Help with POPLA appeal needed please for unjust Uxbridge PCN

The_Deep

That business about charging them £18 an hour, do you really mean it, or will you wimp out as soon as popla finds for you? With respect, you do not appear to have fully grasped the process,

ticketynoo4

Ah I see, this is the not to use F word mentioned in some other posts! Got it, amazing how when you see the letter they send to you automatically refer to it has a F*#%. Great thanks for this, will be taking a look through the newbies section to pull together the POPLA appeal. Will re-post my draft once complete for any feedback.

ticketynoo4

The_Deep wrote: »

That business about charging them £18 an hour, do you really mean it, or will you wimp out as soon as popla finds for you? With respect, you do not appear to have fully grasped the process,

Yep I am a newbie so on a steep learning curve with no experience in this area. I surfed around the forum and found that wording used by another victim of parkdirect and therefore assumed this was right to include when challenging them. All I want to ensure is those cowboys do not get a penny from me. I have been directed to the newbies section which is great and will be pulling together my POPLA response so would appreciate any feedback on this when I post it. If I had known it was not advisable to include the paragraph you reference in the original appeal to parkdirect I would of removed it but unfortunately that letter was sent a week ago.

gertysingh

Ahh I love it when PPCs highlight case laws. Given you ammunition to shove it right back at them......that is when they don't pay yr charge and you take them to the small claims.

gertysingh

Once you've submitted your appeal to Popla (after it has been checked), send them your invoice.

gertysingh

Thornton v Shoe Lane Parking (1971) - just read the case law. I wonder if they actually read it? Superficially as I understand it if you had not seen the conditions - there is no contract. It's all to do when the "handshake" took place.

If another forumer can verify this, you can use it straight back in your Popla appeal.

ticketynoo4

Hi unjust PCN experts, would really appreciate if you could take a look at my below appeal to POPLA for the PCN. If you would like to see the ParkdirectUK appeal rejection letter you can see that on my earlier post on the 20/7 which also has links to the pics they sent.
As well as feedback on my appeal I have a couple of questions to do with my appeal which I would really appreciate feedback on -

1. I have crossed out some text from the Uxbridge template/example in section 1. The Charge is not a genuine pre-estimate of loss - of my appeal as I could not find any reference to this overhead wording on the letters I have received from them so was not sure if it would be relevant. Should I include these references to company overheads of Park direct UK or remove them as per what I have crossed out?
2. In the appeal rejection letter sent back to me they state that the grace period of 60 seconds is for those who park, read the signs and then leave however as the driver was dropping passengers off it directly breached the terms of parking and therefore the grace period would not apply. I have referenced this in section 5. Grace period insufficient despite BPA CoP of my appeal to POPLA but was concerned that as the photographs show someone leaving the vehicle and the driver then exiting if I needed to directly reference this or if the wording I have used will still cover this?
3. Again in the Uxbridge template in section 4. Signage incapable of being read - no contract with driver - of my appeal I removed references to the signage not being readable at night as the PCN occured in the day. I did add about the poor maintenance of the weeds around the sign that can be seen in one of the pictures they sent as I thought this was also worth highlighting. Is that worth including and is it important for me to also include the references about signage not being readable at night?
4. Another forum member (gertysingh) posted about the Thornton v Shoe Lane Parking (1971) case- Superficially as I understand it if you had not seen the conditions - there is no contract. Can someone else verify this and if so how would I best incorporate this into my appeal.
Here is my POPLA appeal submission draft, any feedback greatly received -
Dear POPLA assessor,

My POPLA code is xxxxxxxxxx and as the registered keeper of xxxxxxx I would like to appeal this notice on the following grounds:

1. The Charge is not a genuine pre-estimate of loss
2. Lack of sufficient contractual authority
3. No Keeper liability - the NTK is not compliant with the requirements of POFA2012
4. Signage incapable of being read - no contract with driver
5. Grace period insufficient despite BPA CoP
6. Operation is not reasonable, consistent or transparent
7. Unfair terms - Unenforceable Disguised Penalty

1. The Charge is not a genuine pre-estimate of loss
The demand for a payment of £100 is punitive, unreasonable, exceeds an appropriate amount, and has no relationship to any loss that could have potentially been suffered by the Landowner. I put Park Direct to strict proof of the alleged loss including a detailed breakdown of how the amount of the “charge” was calculated and how it was caused by this alleged sub-2 minute parking event. This PCN is really about breach of contract, so loss must be shown or the charge is unenforceable. The Notice to Keeper letter refers to 'breach of contract' so the charge must be a genuine pre-estimate of loss - and I contend this charge certainly is not based on any such calculation.

Park Direct states, but not limited to "staff costs, premises, telephone, letters and postage, IT systems and support, depreciation of assets, human resources and overheads" within their explanation for calculating genuine pre-estimate of loss. This are all costs which would occurred whether the claimed contravention took place or not and cannot be calculated in any genuine pre-estimate of loss. The parking 'charge' should be cancelled on this point alone.

Park Direct cannot demonstrate any initial quantifiable loss. The parking charge must be an estimate of likely losses flowing from the alleged breach in order to be potentially enforceable. Where there is an initial loss directly caused by the presence of a vehicle in breach of the conditions (e.g. loss of revenue from failure to pay a tariff) this loss will be obvious. An initial loss is fundamental to a parking charge and, without it, costs incurred by issuing the parking charge notice cannot be said to have been caused by the driver's alleged breach. Heads of cost such as normal operational costs (as listed above) and tax-deductible back office functions, debt collection, etc. cannot possibly flow as a direct consequence of this event.

Park Direct would have been in the same position had the parking charge notice not been issued, and would have had many of the same business overheads even if no vehicles breached any terms at all. Therefore, the sum they are seeking is not representative of any genuine loss incurred by either the landowner or the operator.


2. Lack of sufficient contractual authority

Park Direct have no standing as they are an agent, not the landowner. They also have no BPA-compliant landowner contract containing wording specifically assigning them any rights to form contracts with drivers in their own name, nor to pursue these charges in their own name in the Courts.

I put Park Direct to strict proof of the above in the form of their unredacted contract. Even if a basic site agreement is produced and mentions PCNs, the lack of ownership or assignment of title or interest in the land reduces any contract to one that exists simply on an agency basis between Park Direct and their client, containing nothing that could impact on a third party customer. Also the contract must be with the landowner - not another agent - and must comply with paragraph 7 of the BPA CoP and show that this contravention can result in this charge at this car park and that Park Direct can form contracts with drivers in their own right. The whole contract is required to be produced, in order to ensure whether it is with the actual landowner, whether money changes hands which must be factored into the sum charged.

3. No Keeper liability - the NTK is not compliant with the requirements of POFA2012

The Notice to Keeper is not compliant with POFA 2012, Schedule 4 due to these omissions:
''9(2)The notice must—
(b)inform the keeper that the driver is required to pay parking charges in respect of the specified period of parking and that the parking charges have not been paid in full;
(c)describe the parking charges due from the driver as at the end of that period, the circumstances in which the requirement to pay them arose (including the means by which the requirement was brought to the attention of drivers) and the other facts that made them payable;
(d)specify the total amount of those parking charges that are unpaid, as at a time which is—
(i)specified in the notice; and
(ii)no later than the end of the day before the day on which the notice is either sent by post or, as the case may be, handed to or left at a current address for service for the keeper (see sub-paragraph (4));
(e)state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—
(i)to pay the unpaid parking charges; or
(ii)if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver;
(f)warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—
(i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and
(ii)the creditor does not know both the name of the driver and a current address for service for the driver,
the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;
(h)identify the creditor and specify how and to whom payment or notification to the creditor may be made.''

Where paragraph 9 requires certain wording, it is omitted - except a small amended sentence on the payment slip (which has been found in Council PATAS appeals, not to count as the 'PCN' because it is a separate section, designed to be removed). Also, as keeper I cannot be expected to guess the 'circumstances in which the requirement to pay...arose' because the charge is stated to be based on 'an outstanding parking charge'. This so-called outstanding 'parking charge' is not quantified and the signs do not support that contention (see point 4) therefore the NTK misstates the alleged contravention and fails to meet the strict requirements of POFA2012.

Conversely the NTK fails to identify the 'creditor' and fails to state a 'period of parking' so it again does not meet the requirements of POFA 2012. It is not for me to guess who the creditor is. It could be 'ParkDirectUK 'or 'ParkDirectUK Ltd' (both legal names are on the NTK), or alternatively the creditor could be their client, or the landowner, or another party.

There is no 'keeper liability' from a fundamentally flawed NTK and POFA 2012 only applies to parking events. This was not a parking event at all, it was an example of ParkDirect's well documented (in the national press) sharp practice in taking photos of any vehicle which drives through/turns around near their operative with her mobile phone camera, then sending out speculative demands.

POPLA Assessor Matthew Shaw has stated that the validity of a Notice to Keeper is fundamental to establishing liability for a parking charge. ''Where a Notice is to be relied upon to establish liability ... it must, as with any statutory provision, comply with the Act.'' As the Notice was not compliant with the Act due to the many omissions of statutory wording, it was not properly given and so there is no keeper liability.

4. Signage incapable of being read - no contract with driver

The sign in the car park is multi-coloured, non-reflective, unlit and on the floor of the car park as highlighted in the pictures issued to the keeper of the vehicle as evidence by Park Direct. The sign was not seen by the driver and placed on the ground making the sign only visible if the driver was specifically seeking out the sign at pavement level while it is also obstructed by overgrown weeds growing around it as is shown from Park Direct's own evidence photo further hindering the drivers view of the signage

The BPA CoP at Appendix B sets out strict requirements for entrance signage, including “The sign should be placed so that it is readable by drivers without their needing to look away from the road ahead” and “There must be enough colour contrast between the text and its background, each of which should be a single solid colour. The best way to achieve this is to have black text on a white background, or white text on a black background. Combinations such as blue on yellow are not easy to read and may cause problems for drivers with impaired colour vision. Furthermore as the area around the signage has been poorly maintained therefore further restricting the visibility of the signage due to the overgrown weeds. Signs should be readable and understandable at all times. This can be achieved in a variety of ways such as maintaining the area of signage ensuring it is free of any obstructions.

5. Grace period insufficient despite BPA CoP

The BPA code of practice states that: “You should allow the driver a reasonable ‘grace period’ in which to decide if they are going to stay or go. If the driver is on your land without permission you should still allow them a grace period to read your signs and leave before you take enforcement action.”

The driver of the vehicle was in the car park according to the evidence provided by Park Directs first Parking Charge Notice for a total of 5 seconds, this does not even allow a reasonable grace period for the driver to notice a sign while driving and then leave the premises. The rejected appeal letter then further shows pictures highlighting a total of approx 1 minute 11 seconds again an unreasonable grace period for the driver to enter the car park fully, find a space, park the vehicle, leave the vehicle, lock the car, locate the sign, decipher the wording then choose to leave the car park following the same procedure as when entering the car park. With only 60 seconds of grace period offered, there has clearly been an insufficient amount of ‘grace period’ given to the driver in this instance.


6. Operation is not reasonable, consistent or transparent

It would appear that the 'parking attendant' used a handheld ordinary camera/phone to take photographs and there was no windscreen PCN issued so the driver had no idea of any contract nor any alleged breach. The driver does not believe that the person was wearing any kind of uniform or ID showing they are involved with 'parking enforcement' while the parking attendant proceeded to secretly take photos of the vehicle without making themselves known to the driver, as evidenced by the fact that all photos are taken off the far right angled front of the vehicle in front of another vehicle which the 'parking attendant' has used to further obscure themselves from being seen by the driver and making themselves blend in more with their surroundings as if being an innocent bystander. No attempt was taken to take photos close up directly in front of the vehicle due to the driver occupying the vehicle at all times and never exiting the vehicle. I require evidence that the person was properly trained in the BPA Code of Practice as is required for any self-ticketing, as the lack of grace period and the secret pictures taken leads me to think this was not a trained operative. Nor were they using a liveried vehicle, and I contend that mobile phone pictures from a passer-by are neither reliable nor compliant with the BPA CoP as this is not a reasonable, consistent nor transparent operation.

7. Unfair terms - Unenforceable Disguised Penalty

The sign & the NTK are unclear, ambiguous & contradictory. On the NTK the sum is extremely hard to find, hidden in small print on the back. It is stated as a 'contravention' for 'breaching the terms' and this is repeated in the rejection. Yet the sign misleadingly alleges a 'contractual' sum. If so, there would be a time-limited stay, a payment mechanism and a VAT invoice. There is none. This is a disguised penalty. Terms must be clear otherwise the interpretation that favours the consumer applies.

Thanks for any comments on this, if you have any feedback, any answers to my questions. Apologies if these seem very silly questions but I really want to ensure these cowboys do not get a penny and ensure this appeal is water tight so being a complete Newbie with this I realy appreaciate the help.

ticketynoo4

Hi all, would really appreciate if you could take a look at my below appeal to POPLA for the PCN received in Uxbridge by those Parkdirect cowboys.
If you would like to reference the appeal rejection letter and the pics they sent they can be found here -
Rejection letter Page 1 - tinypic.com/m/i52ont/3
Rejection letter Page 2 - tinypic.com/m/i52ook/3
Picture 1 - tinypic.com/m/i52otl/3
Picture 2 - tinypic.com/m/i52ou8/3

As well as feedback on my appeal which I used the Uxbridge POPLA template for I have a couple of questions to do with my appeal which I would really appreciate feedback on -

1. I have crossed out some text from the Uxbridge template/example in section 1. The Charge is not a genuine pre-estimate of loss - of my appeal as I could not find any reference to this overhead wording on the letters I have received from them so was not sure if it would be relevant. Should I include these references to company overheads of Park direct UK or remove them as per what I have crossed out?
2. In the appeal rejection letter sent back to me they state that "the grace period of 60 seconds is for those who park, read the signs and then leave however as the driver was dropping passengers off it directly breached the terms of parking and therefore the grace period would not apply." I have referenced this in section 5. Grace period insufficient despite BPA CoP of my appeal to POPLA but was concerned that as the photographs show someone leaving the vehicle and the driver then exiting if I needed to directly reference this or if the wording I had used will still cover this?
3. Again in the Uxbridge template in section 4. Signage incapable of being read - no contract with driver - of my appeal I removed references to the signage not being readable at night as the PCN occured in the day. I did add about the poor maintenance of the weeds around the sign that can be seen in one of the pictures they sent as I thought this was also worth highlighting. Is that worth including and is it important for me to also include the references about signage not being readable at night?

Here is my POPLA appeal submission draft, any feedback greatly received -

Dear POPLA assessor,

My POPLA code is xxxxxxxxxx and as the registered keeper of xxxxxxx I would like to appeal this notice on the following grounds:

1. The Charge is not a genuine pre-estimate of loss
2. Lack of sufficient contractual authority
3. No Keeper liability - the NTK is not compliant with the requirements of POFA2012
4. Signage incapable of being read - no contract with driver
5. Grace period insufficient despite BPA CoP
6. Operation is not reasonable, consistent or transparent
7. Unfair terms - Unenforceable Disguised Penalty

1. The Charge is not a genuine pre-estimate of loss
The demand for a payment of £100 is punitive, unreasonable, exceeds an appropriate amount, and has no relationship to any loss that could have potentially been suffered by the Landowner. I put Park Direct to strict proof of the alleged loss including a detailed breakdown of how the amount of the “charge” was calculated and how it was caused by this alleged sub-2 minute parking event. This PCN is really about breach of contract, so loss must be shown or the charge is unenforceable. The Notice to Keeper letter refers to 'breach of contract' so the charge must be a genuine pre-estimate of loss - and I contend this charge certainly is not based on any such calculation.

[STRIKE]Park Direct states, but not limited to "staff costs, premises, telephone, letters and postage, IT systems and support, depreciation of assets, human resources and overheads" within their explanation for calculating genuine pre-estimate of loss. This are all costs which would occurred whether the claimed contravention took place or not and cannot be calculated in any genuine pre-estimate of loss. The parking 'charge' should be cancelled on this point alone.
[/STRIKE]
Park Direct cannot demonstrate any initial quantifiable loss. The parking charge must be an estimate of likely losses flowing from the alleged breach in order to be potentially enforceable. Where there is an initial loss directly caused by the presence of a vehicle in breach of the conditions (e.g. loss of revenue from failure to pay a tariff) this loss will be obvious. An initial loss is fundamental to a parking charge and, without it, costs incurred by issuing the parking charge notice cannot be said to have been caused by the driver's alleged breach. [STRIKE]Heads of cost such as normal operational costs (as listed above) and tax-deductible back office functions, debt collection, etc. cannot possibly flow as a direct consequence of this event. [/STRIKE]

Park Direct would have been in the same position had the parking charge notice not been issued,[STRIKE] and would have had many of the same business overheads even if no vehicles breached any terms at all.[/STRIKE] Therefore, the sum they are seeking is not representative of any genuine loss incurred by either the landowner or the operator.


2. Lack of sufficient contractual authority

Park Direct have no standing as they are an agent, not the landowner. They also have no BPA-compliant landowner contract containing wording specifically assigning them any rights to form contracts with drivers in their own name, nor to pursue these charges in their own name in the Courts.

I put Park Direct to strict proof of the above in the form of their unredacted contract. Even if a basic site agreement is produced and mentions PCNs, the lack of ownership or assignment of title or interest in the land reduces any contract to one that exists simply on an agency basis between Park Direct and their client, containing nothing that could impact on a third party customer. Also the contract must be with the landowner - not another agent - and must comply with paragraph 7 of the BPA CoP and show that this contravention can result in this charge at this car park and that Park Direct can form contracts with drivers in their own right. The whole contract is required to be produced, in order to ensure whether it is with the actual landowner, whether money changes hands which must be factored into the sum charged.

3. No Keeper liability - the NTK is not compliant with the requirements of POFA2012

The Notice to Keeper is not compliant with POFA 2012, Schedule 4 due to these omissions:
''9(2)The notice must—
(b)inform the keeper that the driver is required to pay parking charges in respect of the specified period of parking and that the parking charges have not been paid in full;
(c)describe the parking charges due from the driver as at the end of that period, the circumstances in which the requirement to pay them arose (including the means by which the requirement was brought to the attention of drivers) and the other facts that made them payable;
(d)specify the total amount of those parking charges that are unpaid, as at a time which is—
(i)specified in the notice; and
(ii)no later than the end of the day before the day on which the notice is either sent by post or, as the case may be, handed to or left at a current address for service for the keeper (see sub-paragraph (4));
(e)state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—
(i)to pay the unpaid parking charges; or
(ii)if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver;
(f)warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—
(i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and
(ii)the creditor does not know both the name of the driver and a current address for service for the driver,
the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;
(h)identify the creditor and specify how and to whom payment or notification to the creditor may be made.''

Where paragraph 9 requires certain wording, it is omitted - except a small amended sentence on the payment slip (which has been found in Council PATAS appeals, not to count as the 'PCN' because it is a separate section, designed to be removed). Also, as keeper I cannot be expected to guess the 'circumstances in which the requirement to pay...arose' because the charge is stated to be based on 'an outstanding parking charge'. This so-called outstanding 'parking charge' is not quantified and the signs do not support that contention (see point 4) therefore the NTK misstates the alleged contravention and fails to meet the strict requirements of POFA2012.

Conversely the NTK fails to identify the 'creditor' and fails to state a 'period of parking' so it again does not meet the requirements of POFA 2012. It is not for me to guess who the creditor is. It could be 'ParkDirectUK 'or 'ParkDirectUK Ltd' (both legal names are on the NTK), or alternatively the creditor could be their client, or the landowner, or another party.

There is no 'keeper liability' from a fundamentally flawed NTK and POFA 2012 only applies to parking events. This was not a parking event at all, it was an example of ParkDirect's well documented (in the national press) sharp practice in taking photos of any vehicle which drives through/turns around near their operative with her mobile phone camera, then sending out speculative demands.

POPLA Assessor Matthew Shaw has stated that the validity of a Notice to Keeper is fundamental to establishing liability for a parking charge. ''Where a Notice is to be relied upon to establish liability ... it must, as with any statutory provision, comply with the Act.'' As the Notice was not compliant with the Act due to the many omissions of statutory wording, it was not properly given and so there is no keeper liability.

4. Signage incapable of being read - no contract with driver

The sign in the car park is multi-coloured, non-reflective, unlit and on the floor of the car park as highlighted in the pictures issued to the keeper of the vehicle as evidence by Park Direct. The sign was not seen by the driver and placed on the ground making the sign only visible if the driver was specifically seeking out the sign at pavement level while it is also obstructed by overgrown weeds growing around it as is shown from Park Direct's own evidence photo further hindering the drivers view of the signage

The BPA CoP at Appendix B sets out strict requirements for entrance signage, including “The sign should be placed so that it is readable by drivers without their needing to look away from the road ahead” and “There must be enough colour contrast between the text and its background, each of which should be a single solid colour. The best way to achieve this is to have black text on a white background, or white text on a black background. Combinations such as blue on yellow are not easy to read and may cause problems for drivers with impaired colour vision. Furthermore as the area around the signage has been poorly maintained therefore further restricting the visibility of the signage due to the overgrown weeds. Signs should be readable and understandable at all times. This can be achieved in a variety of ways such as maintaining the area of signage ensuring it is free of any obstructions.

5. Grace period insufficient despite BPA CoP

The BPA code of practice states that: “You should allow the driver a reasonable ‘grace period’ in which to decide if they are going to stay or go. If the driver is on your land without permission you should still allow them a grace period to read your signs and leave before you take enforcement action.”

The driver of the vehicle was in the car park according to the evidence provided by Park Directs first Parking Charge Notice for a total of 5 seconds, this does not even allow a reasonable grace period for the driver to notice a sign while driving and then leave the premises. The rejected appeal letter then further shows pictures highlighting a total of approx 1 minute 11 seconds again an unreasonable grace period for the driver to enter the car park fully, find a space, park the vehicle, leave the vehicle, lock the car, locate the sign, decipher the wording then choose to leave the car park following the same procedure as when entering the car park. With only 60 seconds of grace period offered, there has clearly been an insufficient amount of ‘grace period’ given to the driver in this instance.


6. Operation is not reasonable, consistent or transparent

It would appear that the 'parking attendant' used a handheld ordinary camera/phone to take photographs and there was no windscreen PCN issued so the driver had no idea of any contract nor any alleged breach. The driver does not believe that the person was wearing any kind of uniform or ID showing they are involved with 'parking enforcement' while the parking attendant proceeded to secretly take photos of the vehicle without making themselves known to the driver, as evidenced by the fact that all photos are taken off the far right angled front of the vehicle in front of another vehicle which the 'parking attendant' has used to further obscure themselves from being seen by the driver and making themselves blend in more with their surroundings as if being an innocent bystander. No attempt was taken to take photos close up directly in front of the vehicle due to the driver occupying the vehicle at all times and never exiting the vehicle. I require evidence that the person was properly trained in the BPA Code of Practice as is required for any self-ticketing, as the lack of grace period and the secret pictures taken leads me to think this was not a trained operative. Nor were they using a liveried vehicle, and I contend that mobile phone pictures from a passer-by are neither reliable nor compliant with the BPA CoP as this is not a reasonable, consistent nor transparent operation.

7. Unfair terms - Unenforceable Disguised Penalty

The sign & the NTK are unclear, ambiguous & contradictory. On the NTK the sum is extremely hard to find, hidden in small print on the back. It is stated as a 'contravention' for 'breaching the terms' and this is repeated in the rejection. Yet the sign misleadingly alleges a 'contractual' sum. If so, there would be a time-limited stay, a payment mechanism and a VAT invoice. There is none. This is a disguised penalty. Terms must be clear otherwise the interpretation that favours the consumer applies.

Thanks for any feedback on this and any answers to my questions. Apologies if these seem very silly questions but I really want to ensure these cowboys do not get a penny and ensure this appeal is water tight and as I am a complete Newbie with this I really appreaciate the help.

gertysingh

hi Gazza - have your 2 threads merged so that everyone follows what was written before. Click on Report and ask for it to be merged and if no one has looked this over. Bump up your thread requesting comments.

Coupon-mad

Gazza4 wrote: »

Thanks for any feedback on this and any answers to my questions. Apologies if these seem very silly questions but I really want to ensure these cowboys do not get a penny and ensure this appeal is water tight and as I am a complete Newbie with this I really appreaciate the help.

Looks spot on to me - you used the right template and you removed the bits that do not apply (if it was in daylight you are right, you don't need to talk about the signs being unreadable in the dark!). When you submit that appeal online to POPLA I would also attach 'evidence' to your POPLA appeal, being the exact picture where the weeds are overgrowing the sign - just in case ParkDirect 'forget' to include that one in their evidence!