Private parking charges by post should allow 21 days at the discount - the Government need reminding

Coupon-mad

As part of the MHCLG draft proposals to come in for 2022, it is proposed that an early payment incentive shall apply across all PCNs, being a 50% discount for PCNs paid within 14 days:

https://www.gov.uk/government/consultations/parking-code-enforcement-framework/outcome/parking-code-enforcement-framework-consultation-response


Just a heads up, ready for the upcoming final 'technical' PUBLIC CONSULTATION (date still TBA) to everyone to remember to include somewhere in your comments, that the 14 days proposal is an unfair error in the proposals and isn't consistent with Local Authority or TFL postal PCN discount periods, when it comes to PCNs issued by post:

58) PCNs for contraventions detected by an approved device cannot be placed on the vehicle or handed to the person who appears to be in charge of the vehicle. They are sent by post to the registered keeper and in under these circumstances, they are offered a 21 day discount period. 

That is because it serves as the Notice to Owner and the extra week takes account of the time taken to post/serve the document, and also if the recipient wants to post a cheque there needs to a time for them to do so.

Some 85% of private PCNs are currently issued by post and they serve as the 'Notice to Keeper'.

This includes parking charges issued by ANPR or CCTV plus predatory 'self-ticketing by app' where people  - who may not be a PPC employee - hide in bushes or at a distance/in a car and take covert photos which they then just upload (often for a £10 bounty advertised, per PCN) and the PPCs run straight to the DVLA instead of giving the driver notice of the alleged breach and a chance to avoid parking like that again and to appeal.

Postal PCNs definitely need 21 days at the discount (more desperately required in the private sector than for LAs) because parking firms don't post them on the 'date issued'.  They are posted several days later, often using a third party mail sorter who sit on them and then finally present them to the Royal Mail the following week. In future that is something I hope has to be proved to Assessors and Auditors as part of the robust new framework promised.

Windscreen PCNs can have 14 days discount at 50% (no argument there). 
However they should be more common because it's the fairest method of ticketing in disabled bays (and achieves a timely and visible deterrent) and at residential car parks where your typical (deliberately targeted) victim has often just moved in and will never know about a PCN posted to their old address. 

There is no excuse when the alleged breach has been detected in person and not remotely by camera.  We need to see more windscreen PCNs and less unjustified DVLA data harvesting.

Le_Kirk

Good sentiment @Coupon-mad but will responders be allowed to (seemingly) add or alter a condition that has already been (again seemingly) agreed by the first consultation?  The latest consultation due in Summer 2021, whenever that is (why don't they give a date rather than a wide range) is surely about "level of parking charges proposed in Chapter 4"  Not saying we shouldn't try but just concerned that a narrative might not be allowed, especially if they do it as series of tick boxes showing different levels of charges.  Some lateral thinking might be required - I'm good at that apparently; I am told I can't think straight!

Coupon-mad

There is bound to be a comments box, one would hope! 

Also, last time the MHCLG allowed comments by email and that’s how I did mine, with links, evidence, tables and pictures.