Free Traffic Legal Advice

You say you appealed on behalf of the Keeper... in what capacity?

Their authorised representative.  I have a properly executed Letter of Authorisation which was included with the original appeal.

The operator has now missed the PoFA window for keeper liability. For a windscreen NtD, PoFA Sch 4 para 8 requires a postal NtK to be delivered to the keeper not earlier than day 29 and not later than day 56 after the event.

• Parking event: 11 Aug 2025 (Day 0)
• Earliest lawful NtK delivery: 8 Sep 2025 (Day 28 after; delivery Day 29)
• Latest lawful NtK delivery: 6 Oct 2025 (Day 56)
• No NtK was ever delivered. Today is 14 Oct 2025 (Day 64), so the operator has forfeited the right to transfer liability to the keeper under PoFA.

An appeal/rejection (even if addressed to the RK) does not count as, or extend time for, an NtK. Because “delivered” is the test, the last practical posting date would have been Thu 2 Oct 2025 (allowing two working days’ deemed service to land by Mon 6 Oct).

Conclusion: they can pursue the driver only; keeper liability under PoFA is no longer available.

Use that as the core of your IAS appeal, for what it's worth. Irrespective of the alleged contractual breach is, they cannot hold the Keeper liable for the charge if the driver is no identified.

As the IAS is a kangaroo court and their adjudicators are anonymous liars who pretend that they are qualified solicitors (they aren't), they are very likely to reject the appeal on the legally embarrassing grounds that they think they can infer that the Keeper must be the driver.

If the IAS rejects the appeal, so what? Their decision is not binding on the Keeper and they can try and issue a claim in the county court where they wouldn't stand a chance of winning against the Keeper as log as the driver is not identified.

Thank you for your continued assistance.

For the sake of continuity and in the name of completeness, I'll post further updates as they occur.

Thanks again.

Regards

O

As predicted by those here that commented, the appeal has been rejected.

Here's the contents of the response:

<Quote>
Date of Posting: 16 September 2025
Parking Charge Reference Number: <redacted>
Vehicle Registration Number: <redacted>
Location: Jamai/ca Street Car Park, 16-28 St James Street, Liverpool, L1 0AB
Issue Date: 11/08/2025
Reason for Issue: No Valid Payment
Balance Due: £60.00

Dear <registered keeper's first and middle name>

Thank you for your appeal against the above Parking Charge.  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 for the reason(s) detailed below:

As per the terms and conditions of the car park - Vehicles must display a valid pay and display ticket, and valid permit in the windscreen with all of the details clearly visible, or have a valid e-permit registered to the vehicle in question.
Our evidence shows that, at the time of the vehicle inspection, there was no valid ticket/permit/e-permit for your vehicle contrary to the displayed terms and conditions, and pursuant to these terms, a parking charge was issued at 00:27.
We have noted the contents of your appeal but would advise it is the responsibility of the driver to ensure payment is made to cover the full period of parking on site via one of the available payment methods.  At the time of the inspection there was no valid payment in place and a parking charge was issued accordingly.
In light of the situation and as a gesture of goodwill we have reduced the balance back to £60 for 14 days only to allow payment at the lower rate.  Please ensure payment is made during this period or the balance will revert to £100.
As you have breached the terms and conditions of parking, you are now required to pay the contractually agreed charges as stated on our signage.

We now require payment of the parking charge to be made within 28 days of this letter.
If you believe this decision is incorrect, you are entitled to appeal to the Independent Appeals Service (IAS).  In order to appeal you will need your Parking Charge number and your vehicle registration.  Appeals must be submitted to the IAS within 28 days of the date of this letter.  Please visit www.theias.org for full details.

<CENTRED RED TEXT> IMPORTANT NOTE </>
Please note you cannot appeal this charge to the IAS if it is paid.  Should you decide to appeal to the IAS and your appeal is subsequently rejected, the option to pay a discounted amount will no longer be available and the full amount of the PCN will become due, payment should be made to the Operator within 28 days from the date of the IAS rejection notification.

For free advice regarding your parking charge, including advice on appealing, please visit: www.247advice.co.uk

Regards

<Unreadable signature>

Please see overleaf for 'How to Pay'
<end quote>

I am inclined to appeal to the IAS using the points set out in the post by b789 on 10th September, namely the parts of POFA Schedule 4 against which the NtD was non-compliant.

Would this be an advisable course?

Any other hints, tips, or advice please?

Thanks

Regards

O

I've modified the post as suggested.

The Parking Charge Notice is issued on thermal paper and in a tiny font.  It is therefore difficult to photograph, but I have posted a copy of the entirety of the PCN below:

<PARK PAY LOGO> Parkpay Services Ltd, www.paymypcn.net

PARKING CHARGE NOTICE
Notice to driver of breach of terms and conditions
of parking as detailed on the signage at site

PCN Number : <redacted>
Date of Service: 11/08/2025
Period of Parking: 00:27
Observation from: 00:22
Observation to: 00:27
Vehicle Reg No: <redacted>
Vehicle Colour: <redacted>
Vehicle Make: <redacted>
Parking Attendant: Abs
Location: Jamaica Street Carpark, 16-26 Ja
REASON FOR ISSUE: No Valid Payment

The Driver is required to pay a charge of £100 reduced to £60 if paid within 14 days

How to pay your parking charge notice

Online: Pay securely 24 hours a day at www.paymypcn.net

Bank: High Street or online banking
Sort Code: <redacted>
Account Number: <redacted>

This is a parking charge notice issued on private land.  Payment of this charge may be pursued by the operator through legal means including the courts, which may result in you incurring additional costs if unpaid.

You can appeal against the charge by writing to the car park operator.  If you are not satisfied with the outcome, you can make a further appeal to the Independent Appeals Service (IAS).  Details are given elsewhere on this notice.

The car park operator has agreed to adhere to an AIA Code of Practice.

For free advice regarding your parking charge including advice on appealing, please visit www.247advice.co.uk

I don't know how it happened but the post has been truncated and the bottom section of the PCN was omitted from the previous post.

After the above the PCN continues:

APPEALS
In the event that you wish to dispute liability for this Parking Charge, within 28 days beginning with the date after that on which this notice is given, please provide your full name and address, vehicle registration number and the Parking Reference at the top of this notice providing your full reasons.

Appeal decisions should be provided within 28 days.  Where an appeal is submitted within the 14 day timeframe to pay at the reduced rate, and subsequently rejected, you will have a further 14 days to make payment at the reduced rate.  Please note where payment is made this will preclude any ability to appeal.

In the event that your appeal is unsuccessful then we will provide you with appropriate details enabling you to lodge an appeal to the Independent Appeals Service.  Details of the appeal procedure can be found at www.theIASorg

The Independent Appeals Service (www.theIAS.org) provides an Alternative Dispute Resolution scheme for disputes of this type.  We will engage with the IAS Standard Appeals Service providing you comply with our internal appeals procedure as detailed herein and that thereafter you lodge an appeal to the IAS within 28 days of rejection.  If you choose to appeal to the IAS you will lose the ability to pay the charge at the reduced rate.  If you do appeal and do not hear from us within 28 days, then please contact us, do not assume that your appeal has been successful.

HOW TO APPEAL:
Online: www.paymypcn.net
EMail: appeals@paymypcn.net
Post: PCN Parking Solutions, PO Box 5419, Hove, BN52 8AN

YOU MUST SUPPLY YOUR NAME AND POSTAL ADDRESS FOR APPEALS TO BE PROCESSED.

COMPLAINTS
Please note if you wish to challenge the validity of this charge then you must use appeals procedure detailed above.  Other issues can be dealt with under the complaints procedure.

If you wish to complain you MUST complain to us in the first instance by writing to us at the address PO Box 5419, Hove, BN52 8AN.  If you are not satisfied with our response, then you may refer your complaint to the IPC.  Further details can be found at www.theIPC.info

Registered Keeper Details and Data Processing
We have obtained your personal details including the vehicle registration number and in the event that payment is not made in full within 28 days of issue of this Parking Charge, the vehicle's keeper details may be requested from the DVLA and a notice may be sent to the registered keeper.

Where enforcement action is necessary, your details may be passed onto debt recovery companies and/or solicitors for the purpose of pursuing the outstanding charges.  If enforcement action is necessary, then there may be additional charges added to the outstanding amount.

We comply with the DVLA requirements on data release and only retain / process information for the purposes for which it was obtained and in accordance with data protection laws Data Protection Officer - dpo@park-pay.co.uk

For more information please view our Privacy Notice by visiting https://park-pay.co.uk/privacy-policy/

IF YOU FEEL YOU HAVE A RIGHT TO OBJECT UNDER GDPR REGULATIONS IN ANY WAY THEN YOU CAN CONTACT US WITH YOUR CONCERN

[IPC Logo]  ParkPay Services Limited
A member of the International Parking Community

Registered in England and Wales Number: <unreadable>
Registered Office: <unreadable>

This wouldn't stand up ion court. Payment was made for the full duration the vehicle was parked. There is no loss to the landowner.

Please tell us the name of the parking firm. They are an IPC operator which means that they are unscrupulous and are only interested in your money, irrespective of the facts.

With respect, I believe you are misunderstanding the meaning of the word "loss".

Whilst the landowner needs to show evidence of the loss they have suffered, in addition to a "loss" being unpaid parking fees it can also cover the administration costs of issuing the PCN which I shall remind you, for the avoidance of doubt, was issued at or around 00:25 by a person visiting the car park, observing the vehicle for at least 5 minutes, taking several photographs and then issuing a PCN.

If the landowner can show costs associated with the parking attendant visiting the car park at this time and issuing the PCN, then my understanding is that they have a demonstrable loss.

The parking firm concerned is ParkPay Services Limited.

Regards

O

As stated in the OP and subsequent follow-ups, the PCN was issued by a person and affixed to the windscreen meaning references to exemptions applicable to ANPR are, sadly, not relevant.

Some searching since the PCN was issued seems to suggest that the firm in question manage a number of car parks in Liverpool all of which have a ticketing system that expires at 23:59.

Similarly, it seems that a parking attendant visits the car parks shortly after midnight armed with a list of vehicles whose tickets have just expired.

I suspect that this is produced from the web-site and may explain why it is not possible to purchase a ticket just after midnight.

In the instant case, there is a difference of one minute between the PCN being issued at 00:27 and a ticket being purchased via the web-site at 00:28.

I wish it were the other way around as that would strengthen the appeal, but they could still claim the vehicle was parked for 27 minutes without a ticket and issue a PCN for that.

Thanks for sharing your thoughts.

Regards

O

I've modified the post as suggested.

The Parking Charge Notice is issued on thermal paper and in a tiny font.  It is therefore difficult to photograph, but I have posted a copy of the entirety of the PCN below:

<PARK PAY LOGO> Parkpay Services Ltd, www.paymypcn.net

PARKING CHARGE NOTICE
Notice to driver of breach of terms and conditions
of parking as detailed on the signage at site

PCN Number : <redacted>
Date of Service: 11/08/2025
Period of Parking: 00:27
Observation from: 00:22
Observation to: 00:27
Vehicle Reg No: <redacted>
Vehicle Colour: <redacted>
Vehicle Make: <redacted>
Parking Attendant: Abs
Location: Jamaica Street Carpark, 16-26 Ja
REASON FOR ISSUE: No Valid Payment

The Driver is required to pay a charge of £100 reduced to £60 if paid within 14 days

How to pay your parking charge notice

Online: Pay securely 24 hours a day at www.paymypcn.net

Bank: High Street or online banking
Sort Code: <redacted>
Account Number: <redacted>

This is a parking charge notice issued on private land.  Payment of this charge may be pursued by the operator through legal means including the courts, which may result in you incurring additional costs if unpaid.

You can appeal against the charge by writing to the car park operator.  If you are not satisfied with the outcome, you can make a further appeal to the Independent Appeals Service (IAS).  Details are given elsewhere on this notice.

The car park operator has agreed to adhere to an AIA Code of Practice.

For free advice regarding your parking charge including advice on appealing, please visit www.247advice.co.uk