LCP Harlesden Plaza Ticket

Hurtlocker

Hi CM, wrong thread? their reply with laughable GPEOL calc is in post #7 above. :beer:

Coupon-mad

Oh yes, sorry, skim-reading & missed that - surely POPLA would have decided on that by now?!

Hurtlocker

Attn: POPLA Operator Evidence / Admin

Dear Sir/Madam,

After reading through LCP’s latest communication to POPLA in response to my appeal, I would once again like to draw attention to these key observations.

1. The charge of £100 is not a genuine pre-estimate of loss as, by LCP’s definition, it is a fixed amount while the tariff (which should form part of the pre-estimate) is variable, proportionate to stay.

2. The charge of £100 is not a genuine pre-estimate of loss as, by LCP's own admission, the charge is designed to be a deterrent and is in fact punitive in nature.

3. The charge of £100 is not a genuine pre-estimate of loss as the purported breakdown of costs is grossly overinflated. In their last communication LCP attempt to justify the charge by referencing a BPA recommendation. This recommendation is however a maximum not a target. I have gone through the trouble of estimating this myself, and the amount set aside for labour is grossly overstated in LCP’s representations.

a. Labour Cost of Issuing PCN: Based on average cost to employer of a single employee I estimate a £14/hour cost for labour (including N/I, desk space, holidays etc). I am making the very conservative estimate of two PCNs issued per hour (I expect many more could be processed).

b. Cost (including labour) of responding to appeals: This will be higher, but given on average only 3% of all PCN’s issued are appealed* this then brings down the pre-estimate of loss to 3% of this amount (i.e. £100 per appeal becomes £3 per pcn on average every year). LCP is already making use of template responses (albeit not very well) in a drive to improve its efficiency and bring down costs (although it ironically frowns on this practice when it is applied to them). Evidence of this can be seen in the section below of their rebuttal. The prior appellant was clearly a woman, and someone at LCP forgot to switch “her” to “him” when adapting the template for this appeal. This also calls into question the accuracy and competence of LCP’s staff.

* and only 1% in greater London - http://www.londoncouncils.gov.uk/policylobbying/transport/parkinginlondon/parking-faqs.htm?showpage=-1

c. My Total Cost Estimate per PCN

Kadoe - £2.50
Paper, Printing, Postage - £1
Cost to employer of Labour for PCN issuance – £7 assuming two PCN’s issued per hour.
Averaged cost of Appeal handling across all PCNs issued in a year - £3

Total GPEOL: £13.50 + Initial cost of parking

I therefore put to you that both the structure (a fixed fee, ignoring the variable of cost of parking) and the magnitude (several times a GENUINE estimate) make it clear that this is not a Genuine Pre-estimate of Loss.

Kind Regards,

Hurtlocker

FYI - The above was sent some weeks ago and POPLA is yet to pass verdict. I have a feeling they're increasingly inundated as people wise up to the parking charge scam and contest.

OrdinaryPerson

Hi HL,

Have you got your POPLA results?

I submitted mine 2 weeks ago and LCP has not sent me the evidence pack yet. Are they deliberately delaying sending that so I don't have time to respond? What can I do?