ANPR - Horizon Parking - Hotel Nelson Norwich

[candlestick]

Before I go on, I want to clarify whether those are your evidential photos or theirs?

Hey b789! Thank god I found you again. They are mine

---

Your proposed POPLA appeal is broadly on the right lines, but it is doing more work than necessary and it contains a couple of weaknesses that Horizon will try to exploit. POPLA assessors skim. You want a tight appeal that forces Horizon to prove facts they cannot prove, not one that gives them multiple angles to wriggle.

Below is a refined POPLA appeal that keeps your core arguments, removes anything that weakens the case, and directly counters Horizon’s rejection. It assumes Keeper-only, no driver identification, and relies on your contemporaneous photos and mapped route without over-explaining.

You can safely replace what you drafted with this.

I am the registered keeper of the vehicle. I am appealing as keeper only. I am not identifying the driver and no inference may be drawn.


1. The operator has not proven the vehicle was parked on land subject to Horizon Parking contractual terms

The operator relies solely on ANPR images showing vehicle entry and exit past cameras. ANPR evidence does not demonstrate where a vehicle was parked, nor does it establish that the vehicle was parked in an area governed by Horizon Parking’s contractual terms.

This site is not a single uniform car park. It contains multiple distinct parking areas, clearly separated by on-site directional signage. One area is customer/guest parking for Premier Inn and associated businesses. Another area is clearly identified as “Charles & Wensum House – permit holders only”.

The vehicle was parked in the Charles & Wensum House permit-holder area. The operator has produced no evidence that this area falls within Horizon Parking’s enforcement boundary or contractual remit.

The operator is put to strict proof of the exact location where the vehicle was parked and evidence that this specific area is subject to Horizon Parking’s terms.


2. No Horizon contractual signage at the parking location

At the location where the vehicle was parked, there are no Horizon Parking signs, no tariff boards, no payment instructions, and no contractual terms.

The only sign present in that area is a legacy sign referring to clamping of unauthorised vehicles. This is plainly not Horizon Parking contractual signage and is inconsistent with an ANPR pay or registration scheme.

Any Horizon tariff signage relied upon by the operator is located in a different area of the site serving Premier Inn and restaurant customers. Drivers entering the permit-holder area are directed away from that signage by the site’s own directional signs.

The operator has failed to demonstrate that any contractual terms were displayed at the location where the vehicle was parked.


3. A permit-holder-only area cannot give rise to a contractual parking charge

The area where the vehicle was parked is signed as “permit holders only”. Parking is not offered to non-permit holders on contractual terms.

Where parking is not offered, no contract can be formed. A non-permit holder cannot accept terms that are not offered to them.

At most, parking without a permit could amount to trespass. Trespass can only be pursued by the landowner and only for nominal loss. Horizon Parking is not the landowner and has no standing to pursue trespass. No loss has been evidenced.

The operator cannot convert an alleged trespass into a contractual parking charge.


4. Failure to prove landowner authority for this specific area

The operator has not produced any evidence of landowner authority covering the Charles & Wensum House permit-holder parking area.

The operator is put to strict proof by providing:

• a contemporaneous landowner agreement, and
  
• a site boundary plan showing that this permit-holder area is included within Horizon Parking’s enforcement area.
  

Without this evidence, the operator has no authority to issue or pursue parking charges in this location.


5. ANPR does not evidence parking duration or contractual compliance

The operator alleges a period “on site” based on ANPR timestamps. These timestamps record only boundary movements and do not evidence actual parking time or location.

Given the site layout and multiple parking zones, ANPR evidence alone is incapable of establishing a breach of any parking terms.

Conclusion
The operator has failed to demonstrate that:

• the vehicle was parked on land subject to Horizon Parking’s contractual terms,
  
• any contractual signage existed at the parking location,
  
• a contract was capable of being formed in a permit-holder-only area, or
  
• Horizon Parking holds authority to operate in that specific location.
  

Accordingly, the appeal must be allowed and the Parking Charge Notice cancelled.

Two practical notes:

1. First, make sure your own photos are submitted. Keep the originals and extract the EXIF metadata showing date and time. A simple screenshot of the metadata is sufficient. This directly undermines any suggestion the photos are historic or irrelevant.
   
2. Second, include the annotated Google Street View map showing the route taken and the exact parking location. POPLA assessors find visual route evidence persuasive, especially where the operator is asserting the vehicle was in a different area without proof.
   

This is a stronger POPLA appeal. Horizon’s rejection letter is generic and evidentially weak, and their assertion about “designated Premier Inn area” is unsupported.

All makes complete sense. Thanks so so much. Will let you know how it goes