Help, got until 24th November to submit Defence for VCS

Leviathan747

Thanks CM.  Have just spoken to court & the lady said that our case is not down as discontinued & that we should get something in the post eventually!  Will check out that link you posted now....

Coupon-mad

Great, there are two distinct links and here is some more info, as people are saying it does take an afternoon at least, to do it!

HOW TO DO THE SUBMISSIONS:

Responses into the PAS 232 and MHCLG framework documents are not completely straightforward:

On the MHCLG response, you have to answer the questions on a 1-5 scale from strongly agree to strongly disagree, and then put some commentary. No way to upload documents or alternatives.

 On the PAS 232, you have to click on each clause and sub-clause to put your comments, and a suggested rewording of their draft.  You can see comments which other people have written! 

 But, when you click ‘submit’, a message pops up to say your comments have been received, but that only applies to the particular clause you have just addressed.

You have to click ‘submit’ separately for each individual clause response.

Some people will be caught out by this but can revisit it and add further responses up to 12 October.

Things to think about:

A Speeding fine is £100.  A Local Authority lower rate parking penalty is £50.  Which do you think a private PCN should be like?

Do you think they should be allowed to double the costs of the letters by adding a fake debt recovery sum?

Do you think the section about loading/unloading or boarding alighting (e.g. delivery drivers, taxis, or anyone dropping people off) is right and should such short activity be exempt, as we think it should?

Does the section about 'consideration periods' at the start give people long enough?  Why is it that the time starts from when you driver past a remote camera hidden a quarter of a mile away on an approach road...which means five or even ten (or more, in busy times) minutes has gone by before a person is even standing at a pay machine...?

etc. etc.

Leviathan747

Okayy.  That's something for tomorrow's to-do list! 

Leviathan747

Done.  Took me half an hour 
You have 3 more days folks!!

Coupon-mad

Half an hour to do both consultations, that's quick!   

DID YOU REMEMBER TO DOWNLOAD THE COVER LETTER AND READ THE EXTRA LAST MINUTE QUESTIONS THERE, ABOUT ADDING TO THE EXAMPE VEHICLES ANNEX, THE RIGHT TO LOAD/UNLOAD, DROP PEOPLE OFF/COLLECT (e.g. taxis, delivery drivers and everyone merely stopping for that) AND THE RIGHT FOR DISABLED PEOPLE TO PARK ON A DOUBLE YELLOW AS THEY DO ON STREET?

IT'S HIDDEN IN THE COVER LETTER, ANNOYINGLY.

Reminder for all, there are two consultations and they take time if unfamiliar with the subject matter:

An urgent task – deadline is MONDAY!

Please now make a real difference because not enough people have yet, and time is running out. 

The Government is consulting for just a few more days, about a new statutory code of practice (CoP) and framework intended to rein in the rogue parking firms. 

Does it go far enough?  Read and comment on the draft CoP proposal and the enforcement framework consultation (two separate consultation documents).

HOW TO DO THE SUBMISSIONS:

BSI PAS 232 – COMMENTING ON THE CODE OF PRACTICE AS DRAFTED :

1.    You will need to register then log in, to comment on the CoP and enter an occupation even if you are retired or a homemaker.  

 

2.    Register, log into the BSI page, and download & read the cover letter here:

https://standardsdevelopment.bsigroup.com/projects/2020-00193#/section

 

3.    Read the cover letter again and note the suggested extra questions... if you agree that, say, the 'loading/unloading and dropping off, asking for directions, and disabled people parking on double yellows as they can on street' activities listed should be exempt (not parking events, what do you think?) then please go to the Annexes at the end of the PAS Code and find the one about Exempt Vehicles and state what other activity you think should be added to the exempt list. 

 

4.    Download the PAS itself and start commenting on what you wish to say something about.  Quick links to each section appear on the left of your page. 

 

You don’t have to comment on everything, e.g. you might want to skip the definitions and focus on later sections, and certainly look at the Annex tables at the end that show things like consideration & grace periods and exemptions.

 

5.    Submit comments when you are happy with them. Don’t just ‘SAVE’ and forget!

 

THAT IS HALF THE JOB DONE!

THE MHCLG CONSULTATION IS EASIER AS IT IS JUST A LIST OF QUESTIONS. 

 

6.    You can do it first if preferred or pushed for time:

https://forms.office.com/Pages/ResponsePage.aspx?id=EGg0v32c3kOociSi7zmVqAVPfAOtwRxLhHRwQ610oElUMzhQSVo0WUQ4SERVSEZaUU9DTUhFQ1VMUy4u

If your answers exceed 4000 characters (approx. 500 words to a single question or 16000 words (approx. 2500 words) for all the questions below, you can email your answers to parking@communities.gov.uk as long as you state who you are.

 

 

 

THESE ARE THE QUESTIONS YOU WILL SEE, FOR RESPONSES TO THE FRAMEWORK:

Q1 Do you agree or disagree that members of APAs should be required to use a single appeals service appointed by the Secretary of State?

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

 

Q1.1 Please explain your answer

(free text)

 

 

Q2 Please provide any other feedback on the determination of appeals, including the funding model and features that an appeal service should offer e.g. telephone or in-person hearings, the ability to submit evidence online

(free text)

 

Q3 Please provide any comments you have on the proposal to enforce the Code by combining the ATA’s existing audit procedures with additional safeguards.

(free text)

 

Q4 Please outline any alternative means by which the Code could be monitored and enforced. You may wish to cite evidence from other regulatory frameworks which are relevant.

(free text)

 

Q5 Please provide any feedback you have on the proposed governance arrangements for monitoring the new Code of Practice

(free text)

 

Q6 Which parking charge system is most appropriate for private parking?

 a) the Three-tiered system

 b) Mirroring the Local Authority system

(free text)

 

 Q6.1 Please explain your answer. You may, for example, wish to make reference to other deterrent frameworks (for example, for railway tickets or traffic violations)

(free text)

 

 

Q7 What level of discount is appropriate:

40% as is currently offered in private parking and suggested in the three-tiered system, or

50% as is offered in Local Authority parking?

a) 40%

b) 50%

 

Q7.1 Please explain your answer, including whether the discount should be set at a different level

(free text)

 

 

 Q8 How should the level of parking charges be set and how should the levels be revised in future?

(free text)

 

 

Q9 Do you agree or disagree in principle with the idea of the Appeals Charter?

Agree/Disagree

 

Q9.1 Please explain your answer

(free text)

 

 

Q10 Do you agree or not that the examples given in the Appeals Charter are fair and appropriate? Agree/Disagree

 

Q10.1 Please explain your answer.

You may wish, for example, to suggest additional cases to be covered in an Appeals Charter or query existing examples.

(free text)

 

Q11 Do you agree or disagree that the parking industry should contribute towards the cost of the regulation?

Agree/Disagree

 

Q11.1 Please explain your answer.

(free text)

 

YOU CAN INSTEAD GIVE MORE CONCISE ANSWERS ONLINE, USING THE MHCLG PAGE LINK.

Don’t forget that answering these questions is the easier bit…

Looking at the BSI PAS (the draft code of practice itself) involves logging in and submitting comments again, and again and again and takes more time!

There is a discussion about PAS submissions and what the pages look like, here:

https://forums.moneysavingexpert.com/discussion/6195417/am-i-doing-something-wrong/p1

Leviathan747

Coupon-mad said:

Half an hour to do both consultations, that's quick!   
Reminder for all, there are two consultations and they take time if unfamiliar with the subject matter:

Ahhh.  Then I've just done the first survey* lol!  Thanks for the pointers above, will read now..

* MHCLG done.
Attempting PAS 232 now...

Coupon-mad

The survey is easy.  PLEASE DOWNLOAD THE PAS AND COVER LETTER. 

And remember the cover letter when you are looking at/commenting on the Annexes at the end of the PAS. 
Takes HOURS.

Leviathan747

Omigosh!!  So many parking scammer bots on there, posting comments.  Yikes!! 

Coupon-mad

Yes but it has been noticed and reported by various people.

Leviathan747

Have commented on 10. 'Escalation of Costs'  & 11.2 'Debt & Debt collection'.  Will try & chip away at more, when I get the chance.  Thanks for highlighting this Coupon-mad. Have become furious all over again!!!