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.
