3. F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
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F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
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The Bewl Water FAQ itself says parking is charged from 08:00:

https://www.bewlwater.co.uk/faq/

Registered keeper has now received a £100 PCN from First Parking LLP for Bewl Water.

The notice says the car entered at 06:46 and left at 09:17 (151 minutes). The allegation is that payment wasn’t made for the full duration.

The alleged driver has a Ringo receipt showing payment from 08:03–09:03. The car left at 09:17.

So it looks like 3 minutes late to start and 14 minutes over at the end. But surely there should be a grace period either side?

It’s highly confusing – the website itself shows 08:00, which is exactly why payment wasn’t made before then. Registered keeper has no idea what this clear signage is outside Bewl Water about private land that letter aludes to. Keeper is only aware that there is on grounds parking which begins at 08:00 which was largely respected.

To make things worse, the letter is dated 17/09/2025, but it was only found on the doormat this morning (27/09/2025). It says the £100 full charge must be paid by 01/10/2025 at 11:42am, which doesn’t leave much time to deal with it properly.

How does this add up to a £100 bill? It makes no sense at all.

https://ibb.co/NgxGH8K8
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #1 on: »
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #2 on: »
DO NOT identify the driver. There is no legal obligation on the unknown (to them) driver to identify the known Keeper.

The reservoir is subject to reservoir safety legislation, including the Reservoirs Act 1975, which imposes duties on the undertaker regarding inspection, maintenance, and emergency planning. While the leisure and parking operations are run by Salomons UK Ltd, a private company, the underlying land remains part of a statutory utility asset. Because the land is governed by a specific statutory Act and is part of a statutory water undertaking, it is not “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012. This means that keeper liability for private parking charges cannot be enforced under PoFA at this location.

See the linked thread above for how to word the appeal. Note the hook: PoFA Sch 4, para 3(1)(c) excludes land “on which the parking... is subject to statutory control.” If there are byelaws or other statutory controls in force at Bewl Water, PoFA keeper liability is unavailable.

The Medway Water (Bewl Bridge Reservoir) Act 1968 is the local Act that established and governs the Bewl scheme and authorised land acquisition/works. It evidences that the reservoir forms part of a statutory water undertaking, i.e., land under statutory control. Read together with the Reservoirs Act 1975 regime (which imposes statutory duties on the undertaker for inspection, maintenance and emergency planning) this places activities at Bewl within a statutory framework. Under PoFA 2012 Sch 4, land where parking is “subject to statutory control” is excluded from “relevant land,” so keeper liability cannot arise there.
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #3 on: »
Send the following email to First Parking by first class post and get a free certificate of posting from any post office to First Parking LLP, 27 Old Gloucester Street, London, WC1N 3AX:

Quote
Subject: Formal complaint – Breach of PPSCoP 8.1.1(d) and KADOE (Keeper liability misrepresented at Bewl Water)

Dear First Parking LLP Complaints Team,

I write as the registered keeper in relation to Parking Charge Notice [PCN ref], issued at Bewl Water on 17/09/2025.

Your Notice to Keeper (NtK) states or implies that you are able to hold me (the Keeper) liable under Schedule 4 to the Protection of Freedoms Act 2012 (PoFA). That statement is incorrect for this location and places you in breach of the Private Parking Single Code of Practice (PPSCoP), section 8.1.1(d). As you know, a breach of the PPSCoP is also a breach of your DVLA KADOE contract.

Why PoFA keeper liability cannot apply at Bewl Water
PoFA Sch 4 excludes “relevant land” where parking is “subject to statutory control” (Sch 4, para 3(1)(c) and 3(3)).

Bewl Water is a statutory reservoir/undertaking created and governed by specific legislation, including:

• Medway Water (Bewl Bridge Reservoir) Act 1968 (local Act establishing the scheme; authorising works and land acquisition).
• Reservoirs Act 1975 (statutory safety regime imposing duties on the undertaker for inspection, maintenance and emergency planning).

The presence of this statutory framework means the land is under statutory control for PoFA purposes, irrespective of present operational or ownership arrangements.

References (official sources)


Breach of PPSCoP and KADOE
PPSCoP 8.1.1(d) requires that operators must not state or imply that keeper liability applies where Schedule 4 does not. By asserting PoFA keeper liability at Bewl Water, your NtK misrepresents the legal position. This is a Code breach and, consequently, a breach of the DVLA’s KADOE terms, which require adherence to the applicable Code as a condition of data access.

Required remedies
As this is a formal complaint, please confirm within 14 days how you will rectify this compliance failure. At minimum, I expect you to:

1. Cancel PCN [PCN ref] and confirm in writing that no keeper liability is pursued at Bewl Water.
2. Cease and correct all NtK templates and website wording for sites under statutory control to remove any assertion (or implication) of PoFA keeper liability.
3. Conduct an immediate audit of outstanding NtKs issued for Bewl Water (and any other sites under statutory control) and notify affected keepers accordingly.
4. Provide details of staff guidance/training updates to prevent recurrence.

If you do not provide a satisfactory response, I will escalate this complaint to the British Parking Association and to the DVLA for investigation of a PPSCoP/KADOE breach.

Your published complaints policy states complaints must be submitted by post. For the avoidance of doubt, I will only accept your response by post or by email (your choice). Do not require telephone contact, web portals or third-party platforms for complaint handling or evidence review. Please treat this email as a formal complaint and provide your written response by [date – 14 days from today].

Yours faithfully,

[Full name]

[Postal address]
[Email]
Registered Keeper of vehicle [VRM]
PCN: [reference]
« Last Edit: September 28, 2025, 04:08:54 pm by b789 »
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #4 on: »
Hi,

Registered Keeper followed the sticky advise and first emailed the managing agent of Bewl Water to tell them about this charge to dispute and request cancellation. They replied to say they would look into it but never got back.

Now just today I have received this letter from DCBL...

What do I do? Stressing me out.I still dont even understand what this charge is about based on thread above.

Pic link here:

https://ibb.co/cXvg7TWF

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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #5 on: »
Did you appeal as in Reply #3 and the link given in Reply #1?

In the meantime, ignore DCBL, do not contact them in any way. DCB Legal, on the other hand, should not be ignored.
« Last Edit: November 03, 2025, 05:43:38 pm by jfollows »
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #6 on: »
You can safely ignore any debt recovery letters. Debt collectors are powerless to do anything except to try and intimidate the low-hanging fruit on the gullible tree to pay up out of ignorance and fear. You can safely shred those letters and use them as hamster bedding for all anyone cares. Stop stressing.

Did you send the formal complaint as advised to First Parking?
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #7 on: »
Thanks for your answers. Apologies but I did not send the letter above. I opted for another forum advice of first contacting Bewl Water themselves and asked them to cancel this as it was predatory. They said they would look into it and never got back to me then I received this letter yesterday.

On the next letter I receive from DCBL, I will post the letter above to them. Or do you think I should just post it now before they contact again?

Thank you for your help.
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #8 on: »
To repeat: do not contact DCBL in any way, do not call them, do not send them a letter, ignore them.
The reason they wrote to you is because you did not take our advice and appeal on the basis of non-compliance with PoFA 2012 because it is not “relevant land”.
However you would have ended up here anyway, it’s just that you would have stated your position and submitted a valid appeal which would have been rejected anyway.
Wait for a Letter of Claim from DCB Legal and come back here when you do. In the meantime, search the forum to see that in >99.9% of similar cases DCB Legal will eventually discontinue rather than pay the court fee. You will be given advice on the process between now and then.
« Last Edit: November 04, 2025, 07:47:50 am by jfollows »
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #9 on: »
It was a formal complaint that I took time to research for you. Thank you for wasting my time. I hope someone else doesn't waste their time trying to assist you, if you can't be bothered following the advice given.

I saw your thread on MSE and you have decided to follow their advice instead, where they didn't even know about the status of the land in question, even after I had already given it to you.

Good luck. I'm not going to bother with this thread from now on.
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #10 on: »
Hi B789

Firstly thank you for taking the time to research a proposed solution for me. I am really sorry if it came across as I had wasted your time. I only have made two posts on this website, the other of which I followed your advice word for word (you can see it in my post history)

I posted in two places the same thing (here and MSE) because I thought there was some time pressure and did not know how long replies would take so tried to cast my net out wider in the case that one responded faster than the other.

I read your reply in full and although much of the technical jargon was a bit over my head I was very happy to send that. However, on the MSE sticky there was a suggestion that before any of these angles it would just be easiest to contact the retailer first which is the least threatening. Hence, I picked this option as it had the least friction.

I am sorry!

I appreciate your insight and willingness to help. Now the advice has been suggested not to speak further with DCBL so I will not send the letter anymore and I will wait for the letter of claim and come back here.
« Last Edit: November 05, 2025, 12:43:11 pm by joebloggs90 »
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #11 on: »
Apology accepted. Thank you.

I still advise you to send the formal complaint as drafted. Depending on their response, you will then escalate to formal complaints to the BPA and the DVLA.
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Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #12 on: »
Thank you, will do.
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #13 on: »
@Broy life really got in the way last few months but for what its worth I finally sent the letter off today exactly as you wrote.  Of course they had sent me yet another letter threatening legal action which I have ignored.

Will wait to see what they reply and share it here.
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Re: F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100
« Reply #14 on: »
@b789 the following response was received on 05/02/2026 via email.  3 attachments of CCTV of car and one attachment called Parking Charge Notice (the usual stufd they send through the door)

Good Afternoon,

 

Thank you for your letter received 04/02/2026

 

Parking Charge refs: FP481691

Complaint ref: A39065

 

Your complaint has been referred to myself for review, please see my findings below:

 

Parking Charge FP481691 issued on 11/09/2025 at Bewl Water
Contravention – Not paid for the full duration of stay or not registering your vehicle
The vehicle with registration X15RAK was observed via the ANPR cameras entering site on 11/09/2025 at 06:46 and leaving on 11/09/2025 at 09:17. Total time on site 2 hours, 31 minutes, and 39 seconds. (Photographic evidence attached)
First Parking applied to the DVLA to request registered keeper details on 15/09/2025
DVLA keeper details received on 17/09/2025 and Notice to Keeper printed and posted on 17/09/2025. (please see attached)
As no payment, appeal or transfer of liability was received within 28 days of our initial correspondence, the case was referred to our appointed debt collectors on 23/10/2025.
DCBL are now administering the debt on behalf of First Parking
 

I have reviewed the photographic evidence, and I am satisfied that the Parking Charge was issued correctly and in accordance with the Code of Practice.

 

There is clear and sufficient signage on site advising motorists of the terms and conditions.

First Parking has processed the parking charge correctly and in line with the Code of Practice.

 

Due to non-payment, it was referred to debt collection on the 23/10/2025 and DCBL are now administering the debt on our behalf.

 

To answer the points in your letter:

 

The land on which your car was observed via ANPR camera’s is private land. Only the water/reservoir is governed by Medway Water/Southern Water.

 

Bewl Water is primarily managed and operated as a private leisure facility by the Elite Leisure Collection(part of the Markerstudy Group) since 2015, although the reservoir itself remains owned by the utility company Southern Water. The recreational grounds are privately managed.

•           Leisure & Operations: The leisure facilities, including fishing, water sports, and the aqua park, are managed by Elite Leisure Collection.

•           Water Authority: The reservoir and its water resources are controlled by Southern Water, serving as a vital public water source for Kent and East Sussex.

 

The parking charge has been issued under PoFA and is compliant.

 

In summary, I am satisfied the parking charge had been issued correctly at the time and in accordance with the signage in situ.

 

We have reached the end of our complaint process, and my response now concludes our complaints procedure. I trust you will appreciate that there will be no further review of your complaint.

 

Yours Sincerely,

 

Kelly Arnold

Account Manager

 

www.firstparking.co.uk

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