Hi, i went on google AI and told it my problem and it basically told me what to write. ill include my appeal letter here. However, i also found a template addressing the legality of the claim that UKCPS were allowed to act as agents for the railway and asking for written authorisation from national rail to act as agents for them. ive tried to find it but i cant seem to find my way back and since i uploaded the appeal letter via IAS portal i dont have a copy. i did get lots of photos to prove the points i made such aspoor signage and national rail branding etc. im sure if you look you will find it too. Hope this helps. Since it is at the same station you may have joy. Good luck.
To: UKCPS Appeals Department
PCN Reference:
Vehicle Registration:
Date of Incident:
Site: Leeds City Station (Aire Street, LS1 4DY)
I am writing to formally appeal the above-mentioned Parking Charge Notice (PCN) in my capacity as the Registered Keeper. I deny any liability to your company based on the following methodical grounds. Please refer to the attached photographic evidence for each point.
1. Mandatory Consideration Period (IPC Code Section 13.1)
Your own photographic evidence confirms the vehicle was stationary for only 40 seconds. According to Section 13.1 of the IPC Code of Practice, motorists must be allowed a "sufficient Consideration Period" to identify signage, read the terms, and decide whether to be bound by them. A 40-second window is the absolute minimum time required for a driver to safely identify a sign, change glasses to read the text, and understand the restrictive "No Stopping" terms. As the vehicle departed immediately once the terms were understood, the driver rejected the "offer" of a contract. Therefore, no contract was formed. The fact that a passenger entered the vehicle during this time does not create a 'parking event' or signify acceptance of a contract that the driver was still in the process of reading. As the vehicle departed immediately after the terms were understood, no contract was formed, and the charge should be cancelled."
2. Physical Impossibility & Driver Workload
The layout of this site makes it impossible to safely read your terms while in motion:
• 90-Degree Signage: As shown in [ Guests cannot view attachments ] , the primary signage is positioned at a 90-degree angle to the driver’s line of sight on the uphill approach. The text is illegible until the vehicle is already parallel to the sign.
• Navigational Hazards: As shown in [ Guests cannot view attachments ] , the approach requires navigating a mini-roundabout immediately followed by a pedestrian crossing [ Guests cannot view attachments ] . A driver’s due care and attention must remain on these hazards for public safety. Stopping is a necessary safety measure to comply with the IPC requirement that terms be "clearly brought to the attention of the driver."
I draw your attention to UKCPS v Mr X (Bradford, 2014) regarding inadequate signage. In this instance, the driver stopped for only 40 seconds to identify and read a sign that was not legible from a moving vehicle
3. Lack of Keeper Liability (Non-Relevant Land & Railway Byelaws)
This site at Leeds City Station is governed by Railway Byelaws (specifically Byelaw 14) and is therefore "non-relevant land" as defined by Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).
• PoFA Branding: Your notice is incorrectly branded as a "PoFA" Notice to Keeper. Because the land is subject to statutory control, you have no lawful authority to transfer liability from the driver to the Registered Keeper.
• Evidence of Status: As shown in [ Guests cannot view attachments ] , the daily presence of police/emergency vehicles and station-specific branding confirms this is an active railway estate. As the Keeper, I am under no legal obligation to identify the driver, and you have no cause of action against me.
4. Safe Manoeuvring & "De Minimis"
The stop was a dynamic driving event necessitated by safe manoeuvring (reversing after the intended drop-off entrance was mistaken for a taxi rank due to the volume of taxis situated within the drop-off point). A 40-second stop for the purpose of safe positioning and identifying signage is de minimis (too trivial for the law to concern itself with) and does not constitute a "parking event" or a breach of contract.
Summary
It is understood that the driver intended to pick up a passenger from the designated station pick-up point but mistook the entrance for a taxi rank due to the high volume of taxis situated within. Upon overshooting the entrance, the driver stopped for approximately 40 seconds, to safely reverse and, crucially, to identify the restrictive "red" signage. This required the driver to change their glasses to read and understand the terms. While the driver was in this mandatory Consideration Period, the passenger—having spotted the vehicle—approached and entered.
The driver departed immediately upon understanding the "No Stopping" terms, thereby rejecting the contract. This charge is predatory and fails to account for the mandatory consideration period or the physical limitations of the site. I trust you will cancel this notice immediately. Should you reject this appeal, I require the mandatory Independent Appeals Service (IAS) reference number and a full explanation of how you claim "PoFA" authority over land subject to Railway Byelaws.
