Trolling/Taking down Moorside

doubledotcom

It really is simple. I have reported 2 more firms today (SABA and APCOA) over their use of civil claims threats for Penalty Notices issued under Railway Byelaw statute.

Coupon-mad

doubledotcom said:

It really is simple. I have reported 2 more firms today (SABA and APCOA) over their use of civil claims threats for Penalty Notices issued under Railway Byelaw statute.

I am so pleased you are doing this.

This is an important fightback route since the DMCC Act handed regulatory powers to the CMA.

doubledotcom

I'm also in the process of preparing one for the industry as a whole and showing the imbalance of consumer protections and the links between the ATAs, the AOS members and the ADRs.

This is there draft brief that I have prepared but I will need to expand on it for the final complaint:

Private parking enforcement in Great Britain is dominated by two DVLA-accredited trade associations: the British Parking Association (BPA) and the International Parking Community (IPC). Government figures analysed by motoring organisations indicate that private parking firms issued around 14.4 million tickets in the 12 months to March 2025 – in the region of 40,000 tickets every day. Of these, BPA members alone reportedly issued over 11.6 million parking charge notices in 2024.

The BPA is incorporated as “British Parking Association (The)” (company no. 00979689), a company limited by guarantee. Appeals against tickets issued by BPA members can ultimately be escalated to Parking on Private Land Appeals (POPLA). POPLA is not operated by the BPA itself but by Trust Alliance Group Limited (company no. 04351294) under contract. Recent POPLA reports indicate that it now considers on the order of 80,000–90,000 appeals a year, and that roughly 40% of those appeals result in the parking charge being cancelled, either because the operator does not contest the appeal or because the appeal is upheld by POPLA. While this still represents only a small proportion of the millions of tickets issued, there is at least a degree of institutional separation between the trade body and the second-stage appeals service.

The IPC’s structure is markedly different. The International Parking Community and the so-called Independent Appeals Service (IAS) are both trading names of United Trade and Industry Limited (company no. 08248531). In other words, the trade association representing parking operators and the “independent” appeals body are part of the same corporate entity. Available data suggest that only a very small fraction of IPC tickets progress to the IAS and that, in the most recently reported period, around 94% of IAS appeals were rejected. The IPC does not publish comprehensive, up-to-date statistics on the volume and outcomes of appeals.

In practice, therefore, tens of millions of private parking tickets are issued each year; only a modest proportion are appealed; only a sliver reach a second-stage body; and in the IPC sector, that second-stage body is owned and controlled by the same company as the trade association. This structure creates an obvious conflict of interest and raises serious concerns about the independence, transparency and effectiveness of redress available to consumers. In my submission, this is inconsistent with the standards of fairness and genuine independence that should apply to alternative dispute resolution in a high-volume consumer market, particularly now that the CMA has enhanced powers under the Digital Markets, Competition and Consumers Act 2024.

1505grandad

An observation  -  I see that you state:-

"The BPA is incorporated as “British Parking Association (The)” (company no. 00979689), a company limited by guarantee."

Is it relevant that TAGL is also "a company limited by guarantee.":-

". POPLA is not operated by the BPA itself but by Trust Alliance Group Limited (company no. 04351294) under contract."

doubledotcom

The BPA is a company limited by guarantee. That means it has no shareholders and is structured like a membership body. Its income comes from subscriptions and fees paid by its members, and any surplus is reinvested rather than distributed.

POPLA, the appeals service for BPA members, is not operated by the BPA itself. It is run under contract by Trust Alliance Group Ltd, company number 04351294. This company is a private limited company limited by shares. That means it does have shareholders and can distribute profits. Its accounts show it as a trading entity with turnover of around £15.6 million and reserves of about £6.9 million. POPLA is just one of the services it provides.

The distinction matters. The BPA presents itself as a non‑profit trade association, but it outsources appeals to a profit‑making company. The BPA collects fees from its members and passes money to Trust Alliance Group for each appeal lodged. Trust Alliance Group earns revenue regardless of whether the motorist wins or loses.

This is different from the IPC model. The IPC and its appeals body, the IAS, are both operated by United Trade and Industry Ltd, company number 08248531. That is a private limited company. It owns both the trade body and the appeals service directly. In practice, this means the IPC marks its own homework. Unsurprisingly, motorists win fewer than 5 percent of appeals at IAS.

So the BPA is a membership body limited by guarantee, outsourcing appeals to a profit‑making contractor. The IPC is a private company that owns its own appeals service outright. Both models are problematic, but in different ways. The BPA’s arrangement raises questions about outsourcing consumer redress to a commercial contractor. The IPC’s arrangement is worse, because the trade body and the appeals service are controlled by the same company, creating a direct conflict of interest.

The structures themselves show why the system is stacked against motorists.

Some stats I have been able to collate regarding the BPA → POPLA Funnel (2023/24)

Total BPA PCNs issued: 11.63 million
Operator appeals lodged: ~20% → 2.32 million
Operator cancellations: ≈1% of appeals → ~23,000 cancelled
Operator refusals: ≈99% of appeals → ~2.30 million refused
Escalated to POPLA: ~78,000 (≈3.4% of refused appeals, ≈0.67% of all PCNs)
POPLA outcomes: ~38% upheld (~30,000 motorists win), ~62% refused (~48,000 motorists lose)

Consider those numbers in the overall scheme of things with 11.63 million PCNs issued 2023/2024. Over 9 million PCNs are not appealed, so how many of those are just paid? And that's just BPA member issued PCNs.

We know that cancellation of a PCN is vanishingly rare. Operators almost never admit error at the first stage appeal. Escalation is rare also. Even among the millions refused, only a tiny fraction (≈3.4%) go on to POPLA.

POPLA’s slice of the pie: Out of 11.6m BPA PCNs, only ~78k ever reach POPLA — less than 1 in 150. Every POPLA appeal costs the operator ~£34, win or lose. 78k appeals × ~£34 ≈ £2.65m in fees paid to Trust Alliance Group.

The BPA claims that 52% of operator appeals succeed. On the surface, that sounds like motorists are winning half the time. In reality, it is a deviously misleading figure.

First, the denominator is wrong. The 52% is measured only against the small pool of motorists who actually lodge an appeal with the operator. Most people never appeal at all. Out of 11.6 million tickets issued by BPA members in 2023/24, only about 20% were appealed. That means the 52% figure applies to just 2.3 million cases, not the full 11.6 million.

Second, the definition of “succeed” is distorted. Operators can mark a case as “cancelled” for many reasons: withdrawn, timed out, not pursued, or administratively closed. These are lumped together with genuine cancellations. In practice, very few motorists actually get a PCN cancelled because the operator admits it was wrongly issued. We know through this and FTLA forums when dealing with thousands of motorists, we see cancellation rates closer to 1%, not 52%.

Third, the figure hides the funnel. Even if you accept the 52% claim, it still means that millions of motorists are refused at the first stage. Out of 2.3 million appeals, about 1.1 million were rejected. Yet only a tiny fraction of those refusals ever reach POPLA. In 2023/24, just 78,000 cases escalated, which is 0.67 percent of all BPA PCNs. So the supposed “success rate” is irrelevant to the real picture: almost nobody gets a fair hearing.

Fourth, the presentation is mendacious because it suggests fairness where there is none. By quoting “52 percent succeed,” the BPA implies that operators are generous and motorists are well protected. In reality, the figure is cherry‑picked, inflated by non‑cancellation categories, and divorced from the total number of PCNs issued. It masks the fact that the system is designed to deter appeals and keep motorists paying.

1505grandad

" It is run under contract by Trust Alliance Group Ltd, company number 04351294. This company is a private limited company limited by shares. "

Apologies I must admit it is all over my head/understanding  -  I was going by the info at Companies House (is the statement under "Company type incorrect?):-

doubledotcom

You are right. The Companies House listing is accurate. Trust Alliance Group Ltd is a company limited by guarantee, not by shares. Thank you for catching that — it’s a critical detail when benchmarking corporate structures in this industry.

A company limited by guarantee is typically used for non‑profit organisations, charities, or entities where profits are reinvested rather than distributed to shareholders. It has members, not shareholders, and those members act as guarantors. There is no share capital, so no dividends or ownership stakes.

This structure is unusual for a commercial contractor like Trust Alliance Group, especially given its turnover of ~£15.6 million and its role operating POPLA. But the filing is clear: it is not a company limited by shares.

So to correct the earlier narrative:

POPLA is operated under contract by Trust Alliance Group Ltd, company number 04351294, which is a private company limited by guarantee without share capital. That means it has no shareholders and is structured more like a non‑profit, although it operates commercially and generates significant revenue.

slapPCM

I emailed your generic response to their email "Help@moorsidelegal.co.uk", and received the below automatic reply.

I guess I will have to register on their scam portal now?! Really don't want to...

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ChirpyChicken

It isnt a scam portal 

Coupon-mad

It is fine to use the portal.