F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100

[JoeBloggs90]

Continuation of thread from another forum for the  attention of B789, I extract the salient parts of our conversation and paste below. They have replied to letter you asked me to write them. Seeking next steps as not sure how to interpret their message.

I initially wrote:

The Bewl Water FAQ itself says parking is charged from 08:00:

https://www.bewlwater.co.uk/faq/

Registered keeper has now received a £100 PCN from First Parking LLP for Bewl Water.

The notice says the car entered at 06:46 and left at 09:17 (151 minutes). The allegation is that payment wasn’t made for the full duration.

The alleged driver has a Ringo receipt showing payment from 08:03–09:03. The car left at 09:17.

So it looks like 3 minutes late to start and 14 minutes over at the end. But surely there should be a grace period either side?

It’s highly confusing – the website itself shows 08:00, which is exactly why payment wasn’t made before then. Registered keeper has no idea what this clear signage is outside Bewl Water about private land that letter aludes to. Keeper is only aware that there is on grounds parking which begins at 08:00 which was largely respected.

To make things worse, the letter is dated 17/09/2025, but it was only found on the doormat this morning (27/09/2025). It says the £100 full charge must be paid by 01/10/2025 at 11:42am, which doesn’t leave much time to deal with it properly.

How does this add up to a £100 bill? It makes no sense at all.

https://ibb.co/NgxGH8K8

B789 reply:

Send the following email to First Parking by first class post and get a free certificate of posting from any post office to First Parking LLP, 27 Old Gloucester Street, London, WC1N 3AX:

Quote
Subject: Formal complaint – Breach of PPSCoP 8.1.1(d) and KADOE (Keeper liability misrepresented at Bewl Water)

Dear First Parking LLP Complaints Team,

I write as the registered keeper in relation to Parking Charge Notice [PCN ref], issued at Bewl Water on 17/09/2025.

Your Notice to Keeper (NtK) states or implies that you are able to hold me (the Keeper) liable under Schedule 4 to the Protection of Freedoms Act 2012 (PoFA). That statement is incorrect for this location and places you in breach of the Private Parking Single Code of Practice (PPSCoP), section 8.1.1(d). As you know, a breach of the PPSCoP is also a breach of your DVLA KADOE contract.

Why PoFA keeper liability cannot apply at Bewl Water
PoFA Sch 4 excludes “relevant land” where parking is “subject to statutory control” (Sch 4, para 3(1)(c) and 3(3)).

Bewl Water is a statutory reservoir/undertaking created and governed by specific legislation, including:

• Medway Water (Bewl Bridge Reservoir) Act 1968 (local Act establishing the scheme; authorising works and land acquisition).
• Reservoirs Act 1975 (statutory safety regime imposing duties on the undertaker for inspection, maintenance and emergency planning).

The presence of this statutory framework means the land is under statutory control for PoFA purposes, irrespective of present operational or ownership arrangements.

References (official sources)

• PoFA 2012]Protection of Freedoms Act 2012, Sch 4, para 3(1)(c), 3(3):
• Medway Water (Bewl Bridge Reservoir) Act 1968 (1968 c. xxxiii) (official PDF available)
• Reservoirs Act 1975: legislation.gov.uk

Breach of PPSCoP and KADOE
PPSCoP 8.1.1(d) requires that operators must not state or imply that keeper liability applies where Schedule 4 does not. By asserting PoFA keeper liability at Bewl Water, your NtK misrepresents the legal position. This is a Code breach and, consequently, a breach of the DVLA’s KADOE terms, which require adherence to the applicable Code as a condition of data access.

Required remedies
As this is a formal complaint, please confirm within 14 days how you will rectify this compliance failure. At minimum, I expect you to:

1. Cancel PCN [PCN ref] and confirm in writing that no keeper liability is pursued at Bewl Water.
2. Cease and correct all NtK templates and website wording for sites under statutory control to remove any assertion (or implication) of PoFA keeper liability.
3. Conduct an immediate audit of outstanding NtKs issued for Bewl Water (and any other sites under statutory control) and notify affected keepers accordingly.
4. Provide details of staff guidance/training updates to prevent recurrence.

If you do not provide a satisfactory response, I will escalate this complaint to the British Parking Association and to the DVLA for investigation of a PPSCoP/KADOE breach.

Your published complaints policy states complaints must be submitted by post. For the avoidance of doubt, I will only accept your response by post or by email (your choice). Do not require telephone contact, web portals or third-party platforms for complaint handling or evidence review. Please treat this email as a formal complaint and provide your written response by [date – 14 days from today].

Yours faithfully,

[Full name]

[Postal address]
[Email]
Registered Keeper of vehicle [VRM]
PCN: [reference]

---

I sent the above. The following response was received on 05/02/2026 via email.  3 attachments of CCTV of car and one attachment called Parking Charge Notice (the usual stuff they send through the door)

Good Afternoon,



Thank you for your letter received 04/02/2026



Parking Charge refs: FP481691

Complaint ref: A39065



Your complaint has been referred to myself for review, please see my findings below:



Parking Charge FP481691 issued on 11/09/2025 at Bewl Water
Contravention – Not paid for the full duration of stay or not registering your vehicle
The vehicle with registration X15RAK was observed via the ANPR cameras entering site on 11/09/2025 at 06:46 and leaving on 11/09/2025 at 09:17. Total time on site 2 hours, 31 minutes, and 39 seconds. (Photographic evidence attached)
First Parking applied to the DVLA to request registered keeper details on 15/09/2025
DVLA keeper details received on 17/09/2025 and Notice to Keeper printed and posted on 17/09/2025. (please see attached)
As no payment, appeal or transfer of liability was received within 28 days of our initial correspondence, the case was referred to our appointed debt collectors on 23/10/2025.
DCBL are now administering the debt on behalf of First Parking


I have reviewed the photographic evidence, and I am satisfied that the Parking Charge was issued correctly and in accordance with the Code of Practice.



There is clear and sufficient signage on site advising motorists of the terms and conditions.

First Parking has processed the parking charge correctly and in line with the Code of Practice.



Due to non-payment, it was referred to debt collection on the 23/10/2025 and DCBL are now administering the debt on our behalf.



To answer the points in your letter:



The land on which your car was observed via ANPR camera’s is private land. Only the water/reservoir is governed by Medway Water/Southern Water.



Bewl Water is primarily managed and operated as a private leisure facility by the Elite Leisure Collection(part of the Markerstudy Group) since 2015, although the reservoir itself remains owned by the utility company Southern Water. The recreational grounds are privately managed.

•          Leisure & Operations: The leisure facilities, including fishing, water sports, and the aqua park, are managed by Elite Leisure Collection.

•          Water Authority: The reservoir and its water resources are controlled by Southern Water, serving as a vital public water source for Kent and East Sussex.



The parking charge has been issued under PoFA and is compliant.



In summary, I am satisfied the parking charge had been issued correctly at the time and in accordance with the signage in situ.



We have reached the end of our complaint process, and my response now concludes our complaints procedure. I trust you will appreciate that there will be no further review of your complaint.



Yours Sincerely,



Kelly Arnold

Account Manager

[b789]

Hi @JoeBloggs90. Welcome to the forum.

First, I need to correct something. I initially proceeded on the basis that Bewl Water being a statutory reservoir undertaking meant the land was under statutory control for PoFA purposes. That was maybe a bit too broad. Reservoir legislation on its own does not automatically establish that parking or control of vehicles on the leisure estate is subject to statutory control.

For PoFA Schedule 4 to be disapplied, the parking or control of vehicles must itself be subject to statutory control. I have not yet seen any confirmed byelaws or statutory instrument that regulate vehicles on the car parks or access roads where First Parking operate. I cannot find the Act itself anywhere online.

So before we go any further with that argument, we need clarification.

You now need to submit a formal Environmental Information Regulations (EIR) request to Southern Water Services Ltd (they are the statutory undertaker for Bewl Reservoir).
Use this link:

https://www.southernwater.co.uk/about-us...formation/

Submit the request through their EIR route. In the request box, put the following:

“I request confirmation whether any byelaws have been made under the Medway Water (Bewl Bridge Reservoir) Act 1968 or any other enabling legislation in relation to Bewl Water, Bewlbridge Lane, Lamberhurst, TN3 8JH.
If so, please provide a complete copy of all byelaws currently in force.
Please confirm the geographic extent of any such byelaws, specifically whether they apply to the leisure estate, access roads and car parks (not limited to the water body itself).
Please confirm whether any such byelaws regulate, control, restrict or govern the bringing, driving, stopping, standing, leaving or parking of motor vehicles on the land forming part of the Bewl Water estate.”

Submit that and keep a copy. They normally have 20 working days to respond.

Now, separately, we need to tighten up the actual parking charge case.

Please upload:

1. The original Notice to Keeper (both sides). Not a reminder. The very first NtK.
   
2. All images they have supplied so far (ANPR entry/exit etc).
   
3. Any wording on the NtK that mentions PoFA or keeper liability.
   

Also, can you obtain clear photographs of the signage at the location? In particular:

– Any entrance signage.
– Any tariff boards.
– Any signage that states parking charges apply before 08:00.
– Any signage that clearly states that time on site before 08:00 is chargeable.

The FAQ states parking is charged from 08:00. If signage does not clearly state that pre-08:00 presence forms part of a paid contractual period, that becomes highly relevant.

We will deal with:

– Consideration period on entry.
– Mandatory grace period at the end.
– The mismatch between website representation and alleged contractual terms.
– Whether ANPR time on site can lawfully be equated with parking time.

For now:

• Do not contact DCBL.
  
• Do not pay.
  
• Submit the EIR request.
  
• Upload the NtK and evidence here.
  

Once we see the byelaw position and the NtK wording, we will know exactly which direction this goes.

The only other factor that is relevant is that this is being handled by DCBL which means that off they do move to a claim, it will most likely be by their sister company, DCB Legal. I can assure you with greater than 99% certainty, that any claim issued by DCB Legal, as long as it is defended, no matter how poorly, it will be discontinued before they have to pay the £27 trial fee. 

[JoeBloggs90]

Hi @JoeBloggs90. Welcome to the forum.

First, I need to correct something. I initially proceeded on the basis that Bewl Water being a statutory reservoir undertaking meant the land was under statutory control for PoFA purposes. That was maybe a bit too broad. Reservoir legislation on its own does not automatically establish that parking or control of vehicles on the leisure estate is subject to statutory control.

For PoFA Schedule 4 to be disapplied, the parking or control of vehicles must itself be subject to statutory control. I have not yet seen any confirmed byelaws or statutory instrument that regulate vehicles on the car parks or access roads where First Parking operate. I cannot find the Act itself anywhere online.

So before we go any further with that argument, we need clarification.

You now need to submit a formal Environmental Information Regulations (EIR) request to Southern Water Services Ltd (they are the statutory undertaker for Bewl Reservoir).
Use this link:

https://www.southernwater.co.uk/about-us...formation/

Submit the request through their EIR route. In the request box, put the following:

“I request confirmation whether any byelaws have been made under the Medway Water (Bewl Bridge Reservoir) Act 1968 or any other enabling legislation in relation to Bewl Water, Bewlbridge Lane, Lamberhurst, TN3 8JH.
If so, please provide a complete copy of all byelaws currently in force.
Please confirm the geographic extent of any such byelaws, specifically whether they apply to the leisure estate, access roads and car parks (not limited to the water body itself).
Please confirm whether any such byelaws regulate, control, restrict or govern the bringing, driving, stopping, standing, leaving or parking of motor vehicles on the land forming part of the Bewl Water estate.”

Submit that and keep a copy. They normally have 20 working days to respond.

Now, separately, we need to tighten up the actual parking charge case.

Please upload:

1. The original Notice to Keeper (both sides). Not a reminder. The very first NtK.
   
2. All images they have supplied so far (ANPR entry/exit etc).
   
3. Any wording on the NtK that mentions PoFA or keeper liability.
   

Also, can you obtain clear photographs of the signage at the location? In particular:

– Any entrance signage.
– Any tariff boards.
– Any signage that states parking charges apply before 08:00.
– Any signage that clearly states that time on site before 08:00 is chargeable.

The FAQ states parking is charged from 08:00. If signage does not clearly state that pre-08:00 presence forms part of a paid contractual period, that becomes highly relevant.

We will deal with:

– Consideration period on entry.
– Mandatory grace period at the end.
– The mismatch between website representation and alleged contractual terms.
– Whether ANPR time on site can lawfully be equated with parking time.

For now:

• Do not contact DCBL.
  
• Do not pay.
  
• Submit the EIR request.
  
• Upload the NtK and evidence here.
  

Once we see the byelaw position and the NtK wording, we will know exactly which direction this goes.

The only other factor that is relevant is that this is being handled by DCBL which means that off they do move to a claim, it will most likely be by their sister company, DCB Legal. I can assure you with greater than 99% certainty, that any claim issued by DCB Legal, as long as it is defended, no matter how poorly, it will be discontinued before they have to pay the £27 trial fee. 

Hi B789,

Thank you for your continued assistance.

I have now submitted the EIR request to Southern Water exactly as you suggested and will await their response.

In terms of documentation:

The original Notice to Keeper is here: https://ibb.co/NgxGH8K8

Unfortunately, I no longer have any subsequent reminder letters, as they were discarded at the time.

The Registered Keeper commenced RingGo payment at 08:03 on the assumption that parking charges applied from 08:00, based on the published FAQ at the time.

At the relevant time, the FAQ stated:

“Parking charges apply from 8am to 8pm, Monday to Sunday with your first 30 minutes free…”
Source: https://www.bewlwater.co.uk/faq/

However, the website now appears to state something different:

https://www.bewlwater.co.uk/parking-at-bewl-water/

The current wording says:

“Parking charges apply from 6am to 8pm…”

Using Wayback Machine:

In April, the page stated parking charges applied from 8am–8pm.

In May, the FAQ page stated:

“Bewl Water’s standard opening hours are 8.00am – 5.00pm… The gates to our car park shut at 8.00pm.”
“Car parking costs £7 for the entire day…”

So the website wording appears to have changed over time, and even now there seems to be inconsistency between different pages of the same site.

This discrepancy is significant because the vehicle entered at 06:46. The Keeper reasonably relied on the published FAQ stating parking charges began at 08:00. Payment was made at 08:03 accordingly.


I have not returned to Bewl Water and therefore do not currently have photographs of the signage.

However, I located this LinkedIn post which appears to highlight confusion and potential signage inconsistencies at the site:

https://www.linkedin.com/posts/chris-sto...75200-tbDl

This suggests others have experienced similar confusion regarding start times and signage clarity.

Please let me know how you would like to proceed from here. I will update you once Southern Water respond to the EIR request.

Kind regards,

[b789]

Keep Screenshots of everything that shows the opening times of the car park at 8am.