POPLA appeal - PPS parking - Western Gateway (HM Passport Office) - advice on response wording

amidamaru22

 Hi all

 

Looking for some help with this “red route” PCN on private land. I submitted the below initial appeal based on newbies thread, and have got the below rejection mail, with POPLA code.

 

I was actually sat in the car the whole time (10 mins) outside the passport office (waiting for my 70 year old uncle who couldn’t go by train and cannot walk very far). The “officer” clearly took the photos while I was sat in the car, rather than maybe first coming and telling me to movie (typical), I should’ve maybe been more vigilant of their presence.

 

I have also attached the photos uploaded (here) and you can see that I wasn’t parked next to the sign so would reasonably have to get out of the car to even look at it and learn the restrictions.

 

 Initial letter from PPS: 

 Initial appeal text to PPS:

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.

 

There will be no admissions as to who was driving and no assumptions can be drawn. Since your PCN is a vague template, I require an explanation of the allegation and your evidence. You must include a close up actual photograph of the sign you contend was at the location, and that there was sufficient signage at the entrance to the road facing the driver, such that a driver would not have to stop and get out of the car to read the sign. Clearly, the only sign in the area, as shown in your photo, is not facing the road and there was no sign at the entrance (as seen in attached).

 

Response/rejection from PPS:

 

“Further to your appeal received regarding the above parking charge, I have now had the opportunity to review this case and my findings are below.

Parking at Royal Victoria Dock, 1 Western Gateway, London is only for the vehicles that are parked in accordance with the site instructions, as detailed on signage on site; the signage is clear, in excess of industry standards, stating:

 

RED ROUTE

NO PARKING AT ANY TIME

 

NO PARKING ON RED ROUTES OR PEDESTRIAN FOOTPATHS

NO WAITING OT RED ROUTES OR PEDESTRIAN FOOTPATHS

NO LOADING/ UNLOADING OT RED ROUTES OR PEDESTRIAN FOOTPATHS

 

The charge was issued because your vehicle was parked on red route, which is a direct contravention of the advertised on the

signage terms and conditions.

The signage, placed prominently, is sufficient to inform drivers that they are entering private land and need to be aware of terms

and conditions once they are within the car park itself. It also made clear that failure to comply with the terms offered, regardless

of the reason, would result in the issue of a £100 PCN.

Please note that double red lines mean that rules and regulations apply at all times and on all days. Red lines are meant to ease

congestion in traffic hot spots, so they mean no stopping at any time. The double and single red lines used on Red Routes indicate

that stopping to park, load/unload or to board and alight from a vehicle is prohibited.

Having considered the photographs provided by the warden, it is evident that a sign detailing the specific terms was positioned in

close proximity to your parked vehicle. Signage clearly states no parking on red routes. Responsibility rested with the driver to

read the signs and ensure they adhere to the advertised terms in order to avoid the possibility of a PCN being issued.

This site is private land with its own terms and conditions and the motorist is to adhere to the terms as set out. The evidence

shows that your vehicle was parked on red route, and therefore, in breach of the advertised in the signage terms.

For the reasons noted above, we find the PCN was issued correctly, and we refuse your appeal.

Ultimately, it is the responsibility of the motorist to read the signs and adhere to the terms and conditions of the site.”

 

Draft response to POPLA (based on this post from the same issue earlier this year and reference to Henry Greenslade as mentioned here)

 

I am writing as the registered keeper of the above vehicle to formally appeal against the Parking Charge Notice issued by Private Parking Solutions (PPS). The PCN alleges the vehicle was parked on double red lines; however, I dispute the charge on the following grounds:

1. Inadequate and Poorly Positioned Signage The only visible signage was installed parallel to the road and not facing oncoming traffic, contrary to requirements for clear and prominent signage. This made it impossible to view or read from a drivers approach.

2. Signage Obstructed by Another Vehicle At the time, a large Restore van was parked directly in front of the sign as shown in the photos, completely obstructing visibility. Your own photographic evidence shows this obstruction. There were no other signs next to or in front of the vehicle to inform of any restrictions.

3. No Reasonable Opportunity to Understand Terms Before Alleged Contravention Due to the lack of visible signage, the driver exited the vehicle to locate and read the sign. After establishing the nature of the restriction, the vehicle left the area shortly afterward. Your own photos show the vehicles indicator light on and in the process of leaving, during which no parking activity (as defined in the BPA Code of Practice) took place.

4. Non-Compliance with BPA Code of Practice and PoFA 2012 As the registered keeper, I have not been provided with sufficient evidence that your signage complies with the British Parking Associations Code of Practice, nor that the conditions for keeper liability under the Protection of Freedoms Act 2012 Schedule 4 have been met. In light of the above, I request that this Parking Charge Notice be cancelled. Should you choose to reject this appeal, please provide a POPLA verification code so I may refer the matter to the independent appeals service.

5. The roads leading to the passport office are not public roads, they are laid out to appear like public roads and include double red lines next to kerbs, there are no markings on the kerbs themselves. In order for a driver to read any roadside signs it would be necessary to stop which could trigger a charge from UKCPS.

'No stopping' markings should be red and there is an annual report from POPLA which IAS will be familiar with, where Lead Adjudicator, barrister Henry Greenslade refers to what a no stopping zone must look like with red lines and repeater signs. These signs do not exist at the entrance to Western Gateway nor are there repeater signs through the area.

 

 

Is there anything else you can recommend I add in the POPLA appeal or anything I have missed?

 

Thanks in advance!

Coupon-mad

A 'red route' requires repeater signs where the terms and a clearway logo are facing traffic.

Bet that's not the case. Take it to POPLA but you will have to spell out the requirements for a properly signed red route.

amidamaru22

Added POPLA rejection comments here https://forums.moneysavingexpert.com/discussion/comment/81929733/#Comment_81929733

Coupon-mad

"They used pictures showing signs at the entrace - from a DIFFERENT STREET. and the assessor accepted it as adequate. anyway".

POPLA assessment and decision

29/01/2026

Verification Code

566xxxx756

DecisionUnsuccessful

Assessor summary of operator case

The parking operator has issued a parking charge notice (PCN) due to being parked on the red route.

Assessor summary of your case

The appellant has raised the following points from their grounds of appeal.

• They are appealing the PCN as the registered keeper.

• The PCN alleges the vehicle was parked on double red lines, however they dispute this.

• They say that the signage was inadequate and the signage was poorly positioned.

• The only visible sign was positioned parallel to the road and not facing oncoming traffic.

• They say the signage was impossible to view from the driver’s side so this is contrary to requirements for clear and prominent signage.

• They state, no stopping markings should be red and there is an annual report from POPLA, where Lead Adjudicator, barrister Henry Greenslade refers to what a no stopping zone must look like with red lines and repeater signs. These signs do not exist at the entrance to Western Gateway nor are there repeater signs through the area.

• The signage was also obstructed by another oncoming vehicle, and there was no opportunity to consider the terms and conditions.

• Non-Compliance with BPA Code of Practice and PoFA 2012 As the registered keeper.

After reviewing the parking operator’s evidence, the appellant reiterates their grounds of appeal regarding signage and state that the picture of the entrance sign is not there, and they have provided an image from Google street view.

They say that the contract does not have any provision for grace periods which should be required in private car parks for time to enter and decide over whether the driver wants to accept the contract or not.

The appellant has provided the following evidence to support their appeal.

• Photograph showing the entrance to Western Gateway. The above evidence will be considered in making my decision.

Assessor supporting rational for decision

The Protection of Freedoms Act (PoFA) 2012 is a law that allows parking operators to transfer the liability to the registered keeper if the driver or hirer is not identified. Parking operators must follow certain rules including warning the registered keeper that they will be liable if the parking operator is not provided with the name and address of the driver.

In this case, the PCN in question has the necessary information and the parking operator has therefore successfully transferred the liability onto the registered keeper as the driver details were not provided on request.

They say that the PCN stated they parked on double red lines, but they dispute this and say that the signage was inadequate. The appellant has also referred to sections of the BPA’s code of practice, however the Single Code of Practice has been jointly created by the British Parking Association (BPA) and the International Parking Community (IPC) and is largely based on the Government’s Private Parking Code of Practice, so this is what I will use to summarise my reasons as this was affective from the 1st of October 2024, and the parking event occurred on the 13th of October 2025.

Section 3.1.1 of the Single Code of Practice states that there must be an entrance sign displayed and maintained at the entrance to the site, to inform drivers whether parking is permitted subject to terms and conditions or prohibited.

The operator has provided an image of the entrance sign that tells drivers that there is no parking on red routes, and to see signs for full parking terms and conditions.

After consideration, I am satisfied that this complies with section 3.1.3 of the Single Code of Practice, and drivers are warned accordingly on entrance to Royal Victoria Dock, 1 Western Gateway, London, E16 1XL

The appellant has provided an image taken from Google Street View from 2023 for 11 Western gate.

Section 3.1.3 of the Single Code of Practice contains the requirements for signs displaying the terms and conditions. The signs must be placed throughout the site, so that drivers have the opportunity to read them when parking or leaving their vehicle. The terms and conditions must be clear and unambiguous, using a font and contrast that is be conspicuous and legible.

The operator has also provided images of the signs that tell drivers that there is no parking on the red route and the area is monitored 24 hours and day, 7 days a week. The signage also says there is no waiting on the red routes or pedestrian footpaths. These images are date stamped the 13th of October 2025, when this contravention took place.

Although I can see a van Infront of the appellants vehicle, there is also a sign behind.

After consideration, I am satisfied that the signage complies with section 3.1.3 of the Single Code, as the term and conditions are clear for drivers to see and understand, and the driver had the opportunity to view them had they of wished.

In addition to this, the double red lines are clearly identifiable as a restricted red route.

Section 5.1 of the Single Code of Practice states that parking operators must allow a consideration period of appropriate duration, subject to the requirements set out in Annex B to allow a driver time to decide whether to park. In this case, a 5-minute consideration period must be applied to allow motorists time to view the signs and leave if they are unable to comply.

However, the operators’ images are from 11:20 until 11:43, so the driver accepted the terms of a contact by parking on the red route and remaining for longer than the 5-minute consideration period, instead of reading the signs and leaving when immediately if they did not want to cause this PCN to be issued.

The operator has provided images of the appellants vehicle parked on the red route for a 43-minute duration, so this caused the PCN to be issued.

Section 5.2 of the Single Code of Practice requires a parking operator to allow a grace period in addition to the parking period. The Code advises that grace periods do not apply other than where a driver has parked in compliance with the terms and conditions of the area, nor is a grace period a free period of parking. In this case, a 10-minute grace period does not apply as this is only appropriate when a motorist has parked in compliance with the terms and conditions and must be afforded time to leave, like a pay as you go site or maximum say. This does not apply in this case as the driver was in breach of the terms by parking on the red route.

After considering the evidence from both parties, the driver parked on the red route, so therefore did not comply with the terms and conditions of the site. As such, I am satisfied the parking charge has been issued correctly and I must refuse the appeal.

Just ignore them.