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Robin Hood Airport VCS appeal letter
Testrix456
Posts: 6 Forumite
Hi - have read the Newbie section & followed advice re initial letter to VCS. Have received my rejection letter & POPLA code. I have drafted my appeal letter & would appreciate a quick glance by someone else to check that I have got all the points over without getting bogged down!! Many thanks 
Dear POPLA Adjudicator
RE: POPLA code xxxxxx
Vehicle Registration: xxxxxxx
PPC: Vehicle Control Services Limited (‘VCS’)
PCN ref xxxxxx
Alleged Contravention Date: xxxxxx
Date of notice: xxxx
Alleged Contravention: Stopping on a Roadway where stopping is Prohibited.
An invoice headed "PARKING CHARGE NOTICE" for £100 was issued to me, (discounted to £60 if paid within 14 days), as the registered keeper of the vehicle alleged to have stopped on the roadway ''where stopping is prohibited".
I am the registered Keeper of the above vehicle and I am appealing against the above charge. I contend that I am not liable for the parking charge on the following grounds and would ask that they are all considered.
My appeal points are:
1. The charge is not a Genuine Pre-estimate of Loss
2. VCS lack standing to pursue charges or make contracts in their own right
3. Unreadable signage for a no-stopping zone (signs are unclear)
4. The land is not relevant land under POFA 2012; no registered keeper liability
5. No Creditor is identified on the Notice to Appellant
6. Use of a non-compliant ANPR ‘hidden camera van’ at this location - which is not a car park.
I contend as follows:
1. The charge is not a Genuine Pre-estimate of Loss
The first 15 minutes at the Doncaster Robin Hood Airport pick up/drop off car park are free. The timed photographs provided to me as evidence by VCS show that the vehicle was stationary for only a couple of minutes, so there was no loss of revenue.
The demand for a payment of £100 (discounted to £60 if paid within 14 days) is punitive, unreasonable, exceeds an appropriate amount, and has no relationship to the loss that would have been suffered by the Landowner.
In my original appeal to VCS I queried that the amount was neither a genuine tariff/fee for parking, nor was it based upon any genuine pre-estimate of loss to VCS or the landowner. I also specifically asked ‘please supply a breakdown of your alleged 'loss' and state the intention of your enforcement (i.e. deterrent or revenue?)’. In their appeal rejection letter dated xxxxxxxxx VCS ignored my request for details and merely stated ”We confirm that (the PCN charges) represent a sum for liquidated and ascertained damages in respect of a breach of the ‘parking contract’….(and the) charges have been calculated in advance…When a motorist parks in breach of the Terms and Conditions of Parking, a loss in incurred by us as incorrect use of the access roads can lead to congestions, hazards and safety risks.”
The relevant vehicle can clearly be seen as stationary for a few minutes in a layby, at a time when there was no passing traffic on the access road.
As the registered keeper of the vehicle in question I do not believe that any damage or obstruction was caused or any material loss incurred, and that the charge levied is purely a fixed sum decided in advance by VCS as a revenue-raiser/ profit, with no justifiable basis. It does not represent a genuine pre-estimate of any loss following from the incident. VCS cannot argue that this charge is made up of tax-deductible business costs because these would exist even if no cars stopped and were issued with a PCN that day. The charge demanded is an unenforceable penalty dressed up as an imaginary loss, and as such, it breaches the Unfair Terms in Consumer Contracts Regulations 1999.
If VCS seek to contend otherwise I require them (as already asked), to present a full, itemised breakdown of their genuine pre-estimate of loss calculations.
Any attempt to list their business costs to 'paint a picture' of a loss, merely to hide the fact that the charge levied is purely a fixed sum for profit, would be disingenuous.
POPLA Assessor Chris Adamson stated in June 2014
"In each case that I have seen from the higher courts,...it is made clear that a charge cannot be commercially justified where the dominant purpose of the charge is to deter the other party from breach. This is most clearly stated in Lordsvale Finance Plc v Bank of Zambia [1996] QB 752, quoted approvingly at paragraph 15 in Cine Bes Filmcilik Ve Yapimcilik & Anor v United International Pictures & Ors [2003] EWHC Civ 1669 when Coleman J states a clause should not be struck down as a penalty, “if the increase could in the circumstances be explained as commercially justifiable, provided always that its dominant purpose was not to deter the other party from breach”.
This supports the principle that the aim of damages is to be compensatory, beginning with the idea that the aim is to put the parties in the position they would have been in had the contract been performed. It also seems that courts have been unwilling to allow clauses designed to deter breach as this undermines the binding nature of the initial promise made. Whilst the courts have reasonably moved away from a strict interpretation of what constitutes a genuine pre-estimate of loss, recognising that in complex commercial situations an accurate pre-estimate will not always be possible, nevertheless it remains that a charge for damages must be compensatory in nature rather than punitive.''
POPLA Assessor Matthew Shaw has also stated that the entirety of the parking charge must be a genuine pre-estimate of loss in order to be enforceable. For example, were no breach to have occurred, then the cost of parking enforcement, such as erecting signage, would still have been the same. The estimate must be based upon loss flowing from a breach of the parking terms, and in this instance there was no such loss.
In the circumstances I therefore respectfully request that my appeal is upheld and the charge dismissed.
2. VCS lacks standing to levy or pursue charges, or make contracts with drivers, in their own right
As VCS are not the owners of this land, and as such they cannot form a contract with the driver, I asked in my original appeal letter for proof of their locus standi to offer contracts to drivers at this site and to bring a claim in their own right for this particular contravention. I asked for a copy of their contract with the landowner, showing the restrictions, the charges, the dates and terms of business including any payments between themselves and their client, and the definition of their status as agents or contractors and their assigned rights (if any).
VCS failed to directly address this argument, and failed to provide a copy of the requested contract, merely stating that they are contracted by the landowner to provide management and enforcement on the access roads and ‘As such, we are authorised to issue PCNs for contraventions on the access roads’.
I contend that there is no contract with the landowner/occupier that entitles VCS to levy these charges and therefore VCS have no authority to issue parking charge notices (PCNs). This being the case, the burden of proof shifts to VCS to prove otherwise, and I put VCS to strict proof to POPLA that they have the necessary legal authorisation at this location and I demand that VCS produce to POPLA the contemporaneous and unredacted contract between the landowner and VCS that assigns them the proprietary rights to make contracts with drivers and to enforce charges in the courts. The BPA Code of Practice paragraph 7 requires those words when the Operator is not the landowner. I am not merely contesting VCS's right to 'issue PCNs'. Any contractor team at the Airport with a PC and printer could send out such letters but, of course, it does not follow that every Airport contractor can sue a driver. So, a mere witness statement or site agreement slip of paper, saying that VCS can 'issue' PCNs (i.e. send letters) will not be enough to rebut this appeal point which is about their lack of legal standing.
VCS have breached the BPA Code of Practice section 7 and its strict requirements regarding the scope and wording of landowner contracts, and failed to demonstrate their legal standing, which renders this charge unenforceable
I therefore respectfully request that my appeal is upheld and the charge dismissed.
3. Unreadable signage for a no-stopping zone (signs are unclear)
The alleged contravention is 'No stopping/ Waiting in Restricted Areas or Roadways’. I contend that at 2 am (ie in hours of darkness), when the alleged ‘breach’ occurred, warning signs were not sufficiently illuminated, large or placed so as to be visible/ readable whilst driving along the road.
Prominent, clear signs are a strict requirement of the BPA Code of Practice and are especially important in an area which the Operator is, apparently, claiming is a “No Stopping / Waiting in Restricted Areas or Roadways” area, where a driver will not have had a chance to read and understand any alleged contractual terms merely signposted in unclear 'headings above small-print' style. If the operator intends this to be a no stopping zone then they must make that abundantly clear to mitigate any loss and to avoid contraventions if they are contracted to keep the roadway clear. And yet VCS' use of a secret camera van and unclear signs at this Airport have caused so many visitors to be unfairly penalised that the operation here has been exposed by MP Nick Smith very recently as 'predatory' and 'profiteering'. I contend this is a cash cow for VCS and that there are no illuminated clearway 'repeater signs' facing oncoming drivers along the road and there is no 'red route' marked out at this site.
I asked VCS in my original appeal for ‘..a copy of the signage site map and close-up pictures of the signs in situ at the time, taken at a comparable time of day in similar light conditions. Such pictures must clearly show that they are large and illuminated enough that they would be legible from a passing vehicle in hours of darkness’ but VCS ignored that request.
I would further draw the assessor's attention to the 'No Stopping Zones' section of the Chief Adjudicator's first Annual POPLA Report 2013:
''Typically the motorist may have stopped on a double yellow line...of course, on the public highway this is generally permitted, although not on a red route where there is a clear red line. It is therefore very important that any prohibition is clearly marked; bearing in mind that such signage has to be positioned, and be of such a size, as to be read by a motorist without having to stop to look at it."
I request that my appeal is upheld and the charge dismissed.
4) Not Relevant Land as defined under POFA 2012; no registered keeper liability.
The driver has not been identified, yet VCS are claiming POFA 2012 registered keeper liability for this charge. The registered keeper is not liable for this charge as Doncaster Robin Hood Airport is designated as an airport by the Secretary of State and therefore roads within the airport are subject to airport byelaws - accordingly POFA 2012 does not apply (and indeed ‘keeper liability’ is specifically excluded under Schedule 4).
I put the Operator to strict proof otherwise if they disagree with this point and would require them to show evidence including documentary proof from the Airport Authority that this land is not already covered by byelaws.
5) No Creditor identified on the Notice to Appellant
The notice to keeper is not compliant with paragraph 9 (2) (h) of schedule 4 of the Protection of Freedom Act 2012 in that it does not identify the creditor. Whilst the Notice has indicated that the operator requires a payment to VCS, there is no specific identification of the Creditor who may, in law, be VCS or some other party. The Protection of Freedoms Act requires a Notice to Appellant to have words to the effect that “The Creditor is…” and the Notice does not. The keeper is entitled to know the party with whom any purported contract was made. VCS have failed to do this and thus have not fulfilled all the requirements necessary under POFA to allow them to attempt recovery of any charge from the keeper.
6) Non-compliant ANPR 'hidden camera van' system at this location which is not a car park
The BPA code of practice contains the following:
''21 Automatic number plate recognition (ANPR)
21.1 You may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as you do this in a reasonable, consistent and transparent manner. Your signs at the car park must tell drivers that you are using this technology and what you will use the data captured by ANPR cameras for.
21.2 Quality checks: before you issue a parking charge notice you must carry out a manual quality check of the ANPR images to reduce errors and make sure that it is appropriate to take action. Full details of the items you should check are listed in the Operators’ Handbook.
21.3 You must keep any ANPR equipment you use in your car parks in good working order. You need to make sure the data you are collecting is accurate, securely held and cannot be tampered with. The processes that you use to manage your ANPR system may be audited by our compliance team or our agents.
21.4 It is also a condition of the Code that, if you receive and process vehicle or registered keeper data, you must:
• be registered with the Information Commissioner
• keep to the Data Protection Act
• follow the DVLA requirements concerning the data
• follow the guidelines from the Information Commissioner’s Office on
the use of CCTV and ANPR cameras, and on keeping and sharing personal data such as vehicle registration marks.
At this location, the secret camera van does not operate in a reasonable, consistent and transparent manner and I contend that VCS have failed to meet the requirements of all of the above points in the BPA Code of Practice. They will need to show evidence to the contrary on every point, and explain how this hidden camera van can be compliant when this is not a car park, it is a road, and there is no opportunity for drivers in moving traffic to be informed that this technology is in use and what VCS will use the data captured by ANPR cameras for. VCS have breached the BPA Code of Practice as regards the use of a non-compliant ANPR system being merely a van fitted with a hidden camera, patrolling land which is not a 'car park' and neither 'managing, enforcing nor controlling parking'.
Dear POPLA Adjudicator
RE: POPLA code xxxxxx
Vehicle Registration: xxxxxxx
PPC: Vehicle Control Services Limited (‘VCS’)
PCN ref xxxxxx
Alleged Contravention Date: xxxxxx
Date of notice: xxxx
Alleged Contravention: Stopping on a Roadway where stopping is Prohibited.
An invoice headed "PARKING CHARGE NOTICE" for £100 was issued to me, (discounted to £60 if paid within 14 days), as the registered keeper of the vehicle alleged to have stopped on the roadway ''where stopping is prohibited".
I am the registered Keeper of the above vehicle and I am appealing against the above charge. I contend that I am not liable for the parking charge on the following grounds and would ask that they are all considered.
My appeal points are:
1. The charge is not a Genuine Pre-estimate of Loss
2. VCS lack standing to pursue charges or make contracts in their own right
3. Unreadable signage for a no-stopping zone (signs are unclear)
4. The land is not relevant land under POFA 2012; no registered keeper liability
5. No Creditor is identified on the Notice to Appellant
6. Use of a non-compliant ANPR ‘hidden camera van’ at this location - which is not a car park.
I contend as follows:
1. The charge is not a Genuine Pre-estimate of Loss
The first 15 minutes at the Doncaster Robin Hood Airport pick up/drop off car park are free. The timed photographs provided to me as evidence by VCS show that the vehicle was stationary for only a couple of minutes, so there was no loss of revenue.
The demand for a payment of £100 (discounted to £60 if paid within 14 days) is punitive, unreasonable, exceeds an appropriate amount, and has no relationship to the loss that would have been suffered by the Landowner.
In my original appeal to VCS I queried that the amount was neither a genuine tariff/fee for parking, nor was it based upon any genuine pre-estimate of loss to VCS or the landowner. I also specifically asked ‘please supply a breakdown of your alleged 'loss' and state the intention of your enforcement (i.e. deterrent or revenue?)’. In their appeal rejection letter dated xxxxxxxxx VCS ignored my request for details and merely stated ”We confirm that (the PCN charges) represent a sum for liquidated and ascertained damages in respect of a breach of the ‘parking contract’….(and the) charges have been calculated in advance…When a motorist parks in breach of the Terms and Conditions of Parking, a loss in incurred by us as incorrect use of the access roads can lead to congestions, hazards and safety risks.”
The relevant vehicle can clearly be seen as stationary for a few minutes in a layby, at a time when there was no passing traffic on the access road.
As the registered keeper of the vehicle in question I do not believe that any damage or obstruction was caused or any material loss incurred, and that the charge levied is purely a fixed sum decided in advance by VCS as a revenue-raiser/ profit, with no justifiable basis. It does not represent a genuine pre-estimate of any loss following from the incident. VCS cannot argue that this charge is made up of tax-deductible business costs because these would exist even if no cars stopped and were issued with a PCN that day. The charge demanded is an unenforceable penalty dressed up as an imaginary loss, and as such, it breaches the Unfair Terms in Consumer Contracts Regulations 1999.
If VCS seek to contend otherwise I require them (as already asked), to present a full, itemised breakdown of their genuine pre-estimate of loss calculations.
Any attempt to list their business costs to 'paint a picture' of a loss, merely to hide the fact that the charge levied is purely a fixed sum for profit, would be disingenuous.
POPLA Assessor Chris Adamson stated in June 2014
"In each case that I have seen from the higher courts,...it is made clear that a charge cannot be commercially justified where the dominant purpose of the charge is to deter the other party from breach. This is most clearly stated in Lordsvale Finance Plc v Bank of Zambia [1996] QB 752, quoted approvingly at paragraph 15 in Cine Bes Filmcilik Ve Yapimcilik & Anor v United International Pictures & Ors [2003] EWHC Civ 1669 when Coleman J states a clause should not be struck down as a penalty, “if the increase could in the circumstances be explained as commercially justifiable, provided always that its dominant purpose was not to deter the other party from breach”.
This supports the principle that the aim of damages is to be compensatory, beginning with the idea that the aim is to put the parties in the position they would have been in had the contract been performed. It also seems that courts have been unwilling to allow clauses designed to deter breach as this undermines the binding nature of the initial promise made. Whilst the courts have reasonably moved away from a strict interpretation of what constitutes a genuine pre-estimate of loss, recognising that in complex commercial situations an accurate pre-estimate will not always be possible, nevertheless it remains that a charge for damages must be compensatory in nature rather than punitive.''
POPLA Assessor Matthew Shaw has also stated that the entirety of the parking charge must be a genuine pre-estimate of loss in order to be enforceable. For example, were no breach to have occurred, then the cost of parking enforcement, such as erecting signage, would still have been the same. The estimate must be based upon loss flowing from a breach of the parking terms, and in this instance there was no such loss.
In the circumstances I therefore respectfully request that my appeal is upheld and the charge dismissed.
2. VCS lacks standing to levy or pursue charges, or make contracts with drivers, in their own right
As VCS are not the owners of this land, and as such they cannot form a contract with the driver, I asked in my original appeal letter for proof of their locus standi to offer contracts to drivers at this site and to bring a claim in their own right for this particular contravention. I asked for a copy of their contract with the landowner, showing the restrictions, the charges, the dates and terms of business including any payments between themselves and their client, and the definition of their status as agents or contractors and their assigned rights (if any).
VCS failed to directly address this argument, and failed to provide a copy of the requested contract, merely stating that they are contracted by the landowner to provide management and enforcement on the access roads and ‘As such, we are authorised to issue PCNs for contraventions on the access roads’.
I contend that there is no contract with the landowner/occupier that entitles VCS to levy these charges and therefore VCS have no authority to issue parking charge notices (PCNs). This being the case, the burden of proof shifts to VCS to prove otherwise, and I put VCS to strict proof to POPLA that they have the necessary legal authorisation at this location and I demand that VCS produce to POPLA the contemporaneous and unredacted contract between the landowner and VCS that assigns them the proprietary rights to make contracts with drivers and to enforce charges in the courts. The BPA Code of Practice paragraph 7 requires those words when the Operator is not the landowner. I am not merely contesting VCS's right to 'issue PCNs'. Any contractor team at the Airport with a PC and printer could send out such letters but, of course, it does not follow that every Airport contractor can sue a driver. So, a mere witness statement or site agreement slip of paper, saying that VCS can 'issue' PCNs (i.e. send letters) will not be enough to rebut this appeal point which is about their lack of legal standing.
VCS have breached the BPA Code of Practice section 7 and its strict requirements regarding the scope and wording of landowner contracts, and failed to demonstrate their legal standing, which renders this charge unenforceable
I therefore respectfully request that my appeal is upheld and the charge dismissed.
3. Unreadable signage for a no-stopping zone (signs are unclear)
The alleged contravention is 'No stopping/ Waiting in Restricted Areas or Roadways’. I contend that at 2 am (ie in hours of darkness), when the alleged ‘breach’ occurred, warning signs were not sufficiently illuminated, large or placed so as to be visible/ readable whilst driving along the road.
Prominent, clear signs are a strict requirement of the BPA Code of Practice and are especially important in an area which the Operator is, apparently, claiming is a “No Stopping / Waiting in Restricted Areas or Roadways” area, where a driver will not have had a chance to read and understand any alleged contractual terms merely signposted in unclear 'headings above small-print' style. If the operator intends this to be a no stopping zone then they must make that abundantly clear to mitigate any loss and to avoid contraventions if they are contracted to keep the roadway clear. And yet VCS' use of a secret camera van and unclear signs at this Airport have caused so many visitors to be unfairly penalised that the operation here has been exposed by MP Nick Smith very recently as 'predatory' and 'profiteering'. I contend this is a cash cow for VCS and that there are no illuminated clearway 'repeater signs' facing oncoming drivers along the road and there is no 'red route' marked out at this site.
I asked VCS in my original appeal for ‘..a copy of the signage site map and close-up pictures of the signs in situ at the time, taken at a comparable time of day in similar light conditions. Such pictures must clearly show that they are large and illuminated enough that they would be legible from a passing vehicle in hours of darkness’ but VCS ignored that request.
I would further draw the assessor's attention to the 'No Stopping Zones' section of the Chief Adjudicator's first Annual POPLA Report 2013:
''Typically the motorist may have stopped on a double yellow line...of course, on the public highway this is generally permitted, although not on a red route where there is a clear red line. It is therefore very important that any prohibition is clearly marked; bearing in mind that such signage has to be positioned, and be of such a size, as to be read by a motorist without having to stop to look at it."
I request that my appeal is upheld and the charge dismissed.
4) Not Relevant Land as defined under POFA 2012; no registered keeper liability.
The driver has not been identified, yet VCS are claiming POFA 2012 registered keeper liability for this charge. The registered keeper is not liable for this charge as Doncaster Robin Hood Airport is designated as an airport by the Secretary of State and therefore roads within the airport are subject to airport byelaws - accordingly POFA 2012 does not apply (and indeed ‘keeper liability’ is specifically excluded under Schedule 4).
I put the Operator to strict proof otherwise if they disagree with this point and would require them to show evidence including documentary proof from the Airport Authority that this land is not already covered by byelaws.
5) No Creditor identified on the Notice to Appellant
The notice to keeper is not compliant with paragraph 9 (2) (h) of schedule 4 of the Protection of Freedom Act 2012 in that it does not identify the creditor. Whilst the Notice has indicated that the operator requires a payment to VCS, there is no specific identification of the Creditor who may, in law, be VCS or some other party. The Protection of Freedoms Act requires a Notice to Appellant to have words to the effect that “The Creditor is…” and the Notice does not. The keeper is entitled to know the party with whom any purported contract was made. VCS have failed to do this and thus have not fulfilled all the requirements necessary under POFA to allow them to attempt recovery of any charge from the keeper.
6) Non-compliant ANPR 'hidden camera van' system at this location which is not a car park
The BPA code of practice contains the following:
''21 Automatic number plate recognition (ANPR)
21.1 You may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as you do this in a reasonable, consistent and transparent manner. Your signs at the car park must tell drivers that you are using this technology and what you will use the data captured by ANPR cameras for.
21.2 Quality checks: before you issue a parking charge notice you must carry out a manual quality check of the ANPR images to reduce errors and make sure that it is appropriate to take action. Full details of the items you should check are listed in the Operators’ Handbook.
21.3 You must keep any ANPR equipment you use in your car parks in good working order. You need to make sure the data you are collecting is accurate, securely held and cannot be tampered with. The processes that you use to manage your ANPR system may be audited by our compliance team or our agents.
21.4 It is also a condition of the Code that, if you receive and process vehicle or registered keeper data, you must:
• be registered with the Information Commissioner
• keep to the Data Protection Act
• follow the DVLA requirements concerning the data
• follow the guidelines from the Information Commissioner’s Office on
the use of CCTV and ANPR cameras, and on keeping and sharing personal data such as vehicle registration marks.
At this location, the secret camera van does not operate in a reasonable, consistent and transparent manner and I contend that VCS have failed to meet the requirements of all of the above points in the BPA Code of Practice. They will need to show evidence to the contrary on every point, and explain how this hidden camera van can be compliant when this is not a car park, it is a road, and there is no opportunity for drivers in moving traffic to be informed that this technology is in use and what VCS will use the data captured by ANPR cameras for. VCS have breached the BPA Code of Practice as regards the use of a non-compliant ANPR system being merely a van fitted with a hidden camera, patrolling land which is not a 'car park' and neither 'managing, enforcing nor controlling parking'.
0
Comments
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Please also write to DVLA:
Robert.Toft@dvla.gsi.gov.uk
Dear Sir,
I refer to a letter you issued (and of which I have had sight) under your reference MSU 111644/ACTS 89109.
In this letter you stated as follows:
"We have made it clear that, should we become aware of any company seeking to pursue claims under PoFA's provisions where these do not apply, no more data will be made available to the company in relation to those particular car parks until the situation is remedied."
Please find attached a Notice to Keeper where VCS Ltd. alleges keeper liability in respect of stopping on a road at Robin Hood Airport, despite PoFA not being applicable.
The provisions of PoFA do not apply for two reasons:
(i) It is not "relevant land". As is clear from the airport byelaws the road must be subject either to the road traffic enactments or to the byelaws.
http://www.robinhoodairport.com/_assets/downloads/byelaws.pdf
(ii) PoFA is applicable only to parking. Briefly stopping at the roadside to pick up/set down is not parking.
I would be grateful if you would inform me of what action you will now take against VCS in accordance with your policy stated above.
I also believe that VCS has breached it's KADOE contract with DVLA, in which it agreed to request data for the sole purpose of recovering unpaid parking charges. Furthermore, by using data for a purpose other than that for which it was requested, VCS is in breach of the Data Protection Act.
I would further be grateful if you would inform me of the actions DVLA, as data controller and signatory to the KADOE contract, intends to take with respect to these breaches.Je suis Charlie.0 -
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Here's one from about 8 weeks ago. I'm guessing it hasn't changed in the interim.
Je suis Charlie.0 -
Hi - yes Slithy Tove/ Bazster - that is the same as my PCN, which refers to PoFA - happy to write to DVLA. I presume my appeal letter is OK to go? Many thanks0
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Success - I'll post the appeal decision in the appropriate thread 0
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Well done!PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
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