04-14-2026, 05:58 PM
No, it does not materially improve their position. Their reply is mostly standard template material and it does not really answer the real complaint points.
First, they have relied on a 28 day period running from the date of the NtK. The key error is that UKPC have treated the 28 days as running from the date printed on the NtK, namely 15 November 2025. That is not what the PPSCoP says. Clause 8.1.2(e) states that the notice must inform the recipient that, if they appeal within 28 days of receiving the parking charge, the right to pay at the rate applicable when the appeal was made must stand for a further 14 days after rejection. Note 2 then states that a notice sent by post is presumed delivered on the second working day after posting.
On these dates, an NtK dated Saturday 15 November 2025 would be presumed delivered on Tuesday 18 November 2025. The 28 day period from receipt therefore ran to Tuesday 16 December 2025, not Friday 12 December 2025 as UKPC have asserted. Their response is therefore based on the wrong starting date and appears inconsistent with clause 8.1.2(e) and Note 2.
Second, even leaving that timing argument aside, their response still does not properly answer the complaint that their portal accepted the appeal text but produced no acknowledgement, no appeal reference, no rejection and no POPLA code. The PPSCoP requires operators to respond to appeals within 28 days or at least acknowledge them and confirm the timeframe for concluding them.
Third, their attempt to wash their hands of the matter by saying “the case is no longer with UKPC” is pathetically weak. The PPSCoP says a complaint that includes an appeal against the validity of the parking charge must also be treated as an appeal for the clause 8.4 timescales, and complaints must be acknowledged within 14 days and fully responded to within 28 days. A parking charge only becomes overdue after expiry of the 28 days for payment or after the appeals process has been completed and the time to pay has passed.
Their signage paragraph is just boilerplate rubbish. It does not answer the procedural complaint and it does not cure the absence of any proper ADR route.
So the position now is this. Their email does not knock out the BPA complaint point. If anything, it adds to it. They have effectively admitted that no POPLA code was provided, refused to deal substantively with the appeal-process failure, and sought to sidestep responsibility by referring the keeper to a debt collector. That is still worth putting before the BPA and it can also be exhibited in the DCB Legal response as further evidence of unreasonable pre-action conduct.
I would respond to UKPC with the following:
Have you already responded to the LoC from DCB Legal and submitted the BPA complaint?
First, they have relied on a 28 day period running from the date of the NtK. The key error is that UKPC have treated the 28 days as running from the date printed on the NtK, namely 15 November 2025. That is not what the PPSCoP says. Clause 8.1.2(e) states that the notice must inform the recipient that, if they appeal within 28 days of receiving the parking charge, the right to pay at the rate applicable when the appeal was made must stand for a further 14 days after rejection. Note 2 then states that a notice sent by post is presumed delivered on the second working day after posting.
On these dates, an NtK dated Saturday 15 November 2025 would be presumed delivered on Tuesday 18 November 2025. The 28 day period from receipt therefore ran to Tuesday 16 December 2025, not Friday 12 December 2025 as UKPC have asserted. Their response is therefore based on the wrong starting date and appears inconsistent with clause 8.1.2(e) and Note 2.
Second, even leaving that timing argument aside, their response still does not properly answer the complaint that their portal accepted the appeal text but produced no acknowledgement, no appeal reference, no rejection and no POPLA code. The PPSCoP requires operators to respond to appeals within 28 days or at least acknowledge them and confirm the timeframe for concluding them.
Third, their attempt to wash their hands of the matter by saying “the case is no longer with UKPC” is pathetically weak. The PPSCoP says a complaint that includes an appeal against the validity of the parking charge must also be treated as an appeal for the clause 8.4 timescales, and complaints must be acknowledged within 14 days and fully responded to within 28 days. A parking charge only becomes overdue after expiry of the 28 days for payment or after the appeals process has been completed and the time to pay has passed.
Their signage paragraph is just boilerplate rubbish. It does not answer the procedural complaint and it does not cure the absence of any proper ADR route.
So the position now is this. Their email does not knock out the BPA complaint point. If anything, it adds to it. They have effectively admitted that no POPLA code was provided, refused to deal substantively with the appeal-process failure, and sought to sidestep responsibility by referring the keeper to a debt collector. That is still worth putting before the BPA and it can also be exhibited in the DCB Legal response as further evidence of unreasonable pre-action conduct.
I would respond to UKPC with the following:
Quote:Dear Complaints Department
Thank you for your email. However, your response does not address the central complaint and is based on an incorrect calculation of the appeal period.
You state that any appeal had to be submitted by 12 December 2025, calculated from the Notice to Keeper date of 15 November 2025. That is not accepted.
Clause 8.1.2(e) of the Private Parking Single Code of Practice refers expressly to an appeal made within 28 days of RECEIVING the parking charge, and Note 2 to that same provision defines deemed postal delivery as the second working day after posting. The section therefore plainly distinguishes between the date of the notice and the date of RECEIPT, and cannot properly be read as though all periods run from the printed notice date itself.
Your Notice to Keeper is dated Saturday 15 November 2025. Applying the PPSCoP deemed-delivery provision, presumed RECEIPT was Tuesday 18 November 2025. Your assertion that the relevant period expired on 12 December 2025 is therefore inconsistent with the PPSCoP wording and proceeds from the wrong starting point. The 28 day period from RECEIPT ran until Tuesday 16 December 2025. Your assertion that the deadline was 12 December 2025 is plainly wrong.
Your response also fails to properly address the further complaint point, namely that an appeal was submitted through your portal, the text was accepted, but no acknowledgement, no rejection and no POPLA code were ever issued.
The appeal process provisions are clearer still. Clause 8.4.1 requires operators to provide a process which allows a parking charge to be appealed within 28 days and requires the operator either to respond within 28 days or to acknowledge the appeal and confirm the timeframe for concluding it. The PPSCoP also states that enforcement action is action taken to pursue an overdue parking charge, and that a parking charge becomes overdue only after expiry of the relevant 28 day period or, where an appeal has been pursued, once the appeals process has been completed and the time to pay at the full rate has passed.
Instead of engaging with that failure, you have simply repeated generic signage assertions and then attempted to wash your hands of the matter by saying the case is no longer with UKPC. That is not an adequate response to a formal complaint about your own handling of the matter.
Please now confirm:
- whether you accept that your calculation of the 28 day appeal period was wrong;
- what became of the appeal submitted through your portal;
- why no acknowledgement, appeal decision or POPLA code was provided; and
- whether you will now restore ADR or otherwise explain, with reference to the Code, why you contend that no ADR should be available despite the procedural failures identified.
If this is not properly addressed, your response will be relied upon in the BPA complaint and in response to any pre-action correspondence.
Yours faithfully,
Have you already responded to the LoC from DCB Legal and submitted the BPA complaint?
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
