Unfair parking charges

Laura_Simister

Hi
Thanks for your feedback. Please can you review the below letter and see if this is more suitable?
Thanks

Dear POPLA

Address
My Details
Ref.
Issued.
Reg.
Todays Date

I appeal against the decision of LPS because they have failed to follow the BPAcode of practice and attempted to impose a penalty charge for either breach ofcontract or trespass.


My appeal points are (Details of the these points will follow in thisletter):

[*]Unlawful penalty charge
[*]Not a genuine pre-estimate of loss
[*]No contract with the driver
[*]Unfair terms
[*]Unreasonable

The operator does not appear to own the XXXXXX car park and is assumedto be merely agents for the owner or legal occupier. In their Notice and in therejection letters, The operator has not provided me with any evidence that itis lawfully entitled to demand money from a driver or keeper, since it holdsneither interest, nor assignment of, title of the land in question.

I require the operator to provide a full copy of the actual contemporaneous,signed & dated contract with the landowner.

I say that any contract is not compliant with the requirements set out in theBPA Code of Practice.

I do not believe that the Operator has the necessary legal capacity to enterinto a contract with a driver of a vehicle parking in the car park, or indeedthe legal standing to allege a breach of contract. I refer the Adjudicator tothe recent Appeal Court decision in the case of Vehicle Control Services (VCS)v HMRC ( EWCA Civ 186 [2013]): The principal issue in this case was todetermine the actual nature of Private Parking Charges.

It was stated that, "If those charges are consideration for a supply ofgoods or services, they will be subject to VAT. If, on the other hand, they aredamages they will not be."

The ruling of the Court stated, "I would hold, therefore, that themonies that VCS collected from motorists by enforcement of parking charges werenot consideration moving from the landowner in return for the supply of parkingservices."

In other words, they are not, as the Operator asserts, a contractual term. Ifthey were a contractual term, the Operator would have to provide a VAT invoice,to provide a means of payment at the point of supply, and to account to HMRCfor the VAT element of the charge. The Appellant asserts that theserequirements have not been met. It must therefore be concluded that theOperator's charges are in fact damages, or penalties, for which the Operatormust demonstrate his actual, or pre-estimated losses, as set out above.

The Operator also make reference in their appeal refusal of (date) to “seek torecover the monies owed to us” and makes no reference to the Landlord at all.

7.1 of the BPA code of practice makes it a requirement that LPS either own theland, or have the written authorisation of the land owner to enable them tooperate on the land. I, as registered keeper, put LPS to strict proof that avalid contract exists that enables them to act in this manner on behalf of thelandowner. It is not an onerus task to produce the contract as section 8.1 ofthe code means it has to be available at all times.

19.5 of the code of practice states, “If the parking charge that the driver isbeing asked to pay is for a breach of contract or act of trespass, this chargemust be based on the genuine pre-estimate of loss that you suffer,”

The parking charge is only £2 for several hours. On the date of the claimedloss it was not full and there was no physical damage caused. Therefore the only loss would have been amaximum of £2. Neither can LPS lawfully include their operational day-to-dayrunning costs in enforcing parking restrictions at the site (for example, byerecting signage and employing administration staff) in any 'loss' claimed. SeeVEHICLE CONTROL SERVICESLIMITED -v- MR R IBBOTSON and A Retailer v Ms B and MsK, Oxford County Court. This does not represent a loss resulting from a breachof the alleged parking contract. In other words, were no breach to haveoccurred, the cost of parking enforcement would still have been the same. Thishas been quoted by PoPLA itself in adjucation.

I contend there can be no loss greater than £2; no pre-estimate (prior tostarting to 'charge for breaches' at this site) has been prepared or consideredin advance.

The charge that was levied is punitive and therefore void (i.e. unenforceable)against me. The initial charge is arbitrary and in no way proportionate to anyalleged breach of contract. Nor does it even equate to local council chargesfor all day parking. This would also apply to any mentioned costs incurredthrough debt recovery unless it followed a court order. I would question thatif a charge can be discounted by 40% by early payment that it is unreasonableto begin with.

1. Unlawful penalty charge

Since there was no demonstrable loss/damage and yet a breach of contract hasbeen alleged, it can only remain a fact that this 'charge' is an attempt atextorting an unlawful charge to impersonate a parking ticket. This is similarto the decisions in several County Court cases such as Excel Parking Services vHetherington-Jakeman (2008), also OBServices v Thurlow (review, February 2011),Parking Eye v Smith (Manchester County Court December 2011) and UKCPS v Murphy(April 2012) .

The operator is either charging for losses or it is a penalty/fine.

The operator uses an invoice or request for monies, but headed “PARKING CHARGENOTICE” to pass for an official Penalty Charge Notice, which only Police andCouncil Wardens can issue.


2. Not a Genuine Pre-estimate of loss

The wording on the signs appears to indicate that the parking charge representsdamages for a breach of the parking contract, in other words compensationagreed in advance. Accordingly, the charge must be a genuine pre-estimate ofloss. The estimate must be based upon loss flowing from a breach of the parkingterms. This might be, for example, loss of parking revenue at a retail outlet.

The parking company submitted that the charge is a genuine pre-estimate of thelosses incurred in managing the parking location.

The entirety of the parking charge must be a genuine pre-estimate ofloss in order to be enforceable. I require the parking company to submit abreakdown of how these costs are calculated. All of these costs must representa loss resulting from the alleged breach at the time.

Note: the charges demanded by the operator as "genuine loss"are those allegedly incurred at the point of issuing the charge, and can notinclude speculative future costs relating to internal appeal procedures ormounting a POPLA defence.


3. No valid contract with landowner

It is widely known that some contracts between landowner and parking companyhave ”authority limit clauses” that specify that parking companies are limitedin the extent to which they may pursue motorists. One example from a case inthe appeal court is Parking Eye –v- Somerfield Stores (2012) where Somerfieldattempted to end the contract with Parking Eye as Parking Eye had exceeded thelimit of action allowed under their contract.
In view of this, and the British Parking Association (BPA) Code ofPractice section 7 that demands that valid contract with mandatory clausesspecifying the extent of the parking company’s authority, I require the parkingcompany to produce a copy of the contract with the landowner that shows POPLAthat they do, indeed have such authority.

It has also been widely reported that some parking companies have provided“witness statements” instead of the relevant contract. There is no proofwhatsoever that the alleged signatory on behalf of the landowner has ever seenthe relevant contract, or, indeed is even an employee of the landowner. Irequire, if such a witness statement is submitted, that it is accompanied by aletter, on landowner’s headed notepaper, and signed by a director or equivalentof the landowner, confirming that the signatory is, indeed, authorised to acton behalf of the landowner ,has read and the relevant terms of the contract andis qualified to attest to the full limit of authority of the parking company.



4. Unfair terms

The charge that was levied is an unfair term, and therefore not binding,pursuant to the Unfair Terms in Consumer Contracts Regulations 1999. In particular,Schedule 2 of those Regulations gives an indicative (and non-exhaustive) listof terms which may be regarded as unfair and includes at Schedule 2(1)(e)"Terms which have the object or effect of requiring any consumer who failsto fulfil his obligation to pay a disproportionately high sum incompensation." Furthermore, Regulation 5(1) states that: "Acontractual term which has not been individually negotiated shall be regardedas unfair if, contrary to the requirement of good faith, it causes a significantimbalance in the parties' rights and obligations arising under the contract, tothe detriment of the consumer" and 5(2) states: "A term shall alwaysbe regarded as not having been individually negotiated where it has beendrafted in advance and the consumer has therefore not been able to influencethe substance of the term."

5. Unreasonable

The charge that was levied is an unreasonable indemnity clause pursuant tosection 4(1) of the Unfair Contract Terms Act 1977 which provides that: "Aperson cannot by reference to any contract term be made to indemnify anotherperson (whether a party to the contract or not) in respect of liability thatmay be incurred by the other for negligence or breach of contract, except in sofar as the contract term satisfies the requirement of reasonableness.”

I further contend that LPS have failed to show me any evidence that the camerasin this car park comply with the requirements of the BPA Code of Practice part21 (ANPR) and would require POPLA to consider that particular section of theCode in its entirety and decide whether the Operator has shown proof ofcontemporaneous manual checks and full compliance with section 21 of the Code,in its evidence. I, as registered keeper, contend that these cameras and theiroperation do not meet the standards laid down in the BPA code of practice.

I would contend that this appeal should be allowed for these reasons.

Coupon-mad

I would just remove this as it's a bit muddled, from an older template:

I contend there can be no loss greater than £2; no pre-estimate (prior to starting to 'charge for breaches' at this site) has been prepared or considered in advance.

And instead of the wording you currently have under '3. No valid contract with landowner' I would instead put your opening paragraphs which make the same point, better than the 'widely known' two paragraphs you have there. So move all the words from the start, thru to '...available at all times.' under point 3 instead of the 2 paras you have there (delete them).

Then cut & paste the sentences about 'loss' and put them in your point '2. Not a Genuine Pre-estimate of loss'.

Laura_Simister

Many thanks for your comments. I've made the changes as suggested. Please see below. Does this look ready to send to POPLA?
Thanks

Dear POPLA

Address
My Details
Ref.
Issued.
Reg.
Todays Date

I appeal against the decision of LPS because they have failed to follow the BPAcode of practice and attempted to impose a penalty charge for either breach ofcontract or trespass.


My appeal points are (Details of the these points will follow in thisletter):

[*]Unlawful penalty charge
[*]Not a genuine pre-estimate of loss
[*]No contract with the driver
[*]Unfair terms
[*]Unreasonable


1. Unlawful penalty charge

Since there was no demonstrable loss/damage and yet a breach of contract hasbeen alleged, it can only remain a fact that this 'charge' is an attempt atextorting an unlawful charge to impersonate a parking ticket. This is similarto the decisions in several County Court cases such as Excel Parking Services vHetherington-Jakeman (2008), also OBServices v Thurlow (review, February 2011),Parking Eye v Smith (Manchester County Court December 2011) and UKCPS v Murphy(April 2012) .

The operator is either charging for losses or it is a penalty/fine.

The operator uses an invoice or request for monies, but headed “PARKING CHARGENOTICE” to pass for an official Penalty Charge Notice, which only Police andCouncil Wardens can issue.


2. Not a Genuine Pre-estimate of loss

The wording on the signs appears to indicate that the parking charge representsdamages for a breach of the parking contract, in other words compensationagreed in advance. Accordingly, the charge must be a genuine pre-estimate ofloss. The estimate must be based upon loss flowing from a breach of the parkingterms. This might be, for example, loss of parking revenue at a retail outlet.

The parking company submitted that the charge is a genuine pre-estimate of thelosses incurred in managing the parking location.

The entirety of the parking charge must be a genuine pre-estimate ofloss in order to be enforceable. I require the parking company to submit abreakdown of how these costs are calculated. All of these costs must representa loss resulting from the alleged breach at the time.

Note: the charges demanded by the operator as "genuine loss"are those allegedly incurred at the point of issuing the charge, and can notinclude speculative future costs relating to internal appeal procedures ormounting a POPLA defence.



19.5 of the code of practice states, “If the parking charge that thedriver is being asked to pay is for a breach of contract or act of trespass,this charge must be based on the genuine pre-estimate of loss that you suffer,”

The parking charge is only £2 for several hours. On the date of the claimedloss it was not full and there was no physical damage caused. Therefore the only loss would have been amaximum of £2. Neither can LPS lawfully include their operational day-to-dayrunning costs in enforcing parking restrictions at the site (for example, byerecting signage and employing administration staff) in any 'loss' claimed. SeeVEHICLE CONTROL SERVICESLIMITED -v- MR R IBBOTSON and A Retailer v Ms B and MsK, Oxford County Court. This does not represent a loss resulting from a breachof the alleged parking contract. In other words, were no breach to haveoccurred, the cost of parking enforcement would still have been the same. Thishas been quoted by PoPLA itself in adjucation.

The charge that was levied is punitive and therefore void (i.e. unenforceable)against me. The initial charge is arbitrary and in no way proportionate to anyalleged breach of contract. Nor does it even equate to local council chargesfor all day parking. This would also apply to any mentioned costs incurredthrough debt recovery unless it followed a court order. I would question thatif a charge can be discounted by 40% by early payment that it is unreasonableto begin with.


3. No valid contract with landowner

The operator does not appear to own the De Trafford car park and is assumed tobe merely agents for the owner or legal occupier. In their Notice and in therejection letters, the operator has not provided me with any evidence that itis lawfully entitled to demand money from a driver or keeper, since it holdsneither interest, nor assignment of, title of the land in question.

I require the operator to provide a full copy of the actual contemporaneous,signed & dated contract with the landowner.

I say that any contract is not compliant with the requirements set out in the BPACode of Practice.

I do not believe that the Operator has the necessary legal capacity to enterinto a contract with a driver of a vehicle parking in the car park, or indeedthe legal standing to allege a breach of contract. I refer the Adjudicator to therecent Appeal Court decision in the case of Vehicle Control Services (VCS) vHMRC ( EWCA Civ 186 [2013]): The principal issue in this case was to determinethe actual nature of Private Parking Charges.

It was stated that, "If those charges are consideration for a supply ofgoods or services, they will be subject to VAT. If, on the other hand, they aredamages they will not be."

The ruling of the Court stated, "I would hold, therefore, that themonies that VCS collected from motorists by enforcement of parking charges werenot consideration moving from the landowner in return for the supply of parkingservices."

In other words, they are not, as the Operator asserts, a contractual term. Ifthey were a contractual term, the Operator would have to provide a VAT invoice,to provide a means of payment at the point of supply, and to account to HMRCfor the VAT element of the charge. The Appellant asserts that theserequirements have not been met. It must therefore be concluded that theOperator's charges are in fact damages, or penalties, for which the Operatormust demonstrate his actual, or pre-estimated losses, as set out above.

The Operator also make reference in their appeal refusal of (date) to “seek torecover the monies owed to us” and makes no reference to the Landlord at all.

7.1 of the BPA code of practice makes it a requirement that LPS either own theland, or have the written authorisation of the land owner to enable them tooperate on the land. I, as registered keeper, put LPS to strict proof that avalid contract exists that enables them to act in this manner on behalf of thelandowner. It is not an onerus task to produce the contract as section 8.1 ofthe code means it has to be available at all times.



4. Unfair terms

The charge that was levied is an unfair term, and therefore not binding,pursuant to the Unfair Terms in Consumer Contracts Regulations 1999. Inparticular, Schedule 2 of those Regulations gives an indicative (andnon-exhaustive) list of terms which may be regarded as unfair and includes atSchedule 2(1)(e) "Terms which have the object or effect of requiring anyconsumer who fails to fulfil his obligation to pay a disproportionately highsum in compensation." Furthermore, Regulation 5(1) states that: "A contractualterm which has not been individually negotiated shall be regarded as unfair if,contrary to the requirement of good faith, it causes a significant imbalance inthe parties' rights and obligations arising under the contract, to thedetriment of the consumer" and 5(2) states: "A term shall always beregarded as not having been individually negotiated where it has been draftedin advance and the consumer has therefore not been able to influence thesubstance of the term."

5. Unreasonable

The charge that was levied is an unreasonable indemnity clause pursuant tosection 4(1) of the Unfair Contract Terms Act 1977 which provides that: "Aperson cannot by reference to any contract term be made to indemnify anotherperson (whether a party to the contract or not) in respect of liability thatmay be incurred by the other for negligence or breach of contract, except in sofar as the contract term satisfies the requirement of reasonableness.”

I further contend that LPS have failed to show me any evidence that the camerasin this car park comply with the requirements of the BPA Code of Practice part21 (ANPR) and would require POPLA to consider that particular section of theCode in its entirety and decide whether the Operator has shown proof ofcontemporaneous manual checks and full compliance with section 21 of the Code,in its evidence. I, as registered keeper, contend that these cameras and theiroperation do not meet the standards laid down in the BPA code of practice.

I would contend that this appeal should be allowed for these reasons.

Coupon-mad

Nearly there, it will win!

Your point 3 heading lower down doesn't match the summary point 3 above (one says 'driver' and one says 'landowner' and it should be the latter).

And where you ask for the contract of the landowner I would add 'A site agreement with the pub is not the same thing as a contract with the rightful landowner so will not be acceptable, nor will a mere witness statement suffice. I require the actual unredacted contract with the landowner in the evidence, to check that it sets out the parking regime/charges as claimed by the Operator, assigns them title or standing to sue in their own right and otherwise complies with paragraph 7 of the BPA CoP. I understand that I have the right of reply to the evidence before the POPLA appeal is finalised and as such I will wish to scrutinise the landowner contract.'

We also ALWAYS suggest alleging the signs were unclear, there was no entrance sign and they did not form a contract with the driver. Have a paragraph saying the signs were insufficient and unlit so did not form a contract with the driver, even if you know there 'are signs up' (there always are) because it makes them have to show a map and signage photos which they can muck up!

Laura_Simister

Thank you very much for your input. It's very much appreciated.

Here's my final draft. Does this look ok to submit to POPLA?
Thanks
Laura


Dear POPLA

Address
My Details
Ref.
Issued.
Reg.
Todays Date

I appeal against the decision of LPS because they have failed to follow the BPAcode of practice and attempted to impose a penalty charge for either breach ofcontract or trespass.


My appeal points are (Details of these points will follow in thisletter):

[*]Unlawful penalty charge
[*]Not a genuine pre-estimate of loss
[*]No contract with the landowner
[*]Unfair terms
[*]Unreasonable


1. Unlawful penalty charge

Since there was no demonstrable loss/damage and yet a breach of contract hasbeen alleged, it can only remain a fact that this 'charge' is an attempt atextorting an unlawful charge to impersonate a parking ticket. This is similarto the decisions in several County Court cases such as Excel Parking Services vHetherington-Jakeman (2008), also OBServices v Thurlow (review, February 2011),Parking Eye v Smith (Manchester County Court December 2011) and UKCPS v Murphy(April 2012) .

The operator is either charging for losses or it is a penalty/fine.

The operator uses an invoice or request for monies, but headed “PARKING CHARGENOTICE” to pass for an official Penalty Charge Notice, which only Police andCouncil Wardens can issue.


2. Not a Genuine Pre-estimate of loss

The wording on the signs appears to indicate that the parking charge representsdamages for a breach of the parking contract, in other words compensationagreed in advance. Accordingly, the charge must be a genuine pre-estimate ofloss. The estimate must be based upon loss flowing from a breach of the parkingterms. This might be, for example, loss of parking revenue at a retail outlet.

The parking company submitted that the charge is a genuine pre-estimate of thelosses incurred in managing the parking location.

The entirety of the parking charge must be a genuine pre-estimate ofloss in order to be enforceable. I require the parking company to submit abreakdown of how these costs are calculated. All of these costs must representa loss resulting from the alleged breach at the time.

Note: the charges demanded by the operator as "genuine loss"are those allegedly incurred at the point of issuing the charge, and can notinclude speculative future costs relating to internal appeal procedures ormounting a POPLA defence.



19.5 of the code of practice states, “If the parking charge that thedriver is being asked to pay is for a breach of contract or act of trespass,this charge must be based on the genuine pre-estimate of loss that you suffer,”

The parking charge is only £2 for several hours. On the date of the claimedloss it was not full and there was no physical damage caused. Therefore the only loss would have been amaximum of £2. Neither can LPS lawfully include their operational day-to-dayrunning costs in enforcing parking restrictions at the site (for example, byerecting signage and employing administration staff) in any 'loss' claimed. SeeVEHICLE CONTROL SERVICESLIMITED -v- MR R IBBOTSON and A Retailer v Ms B and MsK, Oxford County Court. This does not represent a loss resulting from a breachof the alleged parking contract. In other words, were no breach to haveoccurred, the cost of parking enforcement would still have been the same. Thishas been quoted by PoPLA itself in adjucation.

The charge that was levied is punitive and therefore void (i.e. unenforceable)against me. The initial charge is arbitrary and in no way proportionate to anyalleged breach of contract. Nor does it even equate to local council chargesfor all day parking. This would also apply to any mentioned costs incurredthrough debt recovery unless it followed a court order. I would question thatif a charge can be discounted by 40% by early payment that it is unreasonableto begin with.


3. No valid contract with landowner

The operator does not appear to own the De Trafford car park and is assumed tobe merely agents for the owner or legal occupier. In their Notice and in therejection letters, the operator has not provided me with any evidence that itis lawfully entitled to demand money from a driver or keeper, since it holdsneither interest, nor assignment of, title of the land in question.

I require the operator to provide a full copy of the actual contemporaneous,signed & dated contract with the landowner.



A site agreement with the pub is not the same thing as a contract withthe rightful landowner so will not be acceptable, nor will a mere witnessstatement suffice. I require the actual unredacted contract with the landownerin the evidence, to check that it sets out the parking regime/charges asclaimed by the Operator, assigns them title or standing to sue in their ownright and otherwise complies with paragraph 7 of the BPA CoP. I understand thatI have the right of reply to the evidence before the POPLA appeal is finalisedand as such I will wish to scrutinise the landowner contract.

I say that any contract is not compliant with the requirements set out in theBPA Code of Practice.

I do not believe that the Operator has the necessary legal capacity to enterinto a contract with a driver of a vehicle parking in the car park, or indeedthe legal standing to allege a breach of contract. I refer the Adjudicator tothe recent Appeal Court decision in the case of Vehicle Control Services (VCS)v HMRC ( EWCA Civ 186 [2013]): The principal issue in this case was todetermine the actual nature of Private Parking Charges.

It was stated that, "If those charges are consideration for a supply ofgoods or services, they will be subject to VAT. If, on the other hand, they aredamages they will not be."

The ruling of the Court stated, "I would hold, therefore, that themonies that VCS collected from motorists by enforcement of parking charges werenot consideration moving from the landowner in return for the supply of parkingservices."

In other words, they are not, as the Operator asserts, a contractual term. Ifthey were a contractual term, the Operator would have to provide a VAT invoice,to provide a means of payment at the point of supply, and to account to HMRCfor the VAT element of the charge. The Appellant asserts that theserequirements have not been met. It must therefore be concluded that theOperator's charges are in fact damages, or penalties, for which the Operatormust demonstrate his actual, or pre-estimated losses, as set out above.

The Operator also make reference in their appeal refusal of (date) to “seek torecover the monies owed to us” and makes no reference to the Landlord at all.

7.1 of the BPA code of practice makes it a requirement that LPS either own theland, or have the written authorisation of the land owner to enable them tooperate on the land. I, as registered keeper, put LPS to strict proof that avalid contract exists that enables them to act in this manner on behalf of thelandowner. It is not an onerus task to produce the contract as section 8.1 ofthe code means it has to be available at all times.



I believe the signs are unclear and are not sufficient to form acontract with the driver. Furthermore,there is no visibility of a parking ticket machine in the car park.


4. Unfair terms

The charge that was levied is an unfair term, and therefore not binding,pursuant to the Unfair Terms in Consumer Contracts Regulations 1999. Inparticular, Schedule 2 of those Regulations gives an indicative (and non-exhaustive)list of terms which may be regarded as unfair and includes at Schedule 2(1)(e)"Terms which have the object or effect of requiring any consumer who failsto fulfil his obligation to pay a disproportionately high sum in compensation."Furthermore, Regulation 5(1) states that: "A contractual term which hasnot been individually negotiated shall be regarded as unfair if, contrary tothe requirement of good faith, it causes a significant imbalance in theparties' rights and obligations arising under the contract, to the detriment ofthe consumer" and 5(2) states: "A term shall always be regarded asnot having been individually negotiated where it has been drafted in advanceand the consumer has therefore not been able to influence the substance of theterm."

5. Unreasonable

The charge that was levied is an unreasonable indemnity clause pursuant tosection 4(1) of the Unfair Contract Terms Act 1977 which provides that: "Aperson cannot by reference to any contract term be made to indemnify anotherperson (whether a party to the contract or not) in respect of liability thatmay be incurred by the other for negligence or breach of contract, except in sofar as the contract term satisfies the requirement of reasonableness.”

I further contend that LPS have failed to show me any evidence that the camerasin this car park comply with the requirements of the BPA Code of Practice part21 (ANPR) and would require POPLA to consider that particular section of theCode in its entirety and decide whether the Operator has shown proof ofcontemporaneous manual checks and full compliance with section 21 of the Code,in its evidence. I, as registered keeper, contend that these cameras and theiroperation do not meet the standards laid down in the BPA code of practice.

I would contend that this appeal should be allowed for these reasons.

Coupon-mad

I would still suggest an Unclear signage - no contract with the driver' paragraph as well, that's all!

Coupon-mad wrote: »

We also ALWAYS suggest alleging the signs were unclear, there was no entrance sign and they did not form a contract with the driver. Have a paragraph saying the signs were insufficient and unlit so did not form a contract with the driver, even if you know there 'are signs up' (there always are) because it makes them have to show a map and signage photos which they can muck up!

LaurasColleague

Bit late but just thought I should mention that Laura won at POPLA on the basis of GPEOL! She's having trouble posting on here for some reason but needless to say is very grateful for all the help!! :beer:

Stroma

Congrats to her