Premier Park POPLA appeal

Hi,
I have prepared the following appeal after going through the various posts on the forum. If one of the experts can please browse through and feed back, it will be a great confidence booster.

Incident: Car was caught parked for 2:43 hrs on a dark rainy afternoon with poor visibility. This parking was free previously, but recently restrictions have been put in place for 2 hrs free parking. The new signs are pretty obscure. The location is Newbury Park, Ilford IG2 6BE (Google street maps still do not have the parking restriction signs). I came to know about the restrictions only after I received this notice and went to investigate. Initial appeal with Premier Park was rejected. I had raised lack of Keeper's liability as notice to Keeper was unclear and not according to POFA. I am about to submit the following to POPLA now.
============

I am the registered keeper of vehicle registration XXXX XXX and I wish to reject a recent parking charge number xxxxxxx. I wish to state, without prejudice, that I am rejecting this notice on the grounds stated below:

1. No Keeper liability
2. Inadequate signage
3. Landowner authority
4. Genuine pre-estimation of loss and commercial justification
5. ANPR Accuracy and Compliance
6. ANPR Usage Code of Conduct




1. No Keeper liability
Premier Park has not issued a formal Notice to Keeper (NTK) in accordance with Paragraph 9 of Schedule 4 of the Protection of Freedoms Act (POFA) 2012. The PCN is the only notice issued and it does not serve as a formal Notice to Keeper due the following reasons:
It does not state explicitly anywhere whether it is a Notice to Keeper or a Notice to Driver
The language changes from assuming the recipient to be the Driver (e.g. “By parking within this car you are bound…. In paragraph 1) to assuming the recipient to be the Keeper (e.g. “If you were not the keeper… in paragraph 4).
It is a requirement under the POFA 2012 Schedule 4 Paragraph 9 2 (e) to state that “the creditor does not know both the name of the driver and a current address for service for the driver…”. But the notice does not state this, rather assumes the recipient to be the driver sometimes, and the keeper at other times.
In cases with a keeper appellant, yet no POFA 'keeper liability' to rely upon, POPLA must first consider whether they are confident that the Assessor knows who the driver is, based on the evidence received. No presumption can be made about liability whatsoever. A vehicle can be driven by any person (with the consent of the owner) as long as the driver is insured. There is no dispute that the driver was entitled to drive the car and I can confirm that they were, but I am exercising my right not to name that person.

In this case, no other party apart from an evidenced driver can be told to pay. As there has been no admission regarding who was driving, and no evidence has been produced, it has been held by POPLA on numerous occasions, that a parking charge cannot be enforced against a keeper without a valid NTK.

As the keeper of the vehicle, it is my right to choose not to name the driver, yet still not be lawfully held liable if an operator is not using or complying with Schedule 4. This applies regardless of when the first appeal was made and regardless of whether a purported 'NTK' was served or not, because the fact remains I am only appealing as the keeper and ONLY Schedule 4 of the POFA (or evidence of who was driving) can cause a keeper appellant to be deemed to be the liable party.

The burden of proof rests with the Operator to show that (as an individual) I have personally not complied with terms in place on the land and show that I am personally liable for their parking charge. They cannot.

Furthermore, the vital matter of full compliance with the POFA was confirmed by parking law expert barrister, Henry Greenslade, the previous POPLA Lead Adjudicator, in 2015:

Understanding keeper liability
'There appears to be continuing misunderstanding about Schedule 4. Provided certain conditions are strictly complied with, it provides for recovery of unpaid parking charges from the keeper of the vehicle.

There is no 'reasonable presumption' in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver. [...] If {POFA 2012 Schedule 4 is} not complied with then keeper liability does not generally pass.'

Therefore, no lawful right exists to pursue unpaid parking charges from myself as keeper of the vehicle, where an operator cannot transfer the liability for the charge using the POFA.

This exact finding was made in 6061796103 against ParkingEye in September 2016, where POPLA Assessor Carly Law found:
''I note the operator advises that it is not attempting to transfer the liability for the charge using the Protection of Freedoms Act 2012 and so in mind, the operator continues to hold the driver responsible. As such, I must first consider whether I am confident that I know who the driver is, based on the evidence received. After considering the evidence, I am unable to confirm that the appellant is in fact the driver. As such, I must allow the appeal on the basis that the operator has failed to demonstrate that the appellant is the driver and therefore liable for the charge. As I am allowing the appeal on this basis, I do not need to consider the other grounds of appeal raised by the appellant. Accordingly, I must allow this appeal.''


2. Inadequate Signage: The signs in this car park are not prominent, clear or legible from all parking spaces and there is insufficient notice of the sum of the parking charge itself

The alleged breach took place during a period of dark cloud and heavy rain with very limited visibility. Any signs were high above and not adequately lit to be seen clearly while driving (and indeed were not seen by the driver). Furthermore, the parking charge of £100 is not written in LARGE letters anywhere at eye level and is hardly legible in bright light, and impossible to read on a dark heavily-raining afternoon.

I note that within the Protection of Freedoms Act (POFA) 2012 it discusses the clarity that needs to be provided to make a motorist aware of the parking charge. Specifically, it requires that the driver is given 'adequate notice' of the charge. POFA 2012 defines 'adequate notice' as follows:

''(3) For the purposes of sub-paragraph (2) 'adequate notice' means notice given by: (a) the display of one or more notices in accordance with any applicable requirements prescribed in regulations under paragraph 12 for, or for purposes including, the purposes of sub-paragraph (2); or (b) where no such requirements apply, the display of one or more notices which: (i) specify the sum as the charge for unauthorised parking; and (ii) are adequate to bring the charge to the notice of drivers who park vehicles on the relevant land''.

Even in circumstances where POFA 2012 does not apply, I believe this to be a reasonable standard to use when making my own assessment, as appellant, of the signage in place at the location. Having considered the signage in place at this particular site against the requirements of Section 18 of the BPA Code of Practice and POFA 2012, I am of the view that the signage at the site - given the minuscule font size of the £sum, which is illegible in most photographs and does not appear at all at the entrance - is NOT sufficient to bring the parking charge (i.e. the sum itself) to the attention of the motorist.

There was no contract nor agreement on the 'parking charge' at all. It is submitted that the driver did not have a fair opportunity to read about any terms involving this huge charge, which is out of all proportion and not saved by the dissimilar 'ParkingEye Ltd v Beavis' case.

In the Beavis case, which turned on specific facts relating only to the signs at that site and the unique interests and intentions of the landowners, the signs were unusually clear and not a typical example for this notorious industry. The Supreme Court were keen to point out the decision related to that car park and those facts only:

http ://imgur.com/a/AkMCN

In the Beavis case, the £85 charge itself was in the largest font size with a contrasting colour background and the terms were legible, fairly concise and unambiguous. There were 'large lettering' signs at the entrance and all around the car park, according to the Judges.

Here is the 'Beavis case' sign as a comparison to the signs under dispute in this case:

http ://2.bp.blogspot.com/-eYdphoIIDgE/VpbCpfSTaiI/AAAAAAAAE10/5uFjL528DgU/s640/Parking%2Bsign_001.jpg

This case, by comparison, does not demonstrate an example of the 'large lettering' and 'prominent signage' that impressed the Supreme Court Judges and swayed them into deciding that in the specific car park in the Beavis case alone, a contract and 'agreement on the charge' existed.

Here, the signs are sporadically placed, indeed obscured and hidden in some areas. They are unremarkable, not immediately obvious as parking terms and the wording is mostly illegible, being crowded and cluttered with a lack of white space as a background. It is indisputable that placing letters too close together in order to fit more information into a smaller space can drastically reduce the legibility of a sign, especially one which must be read BEFORE the action of parking and leaving the car.

It is vital to observe, since 'adequate notice of the parking charge' is mandatory under the POFA Schedule 4 and the BPA Code of Practice, these signs do not clearly mention the parking charge which is hidden in small print (and does not feature at all on some of the signs). Areas of this site are unsigned and there are no full terms displayed - i.e. with the sum of the parking charge itself in large lettering - at the entrance either, so it cannot be assumed that a driver drove past and could read a legible sign, nor parked near one.

This case is more similar to the signage in POPLA decision 5960956830 on 2.6.16, where the Assessor Rochelle Merritt found as fact that signs in a similar size font in a busy car park where other unrelated signs were far larger, was inadequate:

''the signage is not of a good enough size to afford motorists the chance to read and understand the terms and conditions before deciding to remain in the car park. [...] In addition the operators signs would not be clearly visible from a parking space [...] The appellant has raised other grounds for appeal but I have not dealt with these as I have allowed the appeal.''

From the evidence I have seen so far, the terms appear to be displayed inadequately, in letters no more than about half an inch high, approximately. I put the operator to strict proof as to the size of the wording on their signs and the size of lettering for the most onerous term, the parking charge itself.

The letters seem to be no larger than .40 font size going by this guide:

[link removed]

As further evidence that this is inadequate notice, Letter Height Visibility is discussed here:

[link removed]

''When designing your sign, consider how you will be using it, as well as how far away the readers you want to impact will be. For example, if you are placing a sales advertisement inside your retail store, your text only needs to be visible to the people in the store. 1-2' letters (or smaller) would work just fine. However, if you are hanging banners and want drivers on a nearby highway to be able to see them, design your letters at 3' or even larger.''

...and the same chart is reproduced here:

[link removed]

''When designing an outdoor sign for your business keep in mind the readability of the letters. Letters always look smaller when mounted high onto an outdoor wall''.

''...a guideline for selecting sign letters. Multiply the letter height by 10 and that is the best viewing distance in feet. Multiply the best viewing distance by 4 and that is the max viewing distance.''

So, a letter height of just half an inch, showing the terms and the 'charge' and placed high on a wall or pole or buried in far too crowded small print, is woefully inadequate in an outdoor car park. Given that letters look smaller when high up on a wall or pole, as the angle renders the words less readable due to the perspective and height, you would have to stand right in front of it and still need a stepladder (and perhaps a torch and/or magnifying glass) to be able to read the terms.

Under Lord Denning's Red Hand Rule, the charge (being 'out of all proportion' with expectations of drivers in this car park and which is the most onerous of terms) should have been effectively: 'in red letters with a red hand pointing to it' - i.e. VERY clear and prominent with the terms in large lettering, as was found to be the case in the car park in 'Beavis'. A reasonable interpretation of the 'red hand rule' and the 'signage visibility distance' tables above and the BPA Code of Practice, taking all information into account, would require a parking charge and the terms to be displayed far more transparently, on a lower sign and in far larger lettering, with fewer words and more 'white space' as background contrast. Indeed in the Consumer Rights Act 2015 there is a 'Requirement for transparency':

(1) A trader must ensure that a written term of a consumer contract, or a consumer notice in writing, is transparent.
(2) A consumer notice is transparent for the purposes of subsection (1) if it is expressed in plain and intelligible language and it is legible.

The Beavis case signs not being similar to the signs in this appeal at all, I submit that the persuasive case law is in fact 'Vine v London Borough of Waltham Forest [2000] EWCA Civ 106' about a driver not seeing the terms and consequently, she was NOT deemed bound by them.

This judgment is binding case law from the Court of Appeal and supports my argument, not the operator's case:

[link removed]

This was a victory for the motorist and found that, where terms on a sign are not seen and the area is not clearly marked/signed with prominent terms, the driver has not consented to - and cannot have 'breached' - an unknown contract because there is no contract capable of being established. The driver in that case (who had not seen any signs/lines) had NOT entered into a contract. The recorder made a clear finding of fact that the plaintiff, Miss Vine, did not see a sign because the area was not clearly marked as 'private land' and the signs were obscured/not adjacent to the car and could not have been seen and read from a driver's seat before parking.

So, for this appeal, I put this operator to strict proof of where the car was parked and (from photos taken in the same lighting conditions) how their signs appeared on that date, at that time, from the angle of the driver's perspective. Equally, I require this operator to show how the entrance signs appear from a driver's seat, not stock examples of 'the sign' in isolation/close-up. I submit that full terms simply cannot be read from a car before parking and mere 'stock examples' of close-ups of the (alleged) signage terms will not be sufficient to disprove this.


3. Landowner authority: No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the BPA Code of Practice

As this operator does not have proprietary interest in the land then I require that they produce an unredacted copy of the contract with the landowner.

The contract and any 'site agreement' or 'User Manual' setting out details - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights, and of course all enforcement dates/times/days, and the boundary of the site - is key evidence to define what this operator is authorised to do, and when/where.

It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is authorised on the material date, to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only).

Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules. A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement.

Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic but crucial information such as the site boundary and any bays where enforcement applies/does not apply. Not forgetting evidence of the only restrictions which the landowner has authorised can give rise to a charge, as well as the date that the parking contract began, and when it runs to, or whether it runs in perpetuity, and of course, who the signatories are: name/job title/employer company, and whether they are authorised by the landowner to sign a binding legal agreement.

Paragraph 7 of the BPA CoP defines the mandatory requirements and I put this operator to strict proof of full compliance:

7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:

a the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined

b any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation

c any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement

d who has the responsibility for putting up and maintaining signs

e the definition of the services provided by each party to the agreement

4. Genuine pre-estimation of Loss and commercial justification
The demand for a payment of £100 (discounted to £50 if paid within 14 days, returned to £100 and reduced once more following appeal) is punitive, unreasonable, exceeds an appropriate amount, and has no relationship to the loss that would have been suffered by the Landowner. The keeper declares that the charge is punitive.
The BPA code of practice states: The BPA Code of Practice states:
“19.5 If the parking charge that the driver 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.
19.6 If your parking charge is based upon a contractually agreed sum, that charge cannot be punitive or unreasonable. I require LCP to provide a detailed breakdown of how the amount of the “charge” was calculated. I am aware from Court rulings and previous POPLA adjudications that the cost of running the business (such as the erection of signage, the provision of back office services, the maintenance of ANPR cameras, cost of membership of the BPA Ltd etc.) may not be included in this pre-estimate of loss.

The Department for Transport guidelines state that:
"Charges for breaking a parking contract must be reasonable and a genuine pre-estimate of loss. This means charges must compensate the landholder only for the loss they are likely to suffer because the parking contract has been broken. Charges may not be set at higher levels than necessary to recover business losses and the intention should not be to penalise the driver."

In addition, the Office of Fair Trading information to the BPA about parking charges states that these are not automatically recoverable: ''The OFT expressed the view that a parking charge will not automatically be recoverable, simply because it is stated to be a parking charge. It cannot be used to create a loss where none exists.”.

I am aware from previous POPLA findings this same site that this Operator has not proved the above to be a genuine pre-estimate of loss. On 13/12/13 POPLA Assessor Sakib Chowdhury stated in a decision about the same issue at Harlesden Plaza, that ''The amount put forward that could amount to a genuine pre-estimate of loss, does not amount to a substantial proportion of even the reduced charge. Consequently, I must find that the Operator has failed to produce sufficient evidence to demonstrate that the parking charge is a genuine pre-estimate of loss.''

Premier Park has not provided a written calculation of their losses prior to their decision to set their PCNs at a fixed sum of £100 (or £50) at this site. Therefore, the charge is punitive in nature.

The Supreme Court, in the case ParkingEye Vs Beavis, allowed for charges, which are not genuine pre-estimation of loss, under very specific conditions of commercial justification where such charges are not “unconscionable and extravagant”. In this case, Premier Park has not made known what the commercial justification is, and hence it is not evidenced that the charges, which are not a genuine pre-estimation of loss, are not “unconscionable and extravagant” under the current context. Without such evidence, the particular case of ParkingEye Vs Beavis cannot be relied upon for this case.

5. ANPR Accuracy and Compliance
Premier Park is obliged to ensure their ANPR equipment is maintained as described in the BPA Code of Practice that states under paragraph 21.3, parking companies are required to ensure ANPR equipment is maintained and is in correct working order. I question the entire reliability of the system and require Premier Park to provide records with dates and times of when the equipment was checked, calibrated, maintained and synchronised with the timer which stamps the photo to ensure the accuracy of the ANPR images. This is important because the entirety of the charge is founded on two images purporting to show my vehicle entering and exiting at specific times. It is vital that this Operator must produce evidence in response and explain to POPLA how their system differs (if at all) from the flawed ANPR system which was wholly responsible for the court loss recently in ParkingEye v Fox-Jones on 8 Nov 2013. That case was dismissed when the judge said the evidence from ParkingEye was fundamentally flawed because the synchronisation of the camera pictures with the timer had been called into question and the operator could not rebut the point.

Replies

  • 6. ANPR Usage code of conduct
    The CCTV Code of Practise issued by the Information Commissioner’s Office (ICO) - which covers all surveillance systems including ANPR and any other camera system used for enforcement - states in section 9.1 “You must let people know when they are in an area where a surveillance system is in operation. The most effective way of doing this is by using prominently placed signs at the entrance to the surveillance system’s zone and reinforcing this with further signs inside the area. This message can also be backed up with an audio announcement, where public announcements are already used, such as on a train. Clear and prominent signs are particularly important where the surveillance systems are very discreet, or in locations where people might not expect to be under surveillance. As a general rule, signs should be more prominent and frequent in areas where people are less likely to expect that they will be monitored by a surveillance system. This is particularly important when an ANPR system is being used that covers a large area.”
    The BPA code states under paragraph 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”.
    Furthermore, Surveillance Camera Code of Practice published Pursuant to Section 30 (1) (a) of the
    Protection of Freedoms Act 2012 - point 2.6 paragraph 3 states “There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints.”
    In this case, there is no sign at the entrance informing the drivers that they are being subjected to surveillance (photographic evidence submitted). Moreover, the obscure and unlit signage does not highlight this information either, nor contains details of a published contact point for access to information and complaints required under PoFA 2012. This renders the evidence of parking times based on images obtained using illegal surveillance unacceptable as evidence.


    I respectfully request that this appeal is upheld and the charge dismissed.
  • edited 31 December 2019 at 11:01AM
    FruitcakeFruitcake Forumite
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    edited 31 December 2019 at 11:01AM
    Never use "without prejudice" unless you really, really, know what it means.

    An NTK does not need to specify that it is a notice to keeper since it is a notice that is sent to the keeper at their address for service.

    4. GPEOL went out in 2015 with the Beavis case, so ditch that. You appear to have used an old version of the BPA CoP as well.

    Put quotes in quotation marks. Make sure the quotes are correct as the wording you use in 5. where you refer to the CoP para 21.3 is not exactly the same as in the current CoP.

    You will need to embed images in the real thing rather than include links. That way the assessor is forced to look at them.
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  • The_DeepThe_Deep Forumite
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    [FONT=Times New Roman, serif][FONT=Times New Roman, serif]Nine times out of ten these tickets are scams, so consider complaining to your MP, it can cause the scammer extra costs and work, and has been known to get the charge cancelled.

    Parliament is well aware of the MO of these private parking companies, many of whom are former clampers, and on 15th March 2019 a Bill was enacted to curb the excesses of these shysters. Codes of Practice are being drawn up, an independent appeals service will be set up, and access to the DVLA's date base more rigorously policed, persistent offenders denied access to the DVLA database and unable to operate.

    Hopefully life will become impossible for the worst of these scammers, but until this is done you should still complain to your MP, citing the new legislation.

    [/FONT][FONT=Times New Roman, serif]http://www.legislation.gov.uk/ukpga/2019/8/contents/enacted[/FONT][FONT=Times New Roman, serif]

    Just as the clampers were finally closed down, so hopefully will many of these Private Parking Companies.[/FONT][/FONT]
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  • Thank you. I'll remove "without prejudice", I've read up on what it means now.

    Regarding the NTK: I will drop the line "It does not state explicitly anywhere whether it is a Notice to Keeper or a Notice to Driver" and retain the rest.

    I'll remove the point on GPEOL, but wanted to highlight the fact that Premier Park have not provided "commercial justification" for the charges either. Is that something that can be pursued? I have included this at the bottom of the GPEOL point. Any advice on how to include that, if at all?

    Noted your comment on quoting CoP exactly and updating the text with latest version. Also embedding images instead of links.
  • Thanks "the Deep". I'll will write to my local MP. But want to first get the appeal out of the way as the deadline is coming up soon.
  • Coupon-madCoupon-mad
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    Remove #4, #5 and #6.

    Make signage your first point instead, as this is what you might win on, if you embed photos to support what you are saying (taken in the dark):
    Car was caught parked for 2:43 hrs on a dark rainy afternoon with poor visibility. This parking was free previously, but recently restrictions have been put in place for 2 hrs free parking. The new signs are pretty obscure.
    Your POPLA code will last a max 33 days. Not just 28. So, you have time to get some photos of the signs in the rain and dark with no flash, as that is what will win your case if you show good evidence.

    Premier Park win lots of POPLA cases and you will not win on your other points but include the landowner and POFA ones anyway, to keep them busy.

    Also embed a screen shot of the BPA CoP about new restrictions/extra signs needed.
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  • Thank you Coupon-mad. I will see if I get a dark and wet day like that day to replace my current photos with those (fingers-crossed). That was when we were experiencing sudden very heavy showers with thunder-storms.

    I have now added the BPA CoP section 18.10 about new signs. Here is the new text:
    In addition, the parking charges have been recently put up. As can be seen from the following photo taken from Google Street Maps - which are a snapshot of some time back - the signs are not present as was shown in the previous photos:

    At the entrance:
    [Photo from Google Street View goes here]

    And inside the parking, showing the parking spot in question:
    [Photo from Google Street View goes here]

    The BPA Code of Practice paragraph 18.10 states “Where there is a change in the terms and conditions that materially affects the motorist then you must make these terms and conditions clear on your signage. Where such changes impose liability where none previously existed then you must consider a transition to allow regular visitors to the site to adjust and familiarise themselves with the changes. Best practice would be the installation of additional/ temporary signage at the entrance and throughout the site making it clear that new terms and conditions apply. This will ensure such that regular visitors who may be familiar with the previous terms become aware of the new ones.”. In this case, as can be seen from previous photos, no attempt has been made to make the regular users aware of new changes in parking conditions.

    Any further comments/suggestions?
  • Coupon-madCoupon-mad
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    Lay it on thick earlier on about the fact it was dark and when the area was experiencing sudden very heavy showers with thunder-storms. ]

    In fact have that in the sub-heading about unclear signs, so POPLA can't miss it, and make sure your photos are not clear (i.e. no putting in photos where the signs can be read).

    Do take the extra days to day 33 to get photos in the dark; it is your winner.
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