.

On 30 August I received a response which neither accepted nor rejected my appeal.

The PCN set out four options as follows:

To pay the driver's alleged parking charge;
To name the driver;
To appeal;
To pay and appeal.

I elected to appeal which then gave Parking Eye 35 days to serve their substantive response. The 30 August response asked again for the driver's details and implied that if I did not comply my appeal "may well be rejected". This appeared to tie their consideration of the merits of my appeal to my willingness to supply the driver's details, which I am under no legal obligation to provide. They were effectively fettering their discretion.

Such a response is not permitted under the BPA Code of Practice and ranks alongside the fourth 'option' of paying the parking charge and appealing which is similarly proscribed under the code.

On 1 September I wrote to Parking Eye bringing this extra-procedural response to their attention.

They responded by post in a letter received by me on 4 September by issuing a second PCN, bearing the same number as the original but dated 30 August in respect of the same alleged parking charge, asking for a penalty to be paid within 28 days of the [new] issue date.
 
On the back of the “new” PCN is a paragraph that says as follows:

“We originally wrote to the registered keeper [that is me] of the vehicle whose details were held by the DVLA at the time of the parking event and they [me again] have informed us that you [me again] were responsible for this vehicle at the time of the parking event [which I did not]…..if you were not the driver at the time [I had already told them I was not] you should tell us the name and current postal address of the driver [I am under no legal obligation to do this]”.

They had thus sent me two separate PCNs on different dates of issue for the same “offence” and a letter which is misinformed and thoroughly confusing.

Finally on 16 September Parking Eye sent a letter rejecting my appeal. The reason given for the rejection was as follows:

“We have reviewed the details outlined in your appeal, but we are not in receipt of sufficient evidence to confirm that the terms and conditions were not breached. These terms are clearly displayed on the signage located throughout the above car park.”

This signally fails to address the fundamental point of my appeal which is that the PCN does not identify the location of the car park where the “offence” is alleged to have taken place. Simply telling me it was “St Michael’s Court” does not give me sufficient detail to allow me to locate the car park in question and hence any discussion of the terms and conditions that were or were not displayed and were or were not breached is simply irrelevant. I made no reference in my appeal to such terms and conditions. Thus I contend that there is a defect in the original PCN which renders it non-compliant with section 9(2)(a) of POFA 2012 and as such liability cannot be transferred to me as the registered keeper. No subsequent further specification of the address (of which there has been none) can remedy this defect.

As a secondary point of appeal I note Parking Eye’s issue of a second PCN dated 30 August but alleging the same offence date of 27 July, which bore an incoherent paragraph on the back (as set out above) claiming I had done or said things as the registered keeper that patently I had not. Taken together with the implied threat that if I did not identify the driver my appeal “may well be rejected” this is an example of outrageous bad faith that should call for the PCN to be dismissed immediately.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 18, 2023, 10:16:32 pm
they have given me all the blurb for appealing to POPLA but NOT the 10 digit number they need to send with their letter of rejection.
They have, it's immediately above 'Dear Sir/Madam'.

And yes, they seldom address the specificities of appeals, far cheaper to send out a boilerplate.

The process of appealing to POPLA is fairly straightforward, and can be done entirely online via their website. There are no telephone or in-person hearings, it's all done 'on the papers'. The general advice with POPLA appeals is to be more thorough than your initial appeal to the parking company, as the POPLA assessor does not have the benefit of any prior knowledge of the case, and the more thorough you are, the less room for misinterpretation there is.

It may help to look at other POPLA appeals to get a feel for how they are constructed - the MSE Forum has a decent introduction guide here (https://forums.moneysavingexpert.com/discussion/comment/64350600/#Comment_64350600 (https://forums.moneysavingexpert.com/discussion/comment/64350600/#Comment_64350600)) - and a search of that forum and the PePiPoo should yield some good recent examples. Ideally, find a couple that have argued similar points to you (I provided a link to a similar case early on in the thread).
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 18, 2023, 09:53:41 pm
Well, no great surprise, Parking Eye have rejected my appeal. Not that they considered the fundamental point raised i.e. imprecise location nor the secondary point inasmuch as they sent a second PCN with a different date but referring to the same "offence". No they came out with this cracker:

Quote
We have reviewed the details outlined in your appeal, but we are not in receipt of
sufficient evidence to confirm that the terms and conditions were not breached. These
terms are clearly displayed on the signage located throughout the above car park.

Irrelevant that I had never questioned the terms and conditions nor whether they were properly displayed nor whether I had breached them or not. I simply pointed to the fact that they had not given me the address for St Michael's Court so they "had not specified the relevant land" as required by the legislation. That point has been completely ignored. They have also completely ignored the incoherent para on the back of the second purported PCN in which they alleged that I as RK had identified myself as the driver (which I hadn't) and if I wasn't the driver (with my driver hat on) could I please identify who was the driver (which I had already said I was not going to do).

So you will see from the letter attached that they have given me all the blurb for appealing to POPLA but NOT the 10 digit number they need to send with their letter of rejection. I assume this is deliberate to try and snooker an appeal to POPLA. I have never appealed to POPLA before. I assume it is fairly straightforward - do they do telephone hearings or do you just get a written verdict?

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Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 09, 2023, 05:37:42 pm
The Code of Practice is binding insofar as they agree to comply with it, and if they do not you could complain to the BPA. The Code of Practice is just that, not the law (although the Supreme Court did describe it as "in practice binding" in the Beavis case).

My point was more that them not complying with the code would be poor practice (and something you could point out), but wouldn't immediately invalidate the charge or prevent them taking further action.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 09, 2023, 03:06:40 pm
Fair point about parking charge v parking penalty, you did mention that before. So are you suggesting I remind them of the 35 day deadline now, before it's expired? From what you say, this is a Code of Practice and as such advisory rather than binding? Tactically it might make sense to wait until we are closer to the expiry of that period?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 09, 2023, 01:57:18 pm
I think I'd me minded to, yes. Although if you're making use of HCAndersen's wording, change 'penalty charge' to 'parking charge'.
Note the above. A minor difference, but important when you're trying to sound like you know your stuff.

I wouldn't say 'you're out of time'. But by all means remind them of the deadlines in the Code of Practice (noting that them failing to comply by it is poor practice, but doesn't necessarily prevent them trying to take things further).

Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 09, 2023, 12:45:07 pm
Here is my suggested letter to PE drawing on HCA's draft but expanding it a bit:

Quote
Dear Sir,

On 14 August I appealed PCN 226902/075498 which you issued on 1 August.

On 30 August I received a response which neither accepted nor rejected my appeal.

On 1 September I wrote to you bringing this extra-procedural response to your attention.

You responded by post in a letter received by me on 4 September by issuing a second PCN, bearing the same number as the original but dated 30 August in respect of the same alleged penalty charge, asking for a penalty to be paid within 28 days of the [new] issue date.

On the back of the “new” PCN is a paragraph that says as follows:

“We originally wrote to the registered keeper [that is me] of the vehicle whose details were held by the DVLA at the time of the parking event and they [me again] have informed us that you [me again] were responsible for this vehicle at the time of the parking event [no I have not]…..if you were not the driver at the time [I have already told you I was not] you should tell us the name and current postal address of the driver [I am under no legal obligation to do this].

You have now sent me two separate PCNs on different dates of issue for the same “offence” and a letter which is misinformed and thoroughly confusing.
As the circumstances of these PCNs are identical and the addressee the same in each case, I trust you will now cancel both, given that the second has no validity, and that you have failed to supply a comprehensive answer to the appeal against the first.

Given that PE had 35 days to respond to my appeal of 14 August - which I contend they have not done in a substantive form - this takes us to 18 September by my reckoning. Should I send the above letter now to "mark their card" and then assuming nothing has arrived by 18 September another to say "you are out of time"? I am mindful that my assertion above "you have failed to supply a comprehensive answer" begs the question "by when"?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 06, 2023, 10:42:32 pm
I think I'd me minded to, yes. Although if you're making use of HCAndersen's wording, change 'penalty charge' to 'parking charge'.

To hopefully avoid any further confusion, you may wish to attach a copy of your initial appeal alongside this, and make clear in the response that you are doing so.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 06, 2023, 10:32:34 pm
Should I write to Parking Eye again to point out the incoherence of this along the lines of HCA's draft?
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 04, 2023, 08:44:58 pm
Here's the back of the new notice. I had looked at it quickly and assumed it was the same rubric as in the first but on looking more carefully there is an additional para which I have marked with asterisks. This is rather a strange para as (to paraphrase) it says they (PE) have written to the RK (i.e. me) and he (me) has informed them that you (again me, as the addressee of the letter) was responsible for the "parking event". But they then go on to say that they don't know the contact details for the driver and could I please inform them who it was if it wasn't me. They then omit the para headed Protection of Freedoms Act that appeared in the original PCN.

So thoroughly convoluted and confusing  :-\

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Title: Re: Private PCN St Michael's Court
Post by: H C Andersen on September 04, 2023, 04:15:39 pm

IMO I would reply, with a straight bat of course.

PCNs **********/*********

Dear Sir,
On *** I appealed PCN ******** which you issued on *****.

On **** I received a response which neither accepted nor rejected my appeal.

On *** I wrote to you bringing this extra-procedural response to your attention.

You responded on **** by issuing a second PCN, no.********, in respect of the same alleged penalty charge. As the circumstances of these PCNs are identical and the addressee the same in each case, I trust you will now cancel both, in as much as the second has any validity, and draw a line under this episode.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on September 04, 2023, 03:56:40 pm
Can we see the back of this new notice?

It's certainly unusual from ParkingEye, their reminder notices are usually clearly identified as such. Perhaps they used the wrong template.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on September 04, 2023, 03:38:02 pm
I have now had a sort of reminder PCN from Parking Eye but it is not headed Reminder, it is almost as though it were a new PCN but relating to the original "offence" i.e. the date of the offence is as before but the PCN bears a new date with a warning that it should be paid within 28 days of "the date of issue" which is now set out as 30 August. Similarly with the period for payment at a discount. The effect seems to be to just extend the periods - although I am not minded to pay anyway - but is this usual/legal?

Certainly you wouldn't find a LA issuing a second PCN for the same offence but with a new date of issue. I don't suppose it invalidates the original PCN does it? It is certainly muddying the waters though!

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Title: Re: Private PCN St Michael's Court
Post by: H C Andersen on September 01, 2023, 01:48:05 pm

I have now submitted the appeal on-line along the lines of the draft above. The interesting thing is that when I get into the appeal pages the full address where the offence is alleged to have occurred is shown. However, this just is not on the face of the PCN and hence I am arguing (or will argue if necessary) that this is inadmissible.

It's not inadmissible, it's evidence..and in your favour.

The PCN itself must—

(a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;

From what you are saying, the creditor knew full well the exact location and you have now been able to determine where this occured.

Great...because it means that you can now look at the site on GSV or in person to check on the signs without undermining a key element of your appeal which was that you were unaware where it occured.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 31, 2023, 12:35:57 pm
I have beefed it up a little. Here is my intended reply:

Quote
I refer to the above PCN dated 1 August and my appeal dated 14 August.

In the PCN you set out 4 options as follows:

To pay the driver's alleged parking charge;
To name the driver;
To appeal;
To pay and appeal.

I elected to appeal which then gave you 35 days to serve your substantive response. You have not done so, instead you have sent a reply asking again for the driver's details and implying that if I did not comply my appeal "may well be rejected". This appears to tie your consideration of the merits of my appeal to my willingness to supply the driver's details, which I am under no legal obligation to provide. You are effectively fettering your discretion.

Such a response is not permitted under the BPA Code of Practice and ranks alongside your 4th 'option' of paying the parking charge and appealing which is similarly proscribed under the code.

As your response is extra-procedural you cannot rely upon it to relieve you of your obligation to respond within the 35-day period, addressing my substantive point regarding location. I look forward to receiving this reply.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 31, 2023, 12:03:03 pm
If you're minded to respond to ParkingEye' fishing letter then I'd agree that Hcandersen's response would achieve the desired aim.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 31, 2023, 11:10:56 am
HCA

I rather like that. I know you of course from Pepipoo and your attention to detail is unsurpassed. Thanks for the heads-up on what is and is not permitted for private parking tickets, a subject on which I am far less well-informed than council PCNs. I will send an e-mail along those lines unless anyone else has a view.
Title: Re: Private PCN St Michael's Court
Post by: H C Andersen on August 30, 2023, 03:21:27 pm

Dear Sir,
PCN *********

I refer to the above dated 1 August and my appeal dated ****.

In the PCN you set out 4 options as follows:

To pay the driver's alleged parking charge;
To name the driver;
To appeal;
To pay and appeal.

I elected to appeal which then gave you 35 days to serve your substantive response. You have not done so, instead you have sent a reply asking again for the driver's details and implying that if I did not comply this would (presumably adversely) affect your consideration of my appeal.

Such a response is not permitted under the BPA Code of Practice and ranks alongside your 4th 'option' of paying 'your' parking charge and appealing which is similarly proscribed under the code.

As your response is extra-procedural you cannot rely upon it to relieve you of your obligation to respond within the 35-day period and I look forward to receiving this reply.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 30, 2023, 01:48:36 pm
It's up to you, the end result should be the same
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 30, 2023, 12:23:52 pm
So just ignore rather than tell them I am not telling them?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 30, 2023, 12:10:41 pm
This is a fairly common response. They're hoping you name the driver so that your argument that they have failed to comply with the requirements of PoFA by not specifying the location is no longer relevant (PoFA only matters in circumstances where they are seeking to recover the charge from the keeper).

Don't tell 'em.

Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 30, 2023, 11:27:36 am
I have now had a response from Parking Eye and it is rather ambivalent. They have not addressed the issue of the vague location at all. They have simply noted that I have not identified the driver and have given me 28 days in which to do so with a vague threat that they might reject the appeal if I don't play ball. To my mind, the vague location argument holds good whether it was me or the unidentified driver who was driving. Seems a bit of a holding tactic and I am minded just to ignore rather than respond and say "I am not identifying the driver but what about the question of vague location?".

Any thoughts?



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Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 16, 2023, 11:50:02 am
Anyway, now sitting back to see what they come back with......
If you appealed online, keep an eye on your email spam folder.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 15, 2023, 07:52:46 pm
Yes, exactly, I think we are all on the same page i.e. the PCN must bear all necessary info if they want the benefit of POFA thus if they have the address just as St Peter's Court it's no good later saying "well, the full address is on our website". This is what I meant by saying "they cannot later adduce further evidence or information". Anyway, now sitting back to see what they come back with......
Title: Re: Private PCN St Michael's Court
Post by: The Rookie on August 15, 2023, 11:02:25 am
Yes, that's really what I was getting at i.e. they can't adduce new evidence/info 
It's nothing to do with 'evidence'.

To be compliant the Notice to Keeper must specify the location.

Its obvious really, for the keeper to be able to contest they must know enough about the allegation to have a chance to do so, if they don't know the location, they can't check the signage etc.etc. to be able to contest it.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 14, 2023, 04:54:25 pm
Oh well, I suppose that's one advance. I imagine the quid pro quo to the PPC industry was "you can't clamp anyone but you can pursue the registered keeper if he refuses to identify the driver".
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 14, 2023, 12:12:43 pm
(who on earth gave it that daft name? Whose freedoms are being protected?)
Bear in mind that the Protection of Freedoms Act is a large piece of legislation, and only one of its schedules relates to parking on private land. Other parts of the act regulate the storage/destruction of fingerprint records by the police and others, the regulation of CCTV use, the protection of property from disproportionate enforcement action, counter-terrorism powers, protecting vulnerable groups, disregarding convictions for outdated crimes like buggery etc., and other measures...

In relation to private parking, the Protection of Freedoms Act also made immobilising vehicles in private car parks an offence. If the case you are currently challenging had happened prior to the introduction of PoFA, the driver may have returned to the car to find a clamp attached, and a private company demanding a fee before they would release it.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 14, 2023, 11:58:09 am
Quite understood. The PCN must be standalone under POFA (who on earth gave it that daft name? Whose freedoms are being protected?)

A reminder of the original PCN turned up in the post today just for good measure....
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 14, 2023, 10:17:42 am
However, this just is not on the face of the PCN and hence I am arguing (or will argue if necessary) that this is inadmissible.
Indeed. To be clear, it's not that the extra information they've included on the appeal website is 'inadmissible' - if the matter goes to POPLA/court, they can include whatever information they so desire. Your argument would be that Schedule 4 of PoFA clearly states that it is the Notice to Keeper that must specify the location, if they want to hold the keeper liable, and that simply stating 'St Michaels Court' does not do this. The fact that further information is provided on their website is largely irrelevant. (After all, not all PCN recipients will visit the website, some will either pay or appeal entirely by post)

So they do maintain the discount pending their reply.
Good to know!
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 14, 2023, 08:40:44 am
Automated response from Parking Eye

Quote
Thank you for contacting Parkingeye, we acknowledge receipt of your appeal.
We endeavour to respond to all appeals as soon as possible. Whilst we consider an appeal the parking charge amount will not increase. Please note that a full written response may take up to 28 days.
Kind Regards,
Parkingeye Appeals Team

So they do maintain the discount pending their reply.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 14, 2023, 07:44:42 am
I have now submitted the appeal on-line along the lines of the draft above. The interesting thing is that when I get into the appeal pages the full address where the offence is alleged to have occurred is shown. However, this just is not on the face of the PCN and hence I am arguing (or will argue if necessary) that this is inadmissible.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 12, 2023, 02:24:52 pm
Yes, that's really what I was getting at i.e. they can't adduce new evidence/info  and have it included in "the process". I was intending to file on-line so with the date of issue being 1 Aug you reckon 14 Aug to file would be safe?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 12, 2023, 01:48:23 pm
Quote
I don't think they can come back and say "sorry, here's the full address with postcode, you have another 14 days to pay the discounted amount."
They can come back with whatever they like, but if they want to engage PoFA to hold the keeper liable, then it's what's on the Notice to Keeper that counts. For a belt and braces approach, you could send your appeal so that it arrives too late for them to issue a compliant notice (so if submitting online, day 13 would do it).
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 12, 2023, 12:44:04 pm
OK I have decided to appeal this one, here's the draft. I fully expect Parking Eye to reject in which case I will take it to POPLA:

Quote
Dear Sirs,

I received your Notice to Keeper 226902/075498 for vehicle VRM LF64SFY of which I am the registered keeper. I was not the driver of the car on the date in question.

You have failed to comply with the requirements of Schedule 4 of The Protection Of Freedoms Act 2012 namely, but not limited to, failing to specify the location of the relevant land as required by section 9 (2)(a) of the Act. It is not possible to determine the location of the alleged breach of your conditions because you have stated the address as just "St Michaels Court". A quick check on Google Maps finds at least nine St Michaels Courts in England including Aylsham, Amersham, two addresses in London, South Shields, Gloucester, Derby, Litchfield and Weybridge. You cannot, therefore, transfer liability for the alleged charge from the driver at the time to me, the keeper.

There is no legal requirement to name the driver at the time and I will not be doing so. I look forward to receiving your notice of acceptance. Should you reject this representation I shall appeal to POPLA. It will not be in order for you to specify the address more closely in a reply. Only the information on the PCN is admissible. Please note I am making this representation within 14 days of issue of the PCN.

I have made up the last bit but hope it's true. I don't think they can come back and say "sorry, here's the full address with postcode, you have another 14 days to pay the discounted amount." But no doubt someone will advise.
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 11, 2023, 01:55:36 pm
I tend not to advise people on their chances at POPLA unless it's clear cut either way (i.e. a near guaranteed success or a guaranteed failure), simply because it's hard to predict which way the assessor will go on a given case, and I don't like to give people either false hope or false pessimism.

The POPLA decision is binding on ParkingEye but not on you. So if POPLA uphold your appeal, ParkingEye must cancel the charge.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 11, 2023, 01:40:32 pm
There is nothing on the PCN about preserving the discount. However the logic from Rookie and DWMB is sound. If we take it that they are going to reject, and if I am minded to pay up if they do, then I might as well pay now. I should say that I am not minded to pay now!

Quite understand the risk/reward argument. If there is at least a 50/50 chance of succeeding at POPLA then it is worth making the appeal. I haven't so far heard anyone say my chances at POPLA are <50% with the vague locus argument.

One further question - if the POPLA decision is not binding on me, is it binding on PE? Or is it just the case that PE would never bother to take it to court once an appeal had been upheld by POPLA?
Title: Re: Private PCN St Michael's Court
Post by: DWMB2 on August 11, 2023, 12:47:28 pm
I don't think there's anything compelling them to uphold the discount. From memory I can't remember if ParkingEye do or not.

But as The Rookie suggests, there's probably a 95% chance they'll reject your appeal regardless of its merits, so you should be prepared to go as far as POPLA if you're intending to fight it.

As I said in my previous reply, it somewhat depends on your attitude to risk. If you pay now, there's a 100% chance it'll cost you £60. If you go to POPLA, there's a chance you'll have to pay £0, and a chance that the full £100 will be in play*.

*Note than POPLA's decision would not be binding on you, if they rejected you can still refuse to pay and have the matter heard in court if ParkingEye choose to pursue it (a loss there would likely be around £200-220)
Title: Re: Private PCN St Michael's Court
Post by: The Rookie on August 11, 2023, 11:54:17 am
Still asking the question - if I appeal to PE within 14 days i.e. by next Tues, will they keep the discount in place pending their reply?
It will tell you on the PCN, but they will reject the appeal anyway (because they can) so it's not a relevant question unless you intend to pay when they reject, in which case you may as well pay now as they will reject.
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 11, 2023, 11:38:13 am
Absolutely! The key to my appeal - could be all over the country. Looking at the case referenced by DWMB on Pepipoo where a rather long street was deemed too vague, a locus that could be in several parts of the country would seem to be a winner but I have never been to POPLA, only PATAS/LTs so don't know how consistent they are. Any views on chances of success?

Still asking the question - if I appeal to PE within 14 days i.e. by next Tues, will they keep the discount in place pending their reply?
Title: Re: Private PCN St Michael's Court
Post by: The Rookie on August 11, 2023, 10:39:09 am
It would help if, when it comes to POPLA, you could find lots of 'St Michaels' court' so as to validate that it's not specific enough.

I readily found Alysham, Amersham, London, South Shields, Gloucester, Derby, Litchfield and Weybridge!
Title: Re: Private PCN St Michael's Court
Post by: Chaseman on August 11, 2023, 12:47:05 am
I have read the case to which DWMB refers on Pepipoo and the draft letter provided by him in that case:

Quote
Dear Sirs,

I have just received your Notice to Keeper xxxxx for vehicle VRM xxxx

You have failed to comply with the requirements of Schedule 4 of The Protection Of Freedoms Act 2012 namely, but not limited to, failing to specify the location of the relevant land as required by section 9 (2)(a) of the Act. It is not possible to determine the location of the alleged breach of your conditions by the wide area covered by the street name and postcode you have given, which contains a number of private and public car parks. You cannot, therefore, transfer liability for the alleged charge from the driver at the time to me, the keeper.

There is no legal requirement to name the driver at the time and I will not be doing so.

I do not expect to hear from you again, or your debt collectors, except to confirm that no further action will be taken on this matter and my personal details have been removed from your records.

Yours etc

I note the keeper was successful in that case because POPLA agreed that the PPC had not specified the "relevant land". In that case the PCN had specified a road but one on which a number of private car parks sat. In my case the PCN gives the name "St Michael's Court" only with no town or postcode. A quick search on Google Maps shows several St Michael's Courts in the country so my argument is that this is even more vague than the Endorfin case. I am minded to use DWMB's template and file an appeal.

Does Parking Eye have to hold the discount open pending their reply?
Title: Re: Private PCN Amersham
Post by: guest179 on August 10, 2023, 10:01:52 pm

The driver" parked the car in a private car park in Amersham controlled by Parking Eye on 27 July.

How do you know? The question is rhetorical but not without purpose. Pl delete all reference to where you guess this breach might have occurred because IMO it undermines the main plank of your defence.

The PCN simply states 'St. Michael's Court'.

Pl amend your thread title. It's not your job as keeper (but not driver) to join up the dots of this PCN.

You are denied the ability to construct a proper defence for want of knowing where the hell it is alleged the breach is supposed to have occurred.
Title: Re: Private PCN Amersham
Post by: DWMB2 on August 10, 2023, 07:02:34 pm
[The driver] parked the car in a private car park in Amersham controlled by Parking Eye on 27 July. She is not now sure whether she paid for two hours and exceeded it, or the limit of free parking was 2 hours and she exceeded that. The PCN does not make it clear either.
I would imagine it is the former - as the PCN states:
"The signage states that, as a paid car park, a Parking Charge is applicable if the motorist fails to make the appropriate tariff payment"

"By either not purchasing the appropriate parking time or by remaining at the car park for longer than permitted....the parking charge is now payable"
I take your point about the 'catch all' phrase being rather vague, although it is standard for ParkingEye charges, and I think it would be an uphill battle to convince POPLA or a judge that the charge is not owed on that basis alone. A counter argument is that the two options describe largely the same thing: if a motorist pays for 2 hours parking and stays for 2 and a half, then they have both not purchased the appropriate parking time and stayed for longer than permitted.

I can obviously appeal citing vagueness of both the offence and the location but I guess Parking Eye will just turn that down automatically.
This might be a more applicable avenue. You're right that the location is rather vague - St Michael's Court isn't a particularly unique name for a location, and without a town or postcode it could refer to a number of locations. In order to hold you liable as the keeper (rather than holding the driver, who they do not know, liable), they need to comply with Schedule 4 of the Protection of Freedoms Act. 9(2)(a) of that Act says they must

"specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates"

You could make an argument that they have failed to specify the land with their vague description. I'm not aware of any authority/cases that have provided a definition of what is required in order to satisfy this requirement. On issues that aren't clear cut, it can be hard to predict which way POPLA will go, so it depends somewhat on your attitude to risk. Some useful background reading from over on PePiPoo: http://forums.pepipoo.com/index.php?showtopic=144900 (http://forums.pepipoo.com/index.php?showtopic=144900) - in that case (involving UKPC), the notice simply stated a road and a postcode. The road in question was rather long with multiple private car parks, so the appeal largely centred on a failure to specify the relevant land.

If you're going to go down this route, show us a draft of your proposed appeal before sending anything.
Title: Private PCN St Michael's Court
Post by: Chaseman on August 10, 2023, 06:06:52 pm
"The driver" parked the car in a private car park controlled by Parking Eye on 27 July. She is not now sure whether she paid for two hours and exceeded it, or the limit of free parking was 2 hours and she exceeded that. The PCN does not make it clear either. Under Parking Charge Information it states "By either not purchasing the appropriate parking time or by remaining at the car park for longer than permitted....the parking charge is now payable"

First this catch-all sort of wording to describe the "offence" would not be permissible in a Council PCN. Secondly the location is given only as St Michaels Court. No address, no town, no postcode. The ticket turned up while the driver was away and I had no idea where the place was so I Googled it and deduced it was Amersham. The car's V5 is in my name. I can obviously appeal citing vagueness of both the offence and the location but I guess Parking Eye will just turn that down automatically. I have no experience of the procedure for appealing to POPLA.

Questions:


I can delay things by writing to PE and stating that I am the RK but was not the driver and giving them the name of the driver but does this risk the discount and is there any point?
Presumably if one appeals to POPLA the full penalty of £100 is at risk? Any views on the likelihood of success there?
If I just ignore the thing altogether I presumably will get increasingly threatening letters referring to bailiffs and court summonses but are they actually likely to follow through on any of this?

GSV unfortunately dates from Sep 2018 when it may have been under control of a different contractor

https://www.google.com/maps/@51.6783501,-0.6044512,3a,45y,317.68h,91.05t/data=!3m6!1e1!3m4!1sgk6MB5utBikTYKU7_FlJog!2e0!7i13312!8i6656?entry=ttu

https://imgur.com/a/gWxfyQi