Your draft is absolutely fine in terms of direction and you are nowhere near FUBAR. It hits all the right points and keeps the driver anonymous.
If you want to tighten it, I would only suggest very minor tweaks rather than a full rewrite:
1. In the first paragraph, you could add a short line to make it explicit that the visit was invited, for example “The driver was an invited visitor to a lawful resident of the estate.” That reinforces that the car was not an interloper.
2. Where you refer to the “industry Code”, you might change that to “the applicable Code of Practice” so it cannot be argued that you have referred to the wrong document. The point about a minimum consideration period still stands without naming any specific Code.
3. After the paragraph about the prohibitive wording, you could add one short sentence such as “In those circumstances, the only possible allegation would be trespass, which only the landowner could pursue, not UKCPS.” That underlines the “no contract” point.
4. I would keep the PoFA section exactly as you have it. It is clear, accurate and firmly states that you will not be naming the driver.
5. At the top of the text, when you paste it into the portal, make sure the appeal is clearly in the name of the registered keeper and that you select “other” and do not tick anything that suggests you were the driver.
Attach the photo showing the VP bay and the neighbouring numbered bays as you planned, submit it and then sit back. This is as strong and concise a keeper appeal as UKCPS are likely to see.
Appealing on day 13 specifically for the sake of the mugs “discount” is, bluntly, pointless. With UKCPS (IPC member) the “appeal” is guaranteed to be rejected anyway and they routinely re-offer the reduced amount in the rejection. The only thing you needs to care about is:
– getting a solid keeper appeal in within the stated appeal window; and
– not naming the driver.
Whether that goes in on day 3, 10 or 20 doesn’t change the legal position at all. You shouldn’t be trying to game the mugs discount clock; you should be assuming you will never pay a penny and that this will be fought if necessary.
On the property managers, they need something more forceful. Right now the managing agents have fobbed you off because the request was too “polite please help” and not “you are the principal, this is your mess, fix it”.
Can you get the resident you were visiting to send something along these lines (with you copied in):
Dear [Name],
I am the leaseholder/tenant of [full address]. On 23/11/25 my invited visitor parked in the bay marked ‘VP’ directly outside my property. My own allocated bay is [number]. UKCPS have issued a Parking Charge Notice alleging that a permit should have been displayed.
I have never been provided with any visitor permits, nor have I ever been informed of any visitor-permit scheme. The bays on this estate are either numbered (allocated to specific properties) or marked ‘VP’, which any reasonable person would understand to mean ‘Visitor Parking’. There is no clear signage at the VP bay explaining that visitors must obtain or display a permit, nor how they could possibly do so. My visitor has parked in that VP bay on previous occasions without issue.
UKCPS are your contractor, not mine. They act on your instructions and for your commercial benefit. It is unacceptable that my invited guests are being threatened with £100 charges for using what is plainly marked as a visitor bay, in circumstances where no visitor permit scheme has ever been communicated to me. This amounts to harassment of my visitors and an unreasonable interference with my right to receive guests.
As principal, you are fully able to instruct UKCPS to cancel this charge. I require you to do so and to confirm in writing that invited visitors may park in VP bays without penalty unless and until a clear, fair and properly communicated visitor-permit scheme is put in place.
If you refuse to intervene, please confirm:
– who within your organisation authorised UKCPS’s operation on this estate;
– a copy of any policy that explains how VP bays are intended to be used; and
– why you consider it reasonable to allow your agent to pursue my invited guests for £100 for using what is signed on the ground as visitor parking.
If this matter is not resolved promptly I will escalate my complaint to the freeholder and, if necessary, consider taking advice on your liability for the actions of your contractor.
Yours faithfully,