PCN Civil Enforcement Spring Hall Medical Practice, Halifax

[b789]

Yes. This is just a payment-pressure letter, not a lawful or coherent appeal/complaint response.

They are now trying to say it is "too late" to appeal, despite previously confirming that the correspondence had been identified as an appeal and passed to the appeals team. That is untenable. They cannot first accept that the matter has been passed to appeals, then later pretend no appeal can be considered because time has expired.

The letter is also internally poor. It repeats the same generic PoFA paragraph, still wrongly referring to "Section 4" rather than Schedule 4, and still fails to address the actual point: PoFA keeper liability is conditional, and the NtK does not specify a "period of parking" under paragraph 9(2)(a). ANPR entry/exit timestamps are not a period of parking.

Most importantly, if this is intended to be an appeal rejection, it must provide a POPLA code. If it is not an appeal rejection, then the appeal remains live. They cannot have it both ways.

I would now stop debating the merits with CEL and force the process point. Send a short response along these lines:

Subject: PCN [PCN number] – failure to provide POPLA code/complaint and appeal remain live

Dear Civil Enforcement Ltd,

I write as the registered keeper.

I refer to your letter dated 10 August 2026.

Your position is incoherent.

Civil Enforcement Ltd previously confirmed that my correspondence had been identified as an appeal and had been passed to your appeals team. You cannot now assert that it is "too late" to appeal.

For the avoidance of doubt, the formal complaint remains live. Under PPSCoP clause 11.2, because that complaint includes a challenge to the validity of the Parking Charge Notice, Civil Enforcement Ltd must handle it as a complaint and must also treat it as an appeal. Those obligations are cumulative.

If your letter dated 10 August 2026 is intended to be an appeal rejection, you must issue a valid POPLA code.

If it is not an appeal rejection, then the appeal remains live and you must either cancel the Parking Charge Notice or issue a proper appeal rejection with a valid POPLA code.

Your repeated generic reference to the Protection of Freedoms Act 2012 does not answer the appeal. Keeper liability is not created merely because 28 days have passed or because the keeper has not named the driver. It is conditional upon full compliance with Schedule 4. The Notice to Keeper fails to specify the required period of parking under Schedule 4 paragraph 9(2)(a). ANPR entry and exit timestamps are not a period of parking.

Your continued demands for payment, including the threat of escalation, while refusing to process the complaint and appeal properly and withholding POPLA access, will be relied upon in complaints to the BPA and DVLA concerning breach of the PPSCoP and improper use of DVLA keeper data.

You must now confirm, within 7 days, either:

1. the Parking Charge Notice is cancelled; or
   
2. the appeal is rejected and a valid POPLA code is provided.
   

No further payment demands, debt escalation or third-party referral should occur while the complaint and appeal remain unresolved.

Yours faithfully,

[Registered Keeper's name]

At this stage, they are hoping you pay rather than notices the procedural mess. The next real step, if they still refuse a POPLA code, is a BPA complaint with the full correspondence chain attached.