Free Traffic Legal Advice

Having previously received a LETTER OF CLAIM dated 22/04/25, I have today
received a LETTER BEFORE CLAIM dated 16/04/26.  Copy here https://ibb.co/HDQXZYLm

Confusingly they have created a distinct new reference number (vs the one on Letter of Claim last year), but I have checked on their portal and it links to the same parking incident.

Last year's Letter of Claim was responded to as instructed here, and Moorside responded with:

"Our client: UKPS Ltd
We write further to our recent email.
Our answers to your questions are as follows:

The additional charge which has been levied on your Parking Charge of £70  is the amount set out in both the British Parking Association and International Parking Community Codes of Practice as the amount which may be added to a Parking Charge when a Parking Charge remains unpaid and when further recovery is required. Our Client is a member of the IPC which is a government approved Accredited Trade Association (ATA) for Private Parking. Our Client adheres to the ATA’s Code of Practice. The £70 does not represent the cost of recovery but is a reasonable amount in relation to the Parking Charge amount, in order to encourage early payment of the Parking Charge without the need for debt recovery. It is a fair amount set by our Client’s government-approved Accredited Trade Association Code of Practice. There are however also costs incurred by our client in relation to debt recovery services.

By entering and parking the vehicle on our client's private land, you agreed to enter into a contract with our client and to be bound by the terms and conditions of that contract. The terms and conditions were clearly displayed at the entrance and in prominent places within the car park. Due to your failure to comply with the terms and conditions, our client has issued the PCN therefore if we are instructed to issue a claim the reason would be for Unpaid parking charges/ breach of contract.

In accordance with our client’s instruction, we are obliged to make proportionate attempts to contact you to request payment be made, inform you of the next steps if you choose not to make payment, and to serve documents if we are instructed to do so.
We have removed your email address and telephone number from our case management system. However, we are obliged to send you correspondence regarding the debt and potential legal proceedings, which our client is entitled to pursue for payment. We still need to send you letters to serve legal documents and communicate regarding the matter therefore communications via letter will continue.
We are satisfied that our correspondence does not amount to harassment under section 1 of the Protection from Harassment Act 1997.

You may wish to seek independent legal advice.
Yours sincerely
Moorside Legal"

Can anyone confirm if this new "Letter Before Claim" changes anything or requires any response from me?

As imgur no longer working I have re-uploaded the earlier documents to:

Original notice:
https://ibb.co/Swy9tb3k
https://ibb.co/pg9hPQh
https://ibb.co/RkC6nD0L
https://ibb.co/6cgg28bm

Letter of claim:
https://ibb.co/9kwrKLFS
https://ibb.co/VWT3GzvM
https://ibb.co/nsqp5pZ8

UKPS internal appeal rejected:

"Thank you for your appeal.
 
Having noted your comments, and checking the evidence gathered when issuing the Parking Charge, we are satisfied that the Parking Charge has been issued correctly and your appeal is rejected.
 
The basis of your appeal is factually incorrect, this parking charge has been issued in line with POFA 2012 and as a result, we will continue to hold the registered keeper liable for this charge unless we are informed that someone, other than the registered keeper was driving. The terms and conditions of this private land state that a permit must be held to park on site. This private land is not a dropping off or picking up area for commuters. Drivers are given a consideration period to read the signage and to make an informed decision as to remain on site or leave, if this consideration period is used in any other way than what it was meant for, the charge is issued.  As the vehicle does not hold a permit, the terms and conditions were breached.
 
Please be advised that all photographic evidence can be viewed by typing: pay.theukps.com in to your top address browser.
 
We now require payment of the parking charge to be made within 28 days of this letter."

Check to see what evidence they have that the vehicle was at the location for 34 seconds. If they've only a single photo, they can't even even prove that it was there for more than 1 second.

Entry and exit photos have timestamps from which I calculated the 34 seconds, the PCN itself does not mention the duration.

They also have (less clear) CCTV appearing to show passenger leaving vehicle, but timestamp of CCTV is not synchronised with the entry and exit photos - with the passenger appearing to disembark (in the CCTV) after the vehicle left the site (according to main photo).     

Keeper received PCN from UKPS for "contravention of terms: Permit Required" at Eaton House near Coventry Railway Station, see https://imgur.com/a/aXDxnV7

Looking at date/time stamps on images the driver was on site for 34 seconds total.  In this time it appears they drove onto site, possibly dropped a passenger, performed a three point turn, and then left site.

Keeper has not responded to PCN. 

Also in images is sign from car park, and a view from the street entrance.

Appears to be a couple of points:
1) 34 seconds on site is nowhere near long enough to try and read and agree to the terms and conditions.
2) There are no entrance signs to site and the signs within site are not large.
3) PCN does not appear to comply with all aspects of PoFA section 9.

Next step (if any) for keeper?