Author Topic: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL  (Read 258 times)

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nothavingthis

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UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« on: October 07, 2024, 08:54:24 am »
Hi, I was wondering if anyone can help me with this. We had an emergency appointment at the maternity suite here whilst my wife was heavily pregnant. I quickly parked up and went inside only to come and find a yellow parking fine sticker with a note inside saying you will get a fine through the post.

The way the carpark is shaped if you don’t go inside and turn left into the car park you will not see payment meter and that’s what I did, I went and turned right and never saw that I had to pay.

https://ibb.co/dQ35Hc7

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b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #1 on: October 07, 2024, 01:35:15 pm »
It's not a "fine" in any way, shape or form. Please show us the "yellow parking fine sticker" that you say was affixed to the vehicle.

If the "yellow parking fine sticker" can be considered as a Notice to Driver (NtD) then they have failed to fully comply with all the requirements of PoFA and so the Keeper cannot be liable for the charge, as long as the drivers identity is not revealed, inadvertently or otherwise.

Incredibly easy to beat but you should first complain to the hospital PALS service and ask them to get the PCN cancelled. Do not be fobbed off by PALS and remind them of their obligations under the NHS car parking guidance 2022 for NHS trusts and NHS foundation trusts.

« Last Edit: October 07, 2024, 01:39:07 pm by b789 »
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nothavingthis

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #2 on: October 09, 2024, 01:52:43 pm »
Thanks for your reply.

This is a picture of the pcn left on my windscreen: https://ibb.co/ynPwxbc

b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #3 on: October 09, 2024, 03:28:27 pm »
Here is an article I'm writing for a website I own which shows why this PCN cannot hold the Keeper liable:

Quote
Why the Keeper Cannot Be Held Liable for the Parking Charge Notice

When dealing with a Parking Charge Notice (PCN) issued by a private parking company (PPC), it's crucial to understand the legal framework that governs liability. In England and Wales, this is largely dictated by the Protection of Freedoms Act (PoFA) 2012, specifically Schedule 4, which sets out the conditions under which a parking operator can hold a vehicle’s keeper liable for unpaid parking charges. In this article, we will explain why, in some cases, a keeper cannot be held liable for a PCN, using a recent scenario as an example.

Understanding the Key Legal Concepts: NtD and NtK

The Protection of Freedoms Act 2012 establishes two main types of notices that can be issued in relation to parking charges:

1. Notice to Driver (NtD): This is a physical notice that is usually attached to the vehicle at the time of the parking incident. It notifies the driver of the alleged parking contravention and initiates the process for pursuing a parking charge.

2. Notice to Keeper (NtK): This is a notice sent to the registered keeper of the vehicle, usually by post, if the parking charge remains unpaid. The NtK can be issued in two scenarios: when no NtD was issued, or when an NtD was issued but the charge remains unpaid.

To hold the vehicle's keeper liable for a parking charge, the PPC must follow strict procedural requirements outlined in Schedule 4 of PoFA.

The Requirements of PoFA for Holding the Keeper Liable

To lawfully transfer liability for a parking charge to the registered keeper, PoFA sets out a number of conditions that must be met. Two of these requirements are particularly important in cases where an NtD was issued:

• Paragraph 7 of PoFA: This paragraph details the requirements for an NtD. For the notice to comply fully with PoFA, it must contain certain prescribed information, such as the reason for the parking charge, the time and date of the alleged contravention, and the amount due. It should also include instructions on how the driver can appeal the charge.

• Paragraph 8 of PoFA: If an NtD was issued, paragraph 8 outlines the rules for issuing an NtK. It states that the NtK cannot be sent before 28 days have passed since the NtD was issued. This waiting period allows the driver time to respond to the NtD before the keeper is pursued for the charge. If the NtK is issued before this 28-day period, the PPC fails to meet the requirements set out by PoFA, and therefore, the keeper cannot be held liable.

Applying This to a Real-World Example

Let’s consider a situation in which a vehicle received a "Parking Charge Notice" attached to its windscreen, followed by an NtK sent only two days later. Here's why this scenario fails to comply with PoFA and why the registered keeper cannot be held liable:

1. The NtD was left on the windscreen: The notice placed on the vehicle constitutes a Notice to Driver (NtD) for the purposes of PoFA. Even if it does not fully comply with all the requirements set out in paragraph 7 (for example, if it does not contain all the necessary information), it still triggers the rules governing the subsequent issuance of an NtK. The mere fact that a physical notice was placed on the vehicle is sufficient to be considered an NtD under PoFA.

2. Premature issuance of the NtK: Under paragraph 8 of PoFA, once an NtD has been issued, the PPC must wait at least 28 days before issuing a Notice to Keeper. This is to give the driver a fair opportunity to respond to the NtD. In this example, the NtK was sent just two days after the NtD was issued, which is a clear violation of the statutory requirements.

3. Consequences of failing to comply with PoFA: Because the PPC did not follow the legally mandated process, they have failed to comply with PoFA’s conditions for transferring liability to the keeper. As a result, they cannot lawfully hold the registered keeper liable for the parking charge. The PPC may still attempt to pursue the driver for the charge, but they would need to prove the identity of the driver at the time of the alleged contravention, which is impossible unless the keeper admits to being the driver too.

Why This Matters

Adhering to the procedural requirements of PoFA is crucial for PPCs seeking to enforce parking charges against vehicle keepers. The Act’s provisions are in place to protect motorists from unfair practices by ensuring that notices are issued correctly and that there is sufficient opportunity to respond before liability is transferred. When these requirements are not met, the parking operator loses the legal basis for holding the registered keeper liable.

In the example provided, the premature issuance of the NtK represents a breach of the rules set out in paragraph 8 of PoFA. Despite any claims the PPC may make about the sufficiency of the NtD, the fact remains that issuing an NtK only two days after the NtD violates the statutory requirements. This breach undermines the parking operator’s ability to transfer liability to the registered keeper, making any demands for payment unenforceable against the keeper under PoFA.

Conclusion

In summary, when a parking operator fails to comply with the procedural requirements of PoFA—such as issuing an NtK too early after an NtD—the registered keeper cannot be held liable for the parking charge. The key takeaway is that PPCs must follow the law to the letter when it comes to parking enforcement. If they fail to do so, the registered keeper has strong grounds to contest any attempts to impose liability.

For anyone dealing with a parking charge notice, understanding PoFA’s requirements can be the difference between having to pay a charge and successfully challenging it. In cases like this, the keeper should not hesitate to dispute the PCN, citing the parking operator’s failure to comply with the law.
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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b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #4 on: October 09, 2024, 03:31:33 pm »
So, in this case, the initial appeal to UKPC, assuming PALS doesn't get the PCN cancelled is an easy one to defeat... as long as the unknown drivers identity is not revealed. There is no legal obligation on the known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the unknown driver and no inference or assumptions can be made.

The NtK is not compliant with all the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

Use the following as your appeal. No need to embellish or remove anything from it:

Quote
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.

As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. UKPC has relied on contract law allegations of breach against the driver only.

The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKPC have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

nothavingthis

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #5 on: October 18, 2024, 02:08:30 pm »
So, in this case, the initial appeal to UKPC, assuming PALS doesn't get the PCN cancelled is an easy one to defeat... as long as the unknown drivers identity is not revealed. There is no legal obligation on the known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the unknown driver and no inference or assumptions can be made.

The NtK is not compliant with all the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

Use the following as your appeal. No need to embellish or remove anything from it:

Quote
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.

As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. UKPC has relied on contract law allegations of breach against the driver only.

The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKPC have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.



I guess i will have to appeal directly to the PCN, got a response back from PALS saying:
Thank you for taking the time to feedback about your recent visit to the Burnley General Hospital. I can provide you with a response to your complaint.

 

You are correct in saying that Car parking at the hospital is managed by a third-party UK Parking Control. The Trust does not have any details of any penalty charging notices (PCN) issued as these are issued only to the registered keeper of the vehicle.

 

The PCN notice will provide you with details of how to appeal and the timescales. You haven’t confirmed whether you have appealed or not, but I will suggest that you follow the appeal process explaining your mitigations if you haven’t already done that.

 

If After your appeal and considering their response, you remain dissatisfied and wish to discuss the matter further, please feel free to make contact.


b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #6 on: October 18, 2024, 03:25:31 pm »
A fob off. Escalate your complaint to the NHS Trust CEO. Get back in touch with PALS and remind whichever moron sent you that response that there has been no "PENALTY" Charge Notice issued because an unregulated private parking company of ex-clamper thugs is not and could never be an "authority" that could issue a "penalty" of any kind. Also remind them that no "offence" has been committed. A "PARKING" Charge Notice is simply a speculative invoice form an alleged breach of contract by the driver of the vehicle and their use of the word "penalty" in their correspondence shows a level of ignorance that is embarrassing and will be reported.

Also point them to the Department of Health and Social Care guidance: NHS car parking guidance 2022 for NHS trusts and NHS foundation trusts, specifically the bit about "Contracted out parking".

Tell them that you are escalating this to the East Lancashire Hospital Trusts CEO, Martin Hodgson.

You need to immediately send a complaint to the CEO at martin.hodgson@elht.nhs.uk

Quote
Subject: Urgent Complaint Regarding Unjust Parking Charge Notice and PALS Response at Burnley Hospital

Dear Mr. Hodgson,

I am writing to formally complain about the handling of my issue by the PALS department and the unfair Parking Charge Notice (PCN) issued by UK Parking Control (UKPC), which operates on behalf of Burnley General Hospital.

During a recent emergency visit to the maternity suite, while my wife was heavily pregnant, I parked quickly to get her the urgent care she needed. Upon returning to my vehicle, I found an irregular notice left on the windscreen, stating that a PCN would be sent to the registered keeper by post. That PCN has now been received, but I must highlight a serious issue.

UKPC’s issuance of the Notice to Keeper (NtK) has failed to comply with the Protection of Freedoms Act (PoFA). The notice left on my windscreen, regardless of whether it was classed as a proper Notice to Driver (NtD), is effectively an NtD under PoFA. As such, UKPC should not have requested the keeper’s details from the DVLA until 28 days after the issue of the NtD. By requesting these details prematurely, UKPC has breached both the British Parking Association (BPA) Code of Practice and PoFA.

This is a serious violation, and it demonstrates that UKPC is operating outside the requirements of its own Code of Practice, effectively making them a "rogue contractor" on your hospital’s premises.

I would also like to draw your attention to the NHS Car Parking Guidance 2022, which makes it clear that:

• "NHS organisations are responsible for the actions of private contractors who run car parks on their behalf."

• "NHS organisations should act against rogue contractors in line with the relevant codes of practice."

• "Contracts should not be let on any basis that incentivises additional charges, for example, ‘income from parking charge notices only’."

UKPC’s conduct in this case is unacceptable and in clear violation of both PoFA and the BPA Code of Practice. It is your responsibility, as the Trust, to hold them accountable and ensure that your contractors are operating within the law.

I demand that this PCN be cancelled immediately, and that UKPC’s practices on your hospital grounds be reviewed to ensure compliance with both the law and NHS guidelines. I also expect a formal response regarding how you will address the breaches I have outlined. Furthermore, the PALS department should be better equipped to provide real support rather than simply redirecting patients to appeal directly with rogue contractors like UKPC.

I look forward to your prompt response.

Yours sincerely,

[Your Full Name]
[Your Contact Information]
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

nothavingthis

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #7 on: October 19, 2024, 01:28:34 pm »
A fob off. Escalate your complaint to the NHS Trust CEO. Get back in touch with PALS and remind whichever moron sent you that response that there has been no "PENALTY" Charge Notice issued because an unregulated private parking company of ex-clamper thugs is not and could never be an "authority" that could issue a "penalty" of any kind. Also remind them that no "offence" has been committed. A "PARKING" Charge Notice is simply a speculative invoice form an alleged breach of contract by the driver of the vehicle and their use of the word "penalty" in their correspondence shows a level of ignorance that is embarrassing and will be reported.

Also point them to the Department of Health and Social Care guidance: NHS car parking guidance 2022 for NHS trusts and NHS foundation trusts, specifically the bit about "Contracted out parking".

Tell them that you are escalating this to the East Lancashire Hospital Trusts CEO, Martin Hodgson.

You need to immediately send a complaint to the CEO at martin.hodgson@elht.nhs.uk

Quote
Subject: Urgent Complaint Regarding Unjust Parking Charge Notice and PALS Response at Burnley Hospital

Dear Mr. Hodgson,

I am writing to formally complain about the handling of my issue by the PALS department and the unfair Parking Charge Notice (PCN) issued by UK Parking Control (UKPC), which operates on behalf of Burnley General Hospital.

During a recent emergency visit to the maternity suite, while my wife was heavily pregnant, I parked quickly to get her the urgent care she needed. Upon returning to my vehicle, I found an irregular notice left on the windscreen, stating that a PCN would be sent to the registered keeper by post. That PCN has now been received, but I must highlight a serious issue.

UKPC’s issuance of the Notice to Keeper (NtK) has failed to comply with the Protection of Freedoms Act (PoFA). The notice left on my windscreen, regardless of whether it was classed as a proper Notice to Driver (NtD), is effectively an NtD under PoFA. As such, UKPC should not have requested the keeper’s details from the DVLA until 28 days after the issue of the NtD. By requesting these details prematurely, UKPC has breached both the British Parking Association (BPA) Code of Practice and PoFA.

This is a serious violation, and it demonstrates that UKPC is operating outside the requirements of its own Code of Practice, effectively making them a "rogue contractor" on your hospital’s premises.

I would also like to draw your attention to the NHS Car Parking Guidance 2022, which makes it clear that:

• "NHS organisations are responsible for the actions of private contractors who run car parks on their behalf."

• "NHS organisations should act against rogue contractors in line with the relevant codes of practice."

• "Contracts should not be let on any basis that incentivises additional charges, for example, ‘income from parking charge notices only’."

UKPC’s conduct in this case is unacceptable and in clear violation of both PoFA and the BPA Code of Practice. It is your responsibility, as the Trust, to hold them accountable and ensure that your contractors are operating within the law.

I demand that this PCN be cancelled immediately, and that UKPC’s practices on your hospital grounds be reviewed to ensure compliance with both the law and NHS guidelines. I also expect a formal response regarding how you will address the breaches I have outlined. Furthermore, the PALS department should be better equipped to provide real support rather than simply redirecting patients to appeal directly with rogue contractors like UKPC.

I look forward to your prompt response.

Yours sincerely,

[Your Full Name]
[Your Contact Information]

Brilliant, thank you very much for your help. I have emailed the relevant parties. Will keep you updated. In the mean time i have already appealed the 'PCN' due to the timing constraints.

b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #8 on: October 19, 2024, 01:36:23 pm »
You had until Tuesday 22nd October to submit an appeal. That's three days away.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

nothavingthis

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #9 on: October 19, 2024, 07:36:00 pm »
You had until Tuesday 22nd October to submit an appeal. That's three days away.

Yeah, true, but i didnt want to leave it last minute incase i got busy and didnt get round to appealing it. On the other hand, the initial complaint to PALS took 3+ days too, even then i had to chase up daily for an update/response.

H C Andersen

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #10 on: October 20, 2024, 04:15:31 pm »
How can you appeal, nobody is pursuing you for money!

Sorry, but the note left on your windscreen is not a Notice to Driver, it bears no resemblance, doesn't contain any of the statutory info, doesn't state what's owing OR to whom, how to pay, how to appeal etc. etc. And as the Act ONLY refers to the contents of a NTD and not the colour, shape, material, writing on or whatever of the envelope or packaging then to pin one's hopes on 'it must be a NTD because this is what the packaging said' would be foolish IMO, particularly as the Act does NOT refer to Parking Charge Notice, let alone define it.

There's a logical and IMO legal distinction to be made between a NTD, some of whose info is missing or incorrect, and therefore not compliant, and a note written on hospital notepaper which doesn't contain any of the statutory info. 

It is not a NTD IMO. 

So OP, as you don't have a Notice to Keeper your* actions are premature IMO.

*- are you the registered keeper and are your DVLA details current?
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DWMB2

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #11 on: October 20, 2024, 04:50:29 pm »
HC Andersen, please try to ensure you read threads more carefully before commenting.

The OP has received a Notice to Keeper, they provided a copy in their opening post.

H C Andersen

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #12 on: October 20, 2024, 05:25:51 pm »
Point taken, I can now see page 1 of a Notice to Keeper.

Which begs the question: why the focus on a non-existent NTD as being the basis of an appeal? Sorry, but surely this is simply a view and not something the OP should take away as being the law:

UKPC’s issuance of the Notice to Keeper (NtK) has failed to comply with the Protection of Freedoms Act (PoFA). The notice left on my windscreen, regardless of whether it was classed as a proper Notice to Driver (NtD), is effectively an NtD under PoFA...

Also, how come the date of 20 Oct. has been given as the last day of the appeals period, surely if posted on Fri. 20 Sept. then it's given on Tues. 24th, the 28-day period beginning on 25th would therefore end on 22 Oct. or is my maths out?

6)A notice sent by post is to be presumed, unless the contrary is proved, to have been delivered (and so “given” for the purposes of sub-paragraph (4)) on the second working day after the day on which it is posted; and for this purpose “working day” means any day other than a Saturday, Sunday or a public holiday in England and Wales.

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b789

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #13 on: October 21, 2024, 12:30:42 am »
The NtD was left on the windscreen: The notice placed on the vehicle constitutes a Notice to Driver (NtD) for the purposes of PoFA. Even if it does not fully comply with all the requirements set out in paragraph 7 (for example, if it does not contain all the necessary information), it still triggers the rules governing the subsequent issuance of an NtK. The mere fact that a physical notice was placed on the vehicle is sufficient to be considered an NtD under PoFA.

Thankfully, if it ever got that far, at least a real judge would be able to decide. (This will never get that far)

Besides telling us that it isn’t a real NTD, which has been explained above, how do you propose dealing with the NtK which attempts to be issued under PoFA section 9? Your view that the PCN attached to the vehicle was not an NtD, is, thankfully, just your view.

You had until Tuesday 22nd October to submit an appeal. That's three days away.

So what’s the gripe about? Who mentioned 20th as the last day?
« Last Edit: October 21, 2024, 12:37:05 am by b789 »
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nothavingthis

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Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
« Reply #14 on: October 23, 2024, 12:30:13 pm »
You had until Tuesday 22nd October to submit an appeal. That's three days away.

Hi again,

As expected the NHS Trust CEO Martin Hodgson has not replied yet, so i am glad i had submitted the appeal in time. (I used what was suggested below by userB789) I have however heard back from UKPC as pasted below (correspondence sent to me via email today):

Thank you for your recent communication concerning parking charge reference [REDACTED].
We have carefully considered your appeal based on the information provided and the evidence supporting the parking charge. In this instance having completed our assessment, we consider the parking charge to have been correctly issued, as the vehicle was parked on site without displaying a valid pay
and display ticket.

Our appeals process is now concluded, you may now choose one of the following options:

1) Pay the parking charge detailed above at the reduced rate of £35.00 to UK Parking Control Ltd. PLEASE REFER OVERLEAF FOR PAYMENT OPTIONS
AND ADDRESS DETAILS.

2) Make an appeal to the independent adjudicator POPLA (Parking on Private Land Appeals) using the verification code provided above. Please note that if you wish to appeal to POPLA, you will lose the right to pay the discounted rate of £35.00, and should POPLA reject your appeal you will be required to pay the full amount of £65.00. If you opt to pay the parking charge you will be unable to appeal with POPLA. Appeals to POPLA must be made within twenty-eight days from the date of this letter. To appeal with POPLA, please visit www.popla.co.uk. If you are unable to access the internet, you may
appeal by post – this must be done using a POPLA postal form which may be obtained by contacting POPLA by phone (0330 159 6126) or post (PO Box1270, Warrington, WA4 9RL).

By law we are also required to inform you that Ombudsman Services (www.ombudsman-services.org/) provides an alternative dispute resolution service that would be competent to deal with your appeal. However, we have not chosen to participate in their alternative dispute resolution service. As such should you wish to appeal then you must do so to POPLA, as explained above.

3) If you choose to do nothing the parking charge will automatically increase after thirty-five days from the date of this letter to £65.00 and the matter will be passed to our debt recovery agent, at which point you will be liable to pay an additional charge of £70, in accordance with the terms and conditions of parking, and further charges will be claimed if court action is taken against you. Any unpaid court judgement may adversely affect your credit rating.

Yours sincerely,
Appeals Department
UK Parking Control Limited

I guess off to POPLA we go  ;)


------------------------------------------------------------------------------
So, in this case, the initial appeal to UKPC, assuming PALS doesn't get the PCN cancelled is an easy one to defeat... as long as the unknown drivers identity is not revealed. There is no legal obligation on the known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the unknown driver and no inference or assumptions can be made.

The NtK is not compliant with all the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

Use the following as your appeal. No need to embellish or remove anything from it:

Quote
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.

As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. UKPC has relied on contract law allegations of breach against the driver only.

The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKPC have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.