Charge for stopping in traffic Bristol Airport

Boudouche1

Here is the top part of the letter

Umkomaas

Let's see the rest of it (redact your personal data). Does it give you 14 days or 30 days to respond?

Fruitcake

Just to confirm (to save me reading back) is this the PCN where you were a passenger and the driver had to stop because of a broken down bus? I ask because I think you may have another No-Stopping PCN for Bristol Airport, and I'm helping at least one other poster as well for another similar PCN. I get confused easily you see. 

Boudouche1

@Umkomaas . I am given 30 days to respond, please see the redacted ltter below:

Boudouche1

And now the second part of the Letter Before Claim:

(Image removed by Forum Team)

Boudouche1

@Fruitcake, you are correct. This PCN is issued with regards to the car stopping in traffic because of the broken down bus. There was a lot of traffic and cars stopped at different stages of North Airport Road even before the event that was caught on camera by VCS. I was trying to see if I can obtain stills from VCS for all those stoppages.

I have also received another (ealrier) PCN where the car stopped at the exit from the long-stay car park, and where there were no red lines. YOu were helping me wiht the other case as well - but the Letter Before Claim does not refer to that earlier incident.

Umkomaas

That's a LBC so send a robust response telling them you will rely on Protection of Freedoms Act 2012 (Schedule 4) (airport not relevant land for the purpose of holding the registered keeper liable) and on the persuasive Appeal Court judgment in VCS v Edward. 

Should they proceed, you reserve the right to claim your full costs on account of their unreasonable behaviour under CPR part 27. 

The NEWBIES FAQ Announcement, second post, covers the writing of a robust response.  Other regulars might be able to sharpen up my outline above. 

Boudouche1

The MSE Forum team has removed the second part of the letter, where I forgot to remove the name of the responding offcier. My bad, I did not notice this earlier - I have now edited this letter as advised, see below

Boudouche1

Thank you @Umkomaas for your advice. I am a bit confused to where to find an example of the robust response. After reading it many times, I think I have now memorised different steps described in the Newbies advice page on the MSE Forum, but cannot locate the specific piece of advice you mention.

I am confused. It seems that I need to provide SAR rather than a robust response. If I do write a response, where do I send it - to VCS's DPO (postal address mentioned on the Privacy page) or to VCS's Litigation department (postal address on the Letter Before Claim)?

Umkomaas

There's no template, if that's what you are seeking. I've given you some ideas to build into your response (and others might throw some thoughts in too), give it a day or so. You could require them to put the claim on hold for 30 days for you to obtain debt advice. That kicks the can down the road, but you might find yourself having to do all the defence work over Christmas. 

If I do write a response, where do I send it - to VCS's DPO (postal address mentioned on the Privacy page) or to VCS's Litigation department (postal address on the Letter Before Claim)?

The DPO won't be dealing with LBC. Hold off sending a SAR as it's likely their eventual PoC (part of the County Court Claim form, you don't have those yet) will be woefully inadequate in detail, and it's against that deficiency you will be defending. So you don't really want to acquire any SAR as they might argue you then have all the details between the PoC and the SAR.