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APCOA - Railway Penalty Notice via ANPR - Any new ideas since the recent lost POPLA appeal?


In April this year I received the attached Penalty Notice for parking at my local railway station. Having read the newbies and Railway bylaws threads I was initially encouraged that I'd be able to avoid a fine by following the usual approach that keeper liability under PoFA 2012 does not apply on Railway land. However in the recent example posted by Kite2010 here POPLA have not accepted the appeal saying it is legal to transfer liability to the owner.
I have already submitted my initial response to APCOA based on the template with some tweaks relevant to my situation. See below for wording.
Re: Notice letter numbered XXXXXX
I dispute your 'parking charge', as the keeper of the vehicle. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
No assumptions should be drawn as to the owner or driver. Since your letter is based on a template, I require a detailed explanation of the allegation and your evidence to be provided.
Please include:
• Clear, close-up photograph(s) of the relevant signage you contend was at the location on the material date
• Clear images which identify the vehicle
• Clear images of the vehicle using the car park
• Full details of the alleged offence
I'd be very grateful if any experts have some suggestions of new strategies to employ here? Initial thoughts - the photos are not very clear, no photos of the vehicle actually parked (you can drive through this car back as a short cut)
Thanks in advance


Comments
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Why did the vehicke get a ticket? Was payment made?From the Plain Language Commission:
"The BPA has surely become one of the most socially dangerous organisations in the UK"1 -
Yes, the 'offence' is no payment made for parking - via the Ringo App0
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Advice is to string it out, as 'byelaws' Penalties (even fake ones like this) time out after just 6 months.
So, when you get the rejection letter or email (check your email junk folder!) work out the last day to do the POPLA appeal which - contrary to the lies on the POPLA website and the rejection letter - is actually DAY 33.
Do your POPLA appeal on day 33. Here's a thread to help, as they are ahead of you in this game to time out an APCOA penalty or win at POPLA (either will do):
https://forums.moneysavingexpert.com/discussion/6338518/apcoa-railway-station-penalty-notice-on-company-van/p1
Why didn't the driver pay and display? Was the car only there minutes?
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