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I'm considering these points for my POPLA Appeal, comments before submission will be welcomed!

1. Registered Keeper Status

I am the Registered Keeper of the vehicle and submit this appeal in that capacity.

I am under no legal obligation to identify the driver to a private parking operator and decline to do so.

Accordingly, if the Operator seeks to pursue me as Registered Keeper, it must demonstrate full compliance with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 ("PoFA").

2. Failure to Establish Keeper Liability under PoFA 2012

The Operator seeks to pursue me as the Registered Keeper. In order to do so, it must demonstrate full compliance with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 ("PoFA").

The Notice to Keeper relies upon "From" and "To" timestamps, which appear to have been generated from ANPR captures of a vehicle entering and exiting the site.

PoFA requires a Notice to Keeper to specify the relevant period of parking. However, entry and exit timestamps merely record vehicle movements past camera locations and are not, in themselves, evidence of a parking period.

The Notice to Keeper does not identify any separately evidenced period of parking and the Operator has not demonstrated how the statutory requirements necessary to transfer liability to the Registered Keeper have been satisfied.

As the driver has not been identified and keeper liability has not been established, the charge cannot be enforced against me as Registered Keeper.

3. The Operator Has Not Proven that a Parking Contravention Occurred

Even if POPLA were to conclude that keeper liability has been established, the Operator must still prove, on the evidence, that the alleged parking contravention occurred.

The Operator relies solely upon ANPR entry and exit timestamps showing a total site presence of approximately 13 minutes.

ANPR cameras record only the times at which a vehicle passes entry and exit points. They do not record whether a vehicle was parked, when any parking commenced, when it ended, or how much of the recorded period was spent driving within the site.

The Operator has provided no evidence of:

the vehicle being parked in a parking bay;
the duration of any alleged parking event;
when any contractual terms were accepted;
the time taken to enter, manoeuvre within the site, read signage, or exit.

The allegation is therefore based upon an inference that a parking event must have occurred between the recorded entry and exit times.

The Operator has produced no direct evidence to support that inference and has not demonstrated that a parking contravention occurred.

4. Failure to Demonstrate Compliance with BPA Consideration and Grace Period Requirements

The British Parking Association Code of Practice requires operators to allow motorists a reasonable consideration period upon arrival to locate and read signage and decide whether to remain on site.

The Operator has produced no evidence demonstrating that any mandatory consideration period was taken into account when assessing this charge.

The total site presence alleged by the Operator is approximately 13 minutes. That period necessarily includes entry, navigation within the site, locating and reading signage, and exiting the site.

The Operator has not demonstrated what portion of the recorded period, if any, constituted actual parking.

Accordingly, compliance with the BPA Code of Practice consideration and grace period requirements has not been established.

5. Inadequate Signage and Failure of Contract Formation

The Operator is required to demonstrate that clear and prominent signage was present and capable of forming a contract with the driver.

The Operator is put to strict proof that:

signage was clearly visible upon entry;
signage was clearly visible throughout the site;
the terms and conditions were legible;
the driver had a reasonable opportunity to read and understand those terms before any contract was formed.

Absent such proof, no contract can be said to have been properly formed.

6. Failure to Properly Consider Submitted Evidence

The Operator requested additional evidence in support of the appeal and directed that such evidence be submitted through its online portal.

The portal did not permit the upload of the requested material. In order to comply with the Operator's request, the material was therefore submitted by email instead.

Despite this, the Operator's rejection letter states:

"As this information has not been received within the specified timeframe..."

The rejection letter does not acknowledge receipt of the emailed submission, nor does it address the substance of the material provided.

I therefore have legitimate concerns that the evidence supplied in response to the Operator's request was either not considered or not properly taken into account before the appeal was rejected.

Whilst this point is not relied upon as a standalone ground of appeal, it raises doubt as to whether the Operator conducted a fair and thorough review of the representations and evidence submitted.

7. Template-Based Rejection and Inaccurate Case Handling

The Operator's rejection letter contains the following statement:

"Please note that as the parking incident occurred in Scotland or Northern Ireland, only the driver can make the appeal to POPLA."

The site concerned is Redbridge Institute of Adult Education in Ilford, England.

The statement is plainly inapplicable to this case and appears to have been inserted from a generic template.

Whilst not determinative on its own, this further supports the concern that the appeal was not individually considered on its own facts.

8. Operator Authority

The Operator is put to strict proof that it has sufficient authority from the landowner to:

issue parking charge notices at this location;
enter into contracts with motorists;
pursue parking charges in its own name;
defend such charges before POPLA and in court proceedings.

Absent such evidence, the Operator has no standing to pursue this charge.

Conclusion

The Operator has failed to:

establish keeper liability under PoFA 2012;
prove that a parking contravention occurred;
demonstrate compliance with BPA consideration and grace period requirements;
demonstrate that a contract was properly formed through adequate signage;
demonstrate proper consideration of submitted evidence;
demonstrate sufficient authority from the landowner.

Accordingly, I respectfully request that POPLA allow this appeal and direct Civil Enforcement Ltd to cancel the Parking Charge Notice.

I submitted the reps drafted above on 20th April, and today received this slightly confusing response:

Thank you for your appeal regarding Parking Charge XX.

Please note that the evidence originally attached with your appeal is insufficient as it does not confirm your legitimate visit on the day/ verify the emergency circumstances detailed in your appeal.

We have extended the deadline for you to provide additional evidence or documentation related to the date of the incident, confirming the circumstances related to the reason for your appeal. You now have an additional 14 days from the date of this email to submit the required information.

Please submit your evidence via the online appeal service at https://appeals.ce-service.co.uk/evidence.

Once a decision has been made, you will be notified via email using the email address you verified when submitting your appeal.

Yours sincerely,
Appeals Department

This feels like some sort of template response that hasn't even looked at what I actually submitted. There was no mention of any emergency circumstances...

Any suggestions of what to do next?!

Hi Based on the 14-day rule (Incident: 18 March, Received: 7 April) and the 13-minute stay shown on the NtK, I’ve drafted the following appeal. I'm focusing on PoFA non-compliance, the 'Double Dip' technical error, and the lack of a defined 'period of parking' (citing Burgess). Does this look airtight before I submit?

Dear Sir or Madam,

Re: Parking Charge Notice number []
I am appealing this notice on the following grounds:

1. Late Delivery and Lack of Keeper Liability (PoFA 2012)
The alleged incident occurred on 18 March 2026. Under Schedule 4, Paragraph 9 of the Protection of Freedoms Act (PoFA) 2012, a Notice to Keeper must be delivered within 14 days of the incident (by 1 April 2026). This notice was not received until 7 April 2026. Because you have failed to comply with the mandatory notice period required by the Act to transfer liability from the driver, there is no lawful basis to hold me, the Registered Keeper, liable for this charge. As the requirements of the Act have not been met, I am under no legal obligation to identify the driver and I decline to do so."

2. Failure to Identify the "Period of Parking"
Your notice identifies ANPR camera timestamps for entry and exit. However, it fails to specify the actual "period of parking" as strictly required by PoFA 2012, Paragraph 9(2)(a). I rely upon the persuasive authority of Excel Parking Services Ltd v Burgess [Case No: C8DP11F0], which established that ANPR timestamps recording times of entry and exit are not evidence of a "period of parking."

3. ANPR Technical Failure (Double Dipping)
Your ANPR system has suffered from a well-documented "double-dipping" error. The vehicle entered and exited the site on two separate occasions within a short timeframe. Your system has paired the initial entry of the day with the final departure, failing to record the intermediate exit and re-entry. I require you to check your full image logs for this VRM to identify the "orphan" records that prove the vehicle was not on site for a continuous period.

4. Mandatory Grace and Consideration Periods
Even if your flawed ANPR data were accurate, your evidence shows an entry at 14:24 and an exit at 14:37—a total duration of only 13 minutes. Per the British Parking Association (BPA) Code of Practice, a motorist must be allowed a "Consideration Period" to read signs and a "Grace Period" to leave the site. A 13-minute stay is entirely consumed by these mandatory periods, meaning no "period of parking" in breach of terms occurred.

Conclusion
As you have failed to meet the statutory requirements of PoFA 2012 to transfer liability to the Keeper, and your own evidence proves no parking contract was breached, I require you to cancel this PCN immediately and confirm in writing that my data has been removed from your systems.

The driver entered the car park twice. The first occasion they drove straight through the car park as they weren't sure they were at the right location. They drove around the block and then back into the car park where they parked, collected some items, returned to the vehicle and left.

On 7th April, I, the registered keeper, received a PCN through the post. I wonder if the time of entry is perhaps the time the driver first entered the car park? Is the NtK fully complaint with PoFA 2012, or could it be appealed on these grounds?

I've been away with work and this slipped off my radar a bit. I've dug the Title Deeds out Is there anything here that could help?


In the meantime I've received this letter from a debt collection company. Any suggestions as to how to handle from here?

  Not sure why the permit isn't visible in their picture.

Don't have a lease, I'm a freeholder. Is there any other information I should be looking for?

Just had the following response from Havering:

Thank you for your enquiry.

I can confirm the contravention date is 24/09/2024 and the Penalty Charge Notice was issued Friday 18/10/2024 1st class mail therefore service is deemed Monday 21/10/2024 which is 27 days service.

Please be advised the options available to you at this time are to make payment of the full outstanding balance of £130 to prevent incurring further charges or wait for the Order For Recovery to file Statutory Declaration should you have the grounds (please see grounds below) to do so and return the form to Traffic Enforcement Centre the address can be found on the form.

I did not receive the:
Notice to Owner (Parking contravention) or
Enforcement Notice (Bus lane contravention) or
Penalty Charge Notice (Moving Traffic contravention or Congestion Charging contravention)
I made representations about the penalty charge to the local authority concerned within 28 days of the service of the Notice to Owner/Enforcement Notice/Penalty Charge Notice, but did not receive a rejection notice.
I appealed to the Parking/Traffic Adjudicator against the local authority’s decision to reject my representation, within 28 days of service of the rejection notice, but have had no response to my appeal.

Kind regards

Any suggestions on next steps...?