Help with confirming the next step? Civil Enforcement x 2 - Letter before action

thisisconfusing

Hello I wonder if anyone can offer any assistance?

OVERVIEW:
I have a small one director limited company.
- I have 2 x "Parking Charge Notices" from Civil Enforcement Ltd - BPA member - for a van owned by my company. 
- These were both sent by post to an old address (previous registered office)
- By the time I got the letters we were already at debt collection stage with several letters from DCBL.
- 8th August 2025 Civil Enforcement sent a Letter before action 
- After reading this forum I responded to the Letter before action by email challenging them (See below). This was my first contact with them. 

- They have responded and rejected, giving 14 days before action (see below) 

QUESTIONS:

1 - Is my next step to appeal to POPLA? What is my appeal grounds?

2 - Do I need to request a POPLA reference number from CIVIL ENFORCEMENT (i don't think they have provided one yet) 
3 - These were the first letters from Civil Enforcement - Are these deemed the "Notice To Keeper"? and if so what ground for defence do they offer?

A1 

B1

OTHER SUPPORTING DOCS 

== Response to Letter Before Action == 

21st August 2025 
To the Legal Team
Civil Enforcement Ltd  

I am responding to your two letters before action and to formally challenge the proposed Legal proceedings for two Parking Charge Notices issued to vehicle registration [xxxxxx
- Your ref: xxxxxxxx 19th July 2024
- Your ref: xxxxxxxx 24th JUly 2024

- We confirm that Slayers Bay Ltd is the vehicle's hirer and keeper for the purpose of the corresponding definitions under Schedule 4 of the Protection of Freedoms Act 2012 ("POFA")
- However the alleged debt is disputed and any court proceedings will be vigorously defended. 
 
You provide no evidence in support of the alleged breach and we see no grounds for why you expect xxxxxxx to pay this charge.
Further the PCN failed to comply with the strict requirements of Schedule 4 of POFA and consequently Civil Enforcement has forfeited any right to claim unpaid parking charges from Slayer's Bay Ltd as the vehicle's hirer and keeper.

Within 28 days please provide us with written confirmation of Civil Enforcement Ltd's acceptance that it cannot and does not hold Slayer's Bay Ltd liable for this parking charge.

== Their Response == 



Thank you for reading this all! 

thisisconfusing

ADDITIONAL
- I had an email conversation with the Health Centre where the van was parked 
They offered to confirm that XXXXX had attended appointments on both days but said that they couldn't cancel the notice 
See both of their responses below

1.
Thank you for your email. We can write a confirmation letter which will confirm XXXXX attended for an appointment on those dates/times, however this will not cancel the fine, likely only reduce the amount to pay. Please confirm if this is what you would like us to do and I can organise this letter for you.
Kind regards,
Barbourne Health Centre

- I replied and asked them if they could get the charge cancelled 

2.

Good morning

We can only supply you with confirmation of attendance and then you use that together with your appeal. We do not have any control over the fines as this is dealt with by the parking company. You will need to follow the appeals process.

Please let us know of any letters you may require us to supply with names and dates of attendance.
Kind Regards

Patient Services Manager 

I didn't know what to do with this as getting such a letter would give Civil Enforcement details of who was driving??

Coupon-mad

Same as my reply here:

https://forums.moneysavingexpert.com/discussion/6642663/advice-needed-please-civil-enforcement-pcn#latest

Too late for POPLA but honestly, who cares? Defending a generic CEL claim is ten times easier than the BPA's non-impartial POPLA.

And obviously giving details of who attended an appointment doesn't make that person necessarily the driver of a 5 seater car. Not that CEL will cancel so that us futile anyway if the landowner won't step in and tell them to cancel.

Bring on the small claim. Honestly.

thisisconfusing

thank you I will read!
- can someone also tell me how to edit my post - I want to remove an identifying detail!!

thisisconfusing

Coupon-mad said:

Same as my reply here:

https://forums.moneysavingexpert.com/discussion/6642663/advice-needed-please-civil-enforcement-pcn#latest

Too late for POPLA but honestly, who cares? Defending a generic CEL claim is ten times easier than the BPA's non-impartial POPLA.

And obviously giving details of who attended an appointment doesn't make that person necessarily the driver of a 5 seater car. Not that CEL will cancel so that us futile anyway if the landowner won't step in and tell them to cancel.

Bring on the small claim. Honestly.

So are you saying I just wait for them to take it to action?
it doesn't say in that post how I will then defend that action?
Which post do I need to read for that?

I am also concerned as the address they are using to contact - I have to rely on other folks passing it on to me - which sometimes they dont...  I could easily miss a letter if it isn't passed on. 

Coupon-mad

Read post 2 of the NEWBIES thread.

Email whoever has an old address, the relevant "note my address/erase the old one" paragraph taken from the standard LBC reply. 

Le_Kirk

thisisconfusing said:

thank you I will read!
- can someone also tell me how to edit my post - I want to remove an identifying detail!!

You cannot edit your posts until you have a certain number of posts under your belt and been a member for a certain time but nobody knows those figures!  You will be able to edit when your status changes from Newbie to Forumite.  If you are desperate to remove something, you could report your post and ask the Forum Team to delete it.

thisisconfusing

Coupon-mad said:

Read post 2 of the NEWBIES thread.

Email whoever has an old address, the relevant "note my address/erase the old one" paragraph taken from the standard LBC reply. 

Thank you for clarifying that I have missed POPLA - I didn't realise that 

Re the defence - I have read and reread post 2 
I believe it is still relevant if my Notice to Keeper is compliant or not??

3 - These were the first letters from Civil Enforcement - Are these deemed the "Notice To Keeper"? and if so what ground for defence do they offer?


 
(Apologies if I have still got the wrong end of the stick) 

kryten3000

These are their "notice to keeper" letters but we can't tell if they have the POFA wording because CEL hide that on the back.

If they issue a claim (or 2 different ones) then their "particulars of claim" will be vague which is enough to have the case struck out.

Additionally, Civil Enforcement Limited, Company number 05645677 are unlikely to have a valid contract to operate at this location.  Any landowner contract that exists is more likely to be with Creative Car Park Limited, Company number 05571660.  This is a valid defence and usually results in a discontinuation of the claim if it has not been struck out earlier.