Is it worth mentioning pregnancy on first template?

To clarify then, should I go with the appeal text I've pasted above (if this is ok), or should I re-do to include the fact a wrong reg no. may also be the problem?

Thanks in advance

Redx wrote: »

FIRST, read the BPA CoP and especially any parts about checking for similar details when using ANPR cameras etc , also mention any partial errors are considered de-minimis

Read the CoP and updated notes for Jan18 onwards, struggling to find anything in there regarding de-minimis/anpr. Forum search additionally doesn't seem to throw up anything formal.

Only this seems vaguely relevant from CoP:

Quality checks: before you issue a parking charge
notice you must carry out a manual quality check of the
ANPR images to reduce errors and make sure that it is
appropriate to take action.
http://www.britishparking.co.uk/write/Documents/AOS_Code_of_Practice_October_2015_update_V6..pdf

Rewritten appeal based on new information and above, would greatly appreciate if someone could scan and give thoughts. Thanks again for all the help so far.

---

Re PCN number: xx

I appeal and dispute your 'parking charge', as the keeper of the vehicle.

On the letter received you provide two pictures of the car numberplate, asserting that this shows entry at 4.15pm and exit at 5.23pm. The reason given for the charge is 'no valid pay and display/permit was purchased.

Attached with this appeal is the parking ticket purchased at 4.21pm on the date in question, and valid until 5.21pm.

I'd like to draw to your attention the British Parking Associations Code of Practice on Grace Periods. The BPA's Kelvin Reynolds stated in a formal BPA article, that good parking management required these grace periods and that it may take some people longer to get to and from a PDT machine:

"The BPA's guidance specifically says that there must be sufficient time for the motorist to park their car, observe the signs, decide whether they want to comply with the operator's conditions and either drive away or pay for a ticket...No time limit is specified. This is because it might take one person five minutes, but another person 10 minutes depending on various factors, not limited to disability."

This has recently been updated further in the BPA CoP: Clause 13.2 and 30.2 - If the parking location is one where parking is normally permitted, you must allow the driver a reasonable grace period in addition to the parking event before enforcement action is taken. In such instances the grace period must be a minimum of 10 minutes.

http://www.britishparking.co.uk/News/good-car-parking-practice-includes-grace-periods

In this case it took the driver longer to comfortably get out of the car and collect their belongings before going to read a sign, find change and then pay, and they did so within five or six minutes. And this was because the driver was over seven months pregnant at the time, and was slower moving and less nimble on their feet than usual.

Given the above and the fact the attached ticket covered 4.21 - 5.21, and the car left within 2 minutes of expiry, it's clear this fits well within reasonable grace periods for a heavily pregnant visitor and to pursue a charge would be in breach of the ICO CoP for ANPR/surveillance cameras, which in turn puts the operator in breach of the BPA Code, too.

Further, if you are asserting the ticket is not valid due to an issue with the VRN rather than the time parked, I will refer you to the above comments, in addition what has been recorded.

VRN on Letter to Keeper: AB58 DAD

VRN on PDT: ADA58

It's unclear how ECP have truncated this VRN for the purposes of the PDT, but it is clear that both refer to the same VRN, and as you will be aware any partial errors are considered de-minimis. In this instance I would again refer you the BPA CoP:

21 (21.2)
Quality checks: before you issue a parking charge notice you must carry out a manual quality check of the ANPR images to reduce errors and make sure that it is appropriate to take action.

Again, to pursue a charge would be in breach of the ICO CoP for ANPR/surveillance cameras, which in turn puts the operator in breach of the BPA Code, too.

Yours faithfully,

Registered Keeper

Thanks

KeithP wrote: »

I would change this sentence to:

Attached with this appeal is a copy of the parking ticket purchased at 4.21pm on the date in question, and valid until 5.21pm.

Do not send them the original ticket.

Thanks, appeal is via ECP website so will send of photo of ticket if that is sufficient in this initial appeal.

Coupon-mad wrote: »

I suggest the above.

If all that doesn't fit in the ECP online appeal, cut out the waffle, like 'I'd like to draw to your attention...' and change things like 'the British Parking Associations Code of Practice on Grace Periods' to 'the BPA CoP on Grace Periods', etc, etc.

Thanks, it's ready to go then. Only other thing, should something along these lines be included regarding fact a PDT has clearly been purchased?

"...as no loss has been recorded by ECP due to a ticket having been purchased..."