Respond to their prima facie evidence with the following which you can copy and paste verbatim:
Response to the operators prima facie evidence/case:
1) No keeper liability: this is not “relevant land” under PoFA – and in any event PoFA has not been strictly complied with:
• Maintained school = public authority site. Cranbrook Primary is a maintained (community) school of the London Borough of Redbridge. The premises are under public authority control and occupation. Private parking firms don’t magic that into “private relevant land” by stapling on a services contract. PoFA Schedule 4 excludes land where parking is “subject to statutory control”. School sites sit within the Council’s statutory framework and governance; any parking arrangements/authorisations arise from (and are constrained by) public law duties, not private whim.
Your “no TRO, therefore relevant land” line is garbage. The absence of a TRO doesn’t prove relevance. “Statutory control” in PoFA isn’t limited to TROs or byelaws. Show contemporaneous documentary proof that, on 18/07/2025, this site wasn’t (a) owned/controlled by the local authority for the purposes of education; (b) managed by or on behalf of that authority; and (c) regulated under any statutory framework/policy that governs use of school premises (which it is). You’ve produced nothing—just assertions.
Burden of proof is yours. If you want to rely on keeper liability, you prove relevance with evidence, not bluster. That means:
• Land status/ownership (Land Registry or Council confirmation);
• The governing body/LA delegation showing who controls parking and under what statutory footing;
• A positive statement (with citations) that the parking of vehicles at this location is not subject to any statutory control/policy/instrument on the material date.
You’ve filed zero of the above. Keeper liability fails at the starting gate.
Even if (which is denied) this were relevant land, PoFA still isn’t met. You haven’t exhibited the NtK or walked the assessor through strict Schedule 4 compliance. Fail any of these and keeper liability is dead:
• 9(2)(a): A period of parking (ANPR entry/exit ≠ parking period).
• 9(2)(b)–(d): Circumstances/charge/when payable (exact statutory content).
• 9(2)(e)(i): The invitation to the keeper (correct wording).
• 9(2)(f): The warning of keeper liability after 28 days (correct wording).
• 9(2)(h): Creditor identity (who is the creditor?).
• 9(2)(i), 9(5): Service within the relevant period and proof of posting (PPSCoP 8.1.2(d) Note 2 = record of date of posting, not just “generated”).
You’ve dumped a narrative and hid the paperwork. That’s not compliance.
Your boilerplate about PoFA 9(2)(f) is meaningless without the actual notice. Put the full NtK in evidence and point to the precise lines that meet each statutory limb—or stop pretending you’ve established keeper liability.
Reality check for the IAS: an assertion that “this is relevant land” is not evidence. If the IAS is prepared to accept keeper liability on a maintained school site without hard proof of relevance and without line-by-line PoFA compliance, then you’re not applying PoFA—you’re just waving it around.
1) 30-minute site concession + mandatory 10-minute end-of-parking grace (PPSCoP 5.2) = still no breach
Your own numbers now say 37 minutes on site. This location runs a 30-minute drop-off/collection concession. Under PPSCoP 5.2, when a permitted period ends the motorist must be given a minimum 10-minute grace period to leave—unless this is a genuine “short stay area” where parking is never allowed for more than 30 minutes for anyone. It isn’t.
Not a short-stay zone, so Note 2 doesn’t apply. This site’s normal regime allows longer stays via Sippi/e-permit (selecting up to 12 hours for £0.00 has already been documented). A car park that routinely permits multi-hour stays is by definition not a Note-2 “short stay area”. So the 10-minute end-of-parking grace applies.
Concession = permitted time. The 30-minute drop-off/collection is an express permission the site advertises. It’s part of the terms. The grace sits on top of that permitted time. Maths even the IAS can follow: 30 + 10 = 40 minutes before any charge can lawfully be triggered.
Your figure buries your own case. You now claim 37 minutes total. That’s within the 40-minute allowance. End of story: no contravention on your own evidence.
If you want to wriggle out of your own concession, prove it. Produce dated, contemporaneous signage and policy for 18/07/2025 showing (a) the 30-minute concession didn’t apply on that date or (b) this site was operating as a true Note-2 short-stay area with a universal ≤30-minute max stay. If you can’t, you don’t get to pretend the concession vanishes when you fancy issuing a PCN.
Ambiguity = your problem. Any fuzziness in your signs or “policy” about when the concession applies is construed against you. You drafted it; you live with it.
Bottom line: 37 ≤ 40. Your own timing nukes the charge.
This PCN has been issued incorrectly and must be cancelled.
Also I know it stated taht most of these will eventually have some form of debt letter then fail to go through to County Court, however I've just seen a post that's before mine for 'Gladstones' where OP states they've received a County Court Claim from Euro Parking Services Limited :O and it totals £257.50 - So worst case scneario I could end up having to may a similar amount if I am unable to fight the final stage at county court?
Just because a claim is issued does not mean that it will ever get as far as a hearing. These companies all rely on you being low-hanging fruit on the gullible tree who can be intimidated into paying up out of ignorance and fear. Unless you understand their modus operandi and your lawful rights like we do, then good luck to you.
As long as you don’t identify the driver they can’t use PoFA 2012 as they continue to claim.
If at any point I am asked if I was the drive, would that mean one has to say no or decline to comment, ie nor confirm nor deny?
There is no legal obligation on the Keeper to identify the driver to an unregulated private parking firm. There is no need to lie either. All you do is refer to the driver in the third person. No "I did this or that", only "the driver did this or that". Understood?
If the operator is unable to rely on PoFA to transfer liability from the unknown (to them) driver to the known Keeper, the burden of proof is on them, not you. How do you imagine that can prove you were the driver if you decline to assist them by identifying the driver for them?
I have just submitted the following FoI request to foi@redbridge.gov.uk
Did you ever get anything back from the FOI request for this?
Yes, and it was a non answer which I have complained about and asked for a review:
(https://i.imgur.com/8QGNRuh.jpeg)
(https://i.imgur.com/Mb797av.jpeg)
And my response, to which they have not yet replied:
Subject: Request for Internal Review – FOI Ref: 29095861
Dear FOI Team,
I am writing to request an internal review of your response to my Freedom of Information request regarding the contracting of UK Car Park Management (UKCPM) at Cranbrook Primary School.
Your reply stated that the information I requested is not held by the London Borough of Redbridge and advised me to contact the private parking firm directly. I believe this response is inadequate for the following reasons:
1. Failure to confirm land ownership and delegation
Even if the Council does not hold the UKCPM contract itself, you are still able – and obliged – to confirm whether the land in question is Council-owned or controlled, and if so, whether any delegation has been granted to the school governing body to enter into such arrangements. This is relevant context squarely within the scope of my request.
2. Duty to advise and assist (s16 FOIA)
The Section 45 Code of Practice requires public authorities to advise and assist applicants. Directing me to contact a private company that is not subject to FOIA does not satisfy this duty. You should instead have identified or signposted the correct public body likely to hold the requested information – in this case, the governing body of Cranbrook Primary School – or considered whether a transfer under FOIA was appropriate.
3. Incomplete handling of the request
My request covered not just the specific contract with UKCPM but also any agreements, delegations, or authorisations by the Council concerning parking enforcement at this location. These are matters the Council is in a position to confirm.
I therefore request that the internal review addresses:
• Whether the land at Cranbrook Primary School, including the car park, is owned or controlled by the Council.
• Whether the Council has delegated authority to the school governing body to enter into parking enforcement arrangements.
• Whether the Council holds any records, correspondence, or authorisations relating to the introduction of private parking enforcement at this site.
• Proper signposting or transfer to the public body that does hold the requested contract (likely the school/governing body).
Please ensure this review is conducted in line with the FOIA Code of Practice and completed within 20 working days.
Yours sincerely,
B789
For now, you can submit the following as your IAS appeal (for what it's worth):
This appeal addresses the operator’s rejection and explains why this PCN cannot lawfully be enforced.
1. Keeper liability cannot apply (land is not “relevant land”)
Under PoFA Sch 4 para 3(1)(b), a parking place provided or controlled by a traffic authority is excluded from “relevant land.” Para 3(2) defines a traffic authority to include a London borough council. Cranbrook Primary School is a community school on land owned and controlled by the London Borough of Redbridge. Control therefore rests with a traffic authority, excluding the site from relevant land. In the alternative, para 3(1)(c) excludes land where parking is subject to statutory control; this site is governed under the Education Acts and controlled by a London borough exercising statutory powers. PoFA keeper liability cannot arise on this land.
2. Standing not evidenced (PPSCoP §14)
The operator refuses to disclose the landowner agreement yet relies on it to found authority. PPSCoP §14.1(a)–(j) requires written confirmation from the landowner covering identity, boundary plan, applicable byelaws, permission and duration, applied terms, method of issuing charges, responsibility for consents, Code-compliance obligations, documentation to be supplied on request, and approach to appeals. These are core standing documents. Redactions for pricing are acceptable, but the authority clauses, boundaries, byelaw status, scope/duration, operative terms, and method of charge must be evidenced. Absent this, standing is not proven.
3. Contravention not proven: ANPR and “37 minutes”
ANPR records site entry/exit, not a period of parking. The operator must evidence a period of parking and also demonstrate compliance with consideration and grace periods required by the PPSCoP. Strict proof is required of ANPR reliability, maintenance, calibration, and clock synchronisation, and (if relevant) patrol notes. None has been produced. Assertions are not evidence.
4. “No permit found” requires strict proof
If relying on a permit system, strict proof is required of the audit trail: the query performed, timestamps, system clock synchronisation with ANPR, and the data extract showing no valid permission at the material time. A generic “no permit found” statement is insufficient.
5. NtK service and PoFA compliance (only if PoFA is claimed)
If the operator seeks to rely on PoFA notwithstanding point 1, strict proof is required of a fully compliant NtK (including para 9(2)(a), 9(2)(e), 9(2)(f)) and proof of posting/service within the relevant period (PPSCoP 8.1.2(d) Note 2 requires a record of the date of posting, not merely the date of generation or consolidator handover). No such proof has been provided.
6. Annex F “Appeals Charter” is irrelevant to liability
Whether the case falls within Annex F does not determine enforceability. Liability depends on (i) applicability of PoFA, (ii) operator standing, and (iii) proof of contravention with compliant evidence. None is satisfied here.
Conclusion
Because the site is not relevant land, PoFA keeper liability cannot arise. In any event, the operator has not proven standing under PPSCoP §14, has not proven a period of parking or ANPR reliability, has not strictly proven the “no permit” allegation, and has not proven NtK service/compliance if they seek to rely on PoFA. The PCN should be cancelled.
I have just submitted the following FoI request to foi@redbridge.gov.uk
Dear FOI Team,
Under the Freedom of Information Act 2000, I request the following information regarding parking enforcement at Cranbrook Primary School, The Drive, Ilford, IG1 3PS:
Has the London Borough of Redbridge, or any delegated authority thereof, contracted UK Car Park Management (CPM) to operate parking enforcement services at the above site?
If so, please provide:
• The name of the contracting party or authority.
• The date the contract was initiated.
• The scope and duration of the contract.
• A copy of the contract or agreement (with any necessary redactions).
If CPM was contracted by the school directly, please confirm whether the school had delegated authority from the borough to enter into such an agreement concerning land use and enforcement.
This request concerns the legitimacy of private enforcement activity on land that appears to fall under local authority control. Please treat this as a matter of public interest and procedural accountability.
I look forward to your response within the statutory 20 working days.
Yours faithfully,
B789
This will establish who to make an official complaint to about the fact that CPM are acting unlawfully by issuing PCNs claiming Keeper liability under PoFA.
As CPM are clearly breaching the PPSCoP section 8.1.1(d) this also warrants a formal complaint to the DVLA, if only to establish a paper trail about their breach of the PPSCoP and therefore the KADOE contract.