Free Traffic Legal Advice

It certainly is a stronger ground for appeal than most. The images look like they were taken by someone on foot (hence observation time) so I can't see how they deduced you exceeded the consideration period or in fact stayed for over an hour.

However they are IPC members.........

Point 1 all fine as long as the POPLA assessor agrees with your assessment the PCN breaches POFA requirements. As b789 who gave you that defence argument loves to point out POPLA assessors are not legally trained and are unlikely to get into the semantics of the wording.

Point 2 that's how the industry works, this will not help with getting POPLA to uphold your appeal.

Point 3 see point 1.

Point 4 may be valid, unlikely a POPLA assessor will agree, Parkingeye signage is often held as best practice.

Point 5, I know this car parking having parked the myself. To call it barrier controlled is pushing the concept, from memory it's a couple of manual pole type barriers. Whether they were open or not doesnt materially impact your case. Most car parks don't have barriers, you can assume that means parking restrictions aren't in force.

Point 6 The wording is indeed clumsy but is factually correct, there is a max stay of 0 minutes being offered (consideration period not withstanding),  contractually if you stay longer you agree for them to invoice you at the rate on the signage.

Point 7 let's see what the POPLA assessor thinks.

Bottom line is you don't have any strong grounds for appeal here, the POPLA  appeal is just going through the motions of running the clock down until they (probably) give up before having to pay a court fee.

And calm down, referring to them as thieves isn't helping or appropriate. The fact their letters were going to an address you didn't have regular access to is on you. If it had been a NIP you'd be in a lot more trouble.

Provide the information requested above, this could well hinge around the availability to register at their kiosk but we need the facts to guide you

As above you can probably avoid paying them if you play the long game although the fact you have 3 PCNs means they may actually go all the way to court.

Ok

Paragraph one, fine, but not in anyway relevant if they intend to use POFA to hold the keeper liable.

Paragraph 2

You're suggesting their standard letter is rubbish, they won't agree. They've also already decided the photos are good enough to send the PCN.

Paragraph three

Thats how all ANPR companies operate, this argument won't win any appeals.

Paragraph 4

The burden of proof will lie with you that the vehicle left and re-entered within the alleged parking period. Their argument would be they don't have evidence of the vehicle leaving and returning which if true would mean they can't prove a negative.

Paragraph 5

Date of incident was 22/12/25, date of notice was the 30/12/25, they are normally deemed delivered 2 days after the date of the notice which even taking into account the bank Holiday is within the 14 days, they actual date of delivery isn't important.

Paragraph 6

Grace periods are not published or disclosed. However in this case free parking was 30 minutes, grace would be a minimum of 10 minutes making 40 minutes, car was in the car park for 53  minutes.

So in summary it's a nicely worded appeal with no points that are likely to get them to grant the appeal. Some of those arguments may have merit if it ever got to court, the quality of the images for example (POPLA might agree that point as well).

So submit it, expect a rejection and POPLA code, try again at POPLA focusing on image quality, probably lose, wait for the debt collectors letters and possible LoC and expect it to go away before it gets to court. Just don't get you hopes up on an initial appeal.

Despite what is often said on here, many appeals do get granted (depends a lot on which PPC), but those appeals have genuine grounds such as frustration of contract, missing signage, minor keying error, genuine double dip, POFA timescales not complied with etc. Just not wanting to pay a PCN isn't enough. The basis on which PPCS operate is legitimate even if the behaviour of some is not.

In many respects it doesnt matter what grounds you use to appeal, it appears the PCN is POFA compliant so they can hold the keeper liable. You haven't given us any reasons why the driver legitimately breached the terms & conditions such as breakdown or medical issue. b789s usual approach is to send in an official sounding defence based on perceived difficiencies in the PCN which rarely if ever works other than to engage with the process, running the clock down and assuming the PPC will give up before court.

In your case I'm not sure the NTK even contains the alleged flaws b789 usually uses as a vehicle to word an appeal. Your best bet is just to say you were a genuine patron of the retail park but I would expect that to be rejected. Bottom line is you dont actually have grounds to challenge the PCN unless there is something you haven't told us, others may have better ideas.

"ECP will reject your appeal (because they always do) "

Do they? You've more chance of getting an appeal granted with the wording above than the usual attempts to argue over the fine print of the PCN.

Contacting the Leisure centre should be your first point of call, and quickly. If not submit that appeal, you may get lucky, or be offered the £20 discount rate for a major keying error. The driver's inability to follow the rules has actually cost ECP real money to issue the PCN, people might not be very sympathetic about that but it's a reality.

I thought that if the licence is not visible then they can't evidence that the car came in at that time. As such they can't prove the vehicle stayed more than 30mins.

Is it worth appealing to the shops in the promenade (eg Tescos, boots) or is that usually pointless?

The images were clear enough for the ANPR software to correctly read the plate.

You can try one of the retailers but in this situation it's whoever actually manages the site that you'd really need to speak to (although Tesco would be my first point of call as the biggest retailer there but Retail Park are not the company they normally use suggesting it's the managing agent who contracted the PPC). What justification would you give for requesting they cancel the PCN? Usually people exceed a maximum stay as they are making a big purchase and can evidence that. In this case you would have been expected to pay if you exceeded the 30 mins free so I can't see that being accepted.