Consultation outcome

Private parking charges, discount rates, debt collection fees and appeals charter: further technical consultation response

Updated 7 June 2022

Introduction

The Department for Levelling Up, Housing and Communities (DLUHC) is taking forward the implementation of the Parking (Code of Practice) Act 2019. This Act was introduced by Sir Greg Knight MP and supported by the Government in response to widespread concerns about the poor practice and behaviour of some parking operators. It will lead to the creation of an independent Code of Practice for private parking companies.

As part of the process to finalise the Code, we recently launched the ‘Private parking charges, discount rates, debt collection fees and appeals charter: further technical consultation’.

This followed our response to the Code Enforcement Framework consultation in March 2021, which proposed a new system to bring private parking charges into closer alignment with the principles of local authority penalties.

The further technical consultation sought respondents’ views on our proposals for private parking charges and the closely related issues of a discount rate for early payment, debt collection practices in the private parking sector and the details of an Appeals Charter to safeguard motorists who have been issued a parking charge they believe to be unfair.

This response follows a comprehensive process to analyse all respondents’ views. It outlines the responses the government received and how they fed into our policy development. It also provides further clarity on the next steps for the development of the Code of Practice and its Enforcement Framework.

DLUHC has discharged its duty under the Equality Act 2010 and has considered the impact of our proposals on groups in society with various protected characteristics.

Timeline

• January-March 2022: Product Discovery to research the needs of the users of the single appeals service.
• February 2022: Publication of Code of Practice and beginning of transition period.
• Spring 2022: Certification Scheme finalised and Scrutiny and Oversight Board appointed.
• Autumn 2022: Conformity Assessment Bodies (CABs) accredited by United Kingdom Accreditation Service.
• From Autumn 2022: All new car parks will conform to the new Code.
• End of 2023: Single appeals service appointed and transition period ends. Parking operators must now follow the requirements of the new Code of Practice.

Breakdown of responses

We received 559 responses through the online form and 14 email responses.

We asked respondents to self-identify as parking operators, motorists, landowners or other. The breakdown of respondent types is as follows:

Land owner 30 5.40%

Motorist 455 80.90%

Of which appear to be landowners/parking operators posing as motorists (based on e-mail domain) 8 1.80%

Parking operator 38 6.30%

Other 45 6.60%

Not Answered 5 0.90%

However, we have no means of verifying each respondent or, for example, whether self-identified motorists have a connection with parking operators or landowners.

More broadly, as the consultation is a self-selecting sample we have placed most weight on the quality of evidence rather than on whether a particular view was repeated multiple times.

Level of parking charges (including discount for early payment)

Questions 1-11

1. Do you agree or disagree that the proposed hybrid model will deliver consistency for motorists?

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.a. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent in London where parking is invited (£80-130 or tariff owned)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/ Somewhat disagree/ Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.b. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent in London where parking is not invited or restricted (£130)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.c. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent in London Blue Badge bays (£130)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.d. Do you agree or disagree that the proposed hybrid model will deliver consistency for motorist in London no stopping zones (£130)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.e. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent outside London where parking is invited (£50-70)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.f. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent outside London where parking is not invited or restricted (£100)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.g. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent in Blue Badge bays outside London (£100)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

2.h. Do you agree or disagree that the proposed hybrid model will provide an effective deterrent in no stopping zones outside London (£100)? Please select the most appropriate answer:

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

3. Are there any other policy objectives that should considered when setting the charge cap?

4. The proposed parking caps will vary depending on geographical area, the type of land and how parking terms and conditions are breached. Are these the right considerations? Please use free text box (max 400 words).

4.i. What else should we consider in determining the level of the charge caps? Please use free text box (max 400 words).

5. Should the higher level of parking charges used in London also be permitted outside London? In what situations? Please use free text box (max 400 words).

6. Should the list of breaches follow the local authority system as closely as possible?

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please use free text box to explain your answer (max 400 words).

6.i. Should any other contraventions be included as additional private parking contraventions?

6.ii. Please provide any feedback on the proposals for higher and lower levels of contraventions?

7. Do you think the proposed 50% discount for early payment is appropriate for the hybrid model and would it achieve the policy objectives set out in paragraph 13? Please use free text box to explain your answer (max 400 words).

8. Overall, do you agree or disagree with the proposed hybrid model?

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

Please explain your answer (max 400 words).

9. What impact would the proposed hybrid model have on you, your business and/or the control of parking on your land? Please use free text box.

10. If government went ahead with the proposed model for parking charges, how should it be implemented? For example, you may wish to suggest timescales or comment on how the system could be made to work in practice. Please use free text box.

11. In our response to Enforcement Framework consultation we proposed that charges should be reviewed every two years as part of the general review of the Code of Practice by the Scrutiny and Oversight Board. Should the Scrutiny and Oversight Board have a role in reviewing the charges regularly? Please use free text box (max 400 words).

11.i. Which factors and metrics should the Scrutiny and Oversight Board take into account when deciding whether charges should be adjusted, and why? Free text box (max 400 words).

Analysis of responses

1. Currently, industry codes voluntarily cap the level of private parking charges at £100. We have previously committed to setting a new cap in the government Code of Practice.

2. In the government response to the Code Enforcement Framework consultation in March 2021, we announced support for Mirroring the Local Authority system for publicly-accessible car parks, while retaining the £100 status quo for private land where parking was not invited and some restricted car parks (residential and staff-only).

3. We decided to consult further to give stakeholders and the public a chance to give their views on a more detailed proposal for parking charge caps, including a proposed list of breaches.

4. The ‘Private parking charges, discount rates, debt collection fees and appeals charter: further technical consultation’ set the following policy objectives for private parking charges:

i. To ensure that charges are proportionate to the level of harm caused and are consistent with other parking penalties.

ii. To ensure that the levels of private parking charges are sufficient to prevent non-compliance with parking restrictions on private land.

iii. To ensure effective delivery of the new parking charges in practice.

5. Overall, most respondents (65%) did not feel that the proposals for parking charges will deliver consistency for motorists, whilst a quarter (25%) either strongly or somewhat agreed. For example, the most common reason provided in opposition was that Local Authority and private parking are not comparable and therefore should not be consistent. This accounted for 28% of responses to this question, while 4% of respondents believed that more should be done to align private parking with the Local Authority approach. Further to this, 24% of respondents believe that the proposed model was complex or confusing. With regard to the level of charges, 17% of respondents believed that stronger deterrence is required to avoid abuse of power whereas 8% felt that proposed charges were excessive and not proportional to contravention.

6. However, respondents were more divided when asked to respond on individual elements of the new proposed system. There was broad agreement that the deterrent levels in London were sufficient for all types of land, including no stopping zones and Blue Badge bays. For example, 51% somewhat or strongly agreed that the proposed charges on land where parking is invited in London provided an effect deterrent, while only 29% somewhat disagreed or strongly disagreed. Similarly, 57% of respondents somewhat or strongly agreed that the proposed levels provided an effect deterrent in London on land where parking is not invited, with only 25% somewhat or strongly disagreeing.

7. There was less support for the proposed parking charge levels outside of London. 72% of respondents disagreed or strongly disagreed that the proposed levels would offer a sufficient deterrent for land where parking is invited, with only 20% agreeing or strongly disagreeing. However, respondents did prefer some elements of the proposed parking charge system outside of London to others. For example, 49% of respondents somewhat or strongly agreed that the £100 charge for land where parking is not invited outside of London offered a sufficient deterrent, with only 37% somewhat or strongly disagreeing. 48% somewhat or strongly agreed that the £100 charge for no stopping zones offered a sufficient deterrent, with only 34% somewhat or strongly disagreeing.

8. When asked if they agreed or disagreed with the proposed parking charges system as a whole,19% somewhat or strongly agreed, while 68% somewhat or strongly disagreed. When asked to explain, the most common answer (53% of respondents to this question) was that the model system did not provide a high enough deterrent. Other answers included that it will be too lenient for those who break the rules (28%), concerns about inconsistencies across the country (23%) and excessive complexity (18%).

9. When asked to comment on whether a 50% discount for early payment was appropriate for the proposed parking charge system and if it met the objectives set out in paragraph 4 above, 26% of respondents agreed that it met the objectives and 61% disagreed. The most common comment (mentioned by 53% respondents who answered this question) was that the discounted level does not provide a sufficient deterrent.

10. When asked what the impact of the proposed hybrid model would have on individuals, businesses and/or the control of parking on your land, the most common answer (43%) was that it would have no impact. However, 27% of respondents spoke of an economic impact leading to potential redundancies and 21% thought the charges were too lenient and would lead to an abuse of parking on private land. 10% believed that the proposed model will increase confusion and ambiguity whereas 6% believed that it would bring about more clarity and efficiency. Similarly, 8% believed that the implementation of the hybrid model discourages the use of private parking whereas 3% believed that it would have the opposite impact.

11. When asked how the proposed model should be implemented, for example with regard to timescales, 35% of respondents expressed concern with the proposed timeline. 16% of respondents felt the policy should be implemented between 10 and 24 months. 9% of respondents thought it should be implemented more quickly, within 9 months, while 6% thought the policy should be implemented over 24 months.

12. There was strong (91%) support for the proposal that the Scrutiny and Oversight Board should have a role in reviewing the level of parking charges regularly. When asked which factors and metrics that Board should taken into account, the most popular answer (mentioned by 47% of respondents) was inflation. Other comments included that the number of parking charges issued, successful appeals or operator profits should be compared to current levels (36%) or the level of deterrent effective as measured by the level of non-compliant parking (32%).

Government position

13. We have given due consideration to the different legal frameworks and enforcement powers between local authority and private parking. It is important to stress that we are not proposing to straightforwardly mirror the local authority system on private land. Instead, we have developed a new system which reflects the differences between both, with particular exceptions for those types of land which have no direct analogue in the local authority system.

14. Respondents have pointed to the lack of a deterrent effect of the local authority system, especially outside London. We have considered these arguments. However, while we accept that deterrence is the primary purpose of parking charges, this must be balanced against other previously-stated considerations. In particular, we were clear that the three objectives of the policy were proportionality and consistency with similar systems, the deterrent effect of parking charges and the deliverability of the system in practice. Taken together, we believe our new system for parking charges provides a sufficient deterrent. As respondents recognise, the deterrent effect is increased for more serious breaches of the terms and conditions in London, while it remains the same as the current levels for land where parking is not invited or in resident or staff-only car parks. At the same time, our new system provides motorists in publicly accessible car parks with greater consistency with other parking frameworks and a proportionate approach whereby more serious breaches of the terms and conditions attract a higher charge.

15. It is also important to note that the existing £100 cap only sets a maximum and that many parking operators set the real parking charge below £100. We asked parking operator respondents how they set their caps. 49% of operators who answered this question set a charge below £100 in 1-25% of their car parks, 3% set a charge below £100 in 51-75% of their car parks and 26% set the charge below £100 in 76-100% of their car parks. The most common factor (23%) in determining the cap was landowner or client requirements. This suggests to us that many parking operators already operate flexibly below the £100 maximum cap and that therefore the impact of the reduction of parking charge levels outside of London is less than it would be if all operators currently set their charges at £100.

16. We have considered also that the Scottish Government and Transport for London are currently consulting on increasing the level of PCNs. This was mentioned by at least 12.5% of respondents, most commonly in response to question 8 on the overall parking charge proposal. The TfL consultation is specifically focused on contraventions on the red route network and any parking contraventions are on-street, whereas our proposals for private parking largely concern off-street parking. The Scottish Government consultation comes in the context of the introduction of provisions within the Transport (Scotland) Act 2019 that will ban pavement parking, double parking and parking at dropped kerb. Therefore, we do not believe these consultations to have a direct application to our proposals. We have, however, committed to reviewing private parking charges and will consider the consequences if local authority penalties change more widely.

17. We have also considered the argument that Motorway Service Areas (MSAs) are required by Department for Transport (DfT) Circular 02/2013, ‘The Strategic Road Network and the Delivery of Sustainable Development’ to offer two hours free parking to vehicles at all times, as well as access to various facilities. This is a safety-critical requirement to ensure motorists can rest while using the strategic road network. There is therefore a strong need for a high turnover in MSA spaces to ensure a constant supply. We have reflected this in the creation of a new ground for issuing parking charges, ‘Overstaying the permitted period at a Motorway Service Area (MSA).’

18. Taking into consideration the consultation responses, the government will include the following approach in the upcoming parking Code of Practice:

Standalone private car park or publicly accessible customer car park

Type of breach	England (outside London) and Wales	London	Scotland
Lower	£50	£80	£50
Higher	£70	£130	£60
Abusing a Blue Badge bay	£100	£130	£100

Residents’ permit-only car park

Type of breach	England (outside London) and Wales	London	Scotland
Parking when not a resident	£100	£130	£100

Land on which parking is not permitted

Type of breach	England (outside London) and Wales	London	Scotland
Parking	£100	£130	£100

‘No stopping’ zone e.g. on an airport road

Type of breach	England (outside London) and Wales	London	Scotland
Parking	£100	£130	£100

Contraventions

Local authority off-street contraventions from PCN Codes 6.7.7	Level
Parked in a loading place or bay during restricted hours without loading	Higher
Parked in an electric vehicles’ charging place during restricted hours without charging	Higher
Using a vehicle in a parking place in connection with the sale or offering or exposing for sale of goods when prohibited	Higher
Parked in a restricted area in a car park	Higher
Parked without a valid virtual permit or clearly displaying a valid physical permit where required	Higher*
Parked in a designated disabled person’s parking place without displaying a valid disabled person’s badge in the prescribed manner	Higher**
Vehicle parked exceeds maximum weight or height or length permitted	Higher
Parked in a car park or area not designated for that class of vehicle	Higher
Parked causing an obstruction	Higher
Parked in car park when closed	Lower
Parked in a pay & display car park without clearly displaying multiple valid pay and display tickets when required	Lower
Parked in a parking place for a purpose other than that designated	Lower
Parked with engine running where prohibited	Lower
Parked without payment of the parking charge	Lower
Parked for longer than permitted	Lower
Parked after the expiry of paid for time	Lower
Parked in a car park without clearly displaying a valid pay & display ticket or voucher or parking clock	Lower
Not parked correctly within the markings of a bay or space	Lower
Re-parked in the same car park within the prescribed time period after leaving	Lower

*£100 if outside of London and in a resident or staff-only car park.

**£100 outside of London.

Local authority on-street contraventions from PCN Codes 6.7.7	Level
Stopped where prohibited (on a red route or clearway)	Higher**

Additional private contraventions	Level
Misuse of Specialist Bays (Doctors’ Bay, Emergency Vehicles, Parent and Child, Staff-Only bay in a mixed use car park etc.)	Higher
Parked in a customer only space if not a customer	Higher
Transferring a parking ticket	Higher
Failure to register vehicle if required	Higher
Parking on controlled land where parking is not permitted	Higher**
Overstaying the permitted period at a Motorway Service Area (MSA)	Higher

**£100 outside of London

Discount rate

The amount of the parking charge shall be discounted by 50% where payment is made within 14 days of the receipt of the parking charge.

Recovery of Tariff

If the tariff owed is higher than the discounted level of the parking charge, payment of the full tariff may be sought.

19. With the agreement of Scottish Government and Welsh Government, private parking charges in Scotland and Wales will also be brought into closer alignment with local authority PCNs, with a 50% discount for early payment. PCN levels in Wales are the same as those in England outside of London. In Scotland, for publicly accessible car parks Higher breaches will attract a charge of £60 and Lower breaches a charge of £50.

20. As outlined in the response to the Code Enforcement Framework consultation in March 2021, we intend for the level of parking charges to be reviewed as part of the general review of the Code of Practice by the Scrutiny and Oversight Board. This will take place within two years of the Code being enforced.

21. We have considered the concerns raised with the proposed timeline for implementation. The Code of Practice has been published alongside this consultation response. This marks the beginning of a transition period during which we expect the industry to align with the requirements of the Code as soon as possible and we will establish the Scrutiny and Oversight Board to oversee this process.

22. It will take some time, however, for the rest of the enforcement framework to be established. We will expect potential Conformity Assessment Bodies (CABs) to seek accreditation from the United Kingdom Accreditation Service (UKAS) in spring 2022 and for this to be complete by autumn 2022. Following the accreditation of the CABs, parking operators will be expected to seek Certification against the new Code throughout 2022 and the first half of 2023. In the meantime, the Accredited Trade Associations (ATAs) will be responsible for ensuring that the existing industry Codes are enforced as a minimum requirement. Parking operators will be expected to fully adhere to the new Code when the single appeals service is appointed before 2024.

Debt collection fees

Questions 12-13

12. In setting the cap on additional debt collection fees, we have considered the deterrent effect, the amount of court fees and the cost of enforcing parking charges. Are there other factors we should consider? Free text box

13. Do you have any suggestions for the content of the Certification Scheme we are proposing parking Debt Recovery Agencies must sign up to? Free text box.

Analysis of responses

23. In the consultation we proposed to cap the level of debt recovery fees at the existing industry level of £70. We were guided by the following policy objectives in determining the new arrangements for debt collection:

i. A reduction in harm to motorists from aggressive and intimidating debt collection practices.

ii. A reduction in the number of CCJs against motorists, with negative and potentially life-changing impacts on credit scores.

iii. The provision of a sufficient deterrent against the non-payment of legitimately issued parking charges, enabling the fair and efficient management of parking spaces on private land.

24. We asked respondents what factors we should consider in determining the cap. However, respondents were divided on the proposal to cap the level of additional fees. Of total responses to the question, 52% were in favour to cap additional fees and 32% were against the cap. The remaining 16% were either undecided or cited conflicting options.

25. Those who favoured the proposal argued that DRAs can play a positive role in helping operators to recover unpaid parking charges and potentially reduce the number of CCJs. Almost everyone in favour of the proposed cap felt that the cap provides a sufficient deterrent against non-payment and that the proposed factors were sufficient considerations in setting the cap. 4% out of those who favoured the proposal suggested to keep the cap under review and increase it with inflation to maintain the level of deterrent.

26. In contrast, the 32% that disagreed with the proposal did so because they thought the cap is set too high and does not reflect genuine enforcement costs or did not think that debt recovery is a suitable mechanism to recover unpaid parking charges. Out of the 32% that disagreed, 8% contemplated whether a disputed parking charge can even be considered a debt, arguing that it should be for the court to decide whether the debt for unpaid parking charge exists. 3% questioned the disparity between court fees and the proposed cap. Others questioned why court fees should be captured within the cap when successful debt recovery process does not trigger court proceedings. Some respondents argued that DRAs operate on no win, no fee basis and as such, private parking operators do not incur additional cost. In total, 18% of all respondents called for the proposal to be scrapped and debt collection to be banned altogether.

27. Those who favoured the proposal argued that although the fee captures enforcement costs such as tracing and processing of cases, the fee is not only about expenses incurred but should provide high enough deterrent to encourage motorists to engage with the process and pay the charge on time. However, no substantial evidence that additional fees provide effective deterrent for motorists to engage with the process were provided.

28. We also proposed that Debt Recovery Agents (DRAs) must be members of an accredited parking association and sign up to a Certification Scheme and asked respondents for views on the contents of the Scheme. 35% of respondents believed that additional fees should only be enforceable where the DRA is certified by a regulated body. Some mentioned that DRAs should follow the principles of independent bodies such as the Financial Conduct Authority (FCA) or the Credit Services Association (CSA). 17% of respondents mentioned that DRAs should be unable to use threatening or intimidating language and should be considerate to vulnerable debtors.

Government position

29. The government recognises that DRAs can provide an additional level of deterrent. However, consultation responses did not provide us with sufficient evidence to determine whether additional fees are required as part of that deterrent, or if their use outweighs the costs to motorists from ill-informed or aggressive debt collecting practices.

30. Given the lack of evidence for the need for additional fees, the Code of Practice will not permit operators and DRAs to add additional fees on top of the amount of the parking charge in its current iteration. Operators will, however, be permitted to use DRAs, subject to additional safeguards such as a ban on misleading and intimidatory language in communications and greater protection for vulnerable customers.

31. We intend to review the policy as part of the general review of the Code of Practice, within two years of its implementation. In that review, we will consider such factors as the level of compliance with parking charges, the amount of court claims relating to unpaid parking charges and any changes in the practices and behaviour of DRAs as a result of the new Certification Scheme.

Appeals Charter

Question 14

14. Do you agree or not that the examples given in the paragraph 46?

Strongly agree/Somewhat agree/Neither agree nor disagree/Somewhat disagree/Strongly disagree

14.1. Please explain your answer. You may wish, for example, to suggest additional cases to be covered in an Appeals Charter or query existing examples. Free text box

Analysis of responses

32. In the Code Enforcement Framework consultation, the Government proposed an Appeals Charter, outlining how operators should handle certain grounds of appeal against parking charges by motorists which are based on innocent error or mitigating circumstances. Over 80% of respondents were in agreement with the idea and in the recent further consultation, we consulted on a draft appeals charter containing examples of instances where the parking charge should be cancelled.

33. When asked if they agreed or disagreed with the examples given in the proposed Appeals Charter, 22% strongly agreed and 22% somewhat agreed. 24% strongly disagreed and 16% somewhat disagreed. Overall, then, 44% agreed and 40% disagreed.

34. 48% of respondents believed that if the charge was issued due to the fault of the motorist then the Charter should not apply. 8% mentioned that there should be an independent appeals process, in addition to the appeal to the parking operator and 6% explicitly mentioned that the Charter should cover cases where equipment had failed.

Government position

35. We have considered the argument that the Charter should not apply where the motorist makes an error, or that motorists’ errors should attract some sort of charge. We have decided that the Appeals Charter will require to the operator to simply cancel the charges if they accept an appeal on the grounds listed in the charter. This is in order to incentivise the use of parking facilities which minimise the potential of user error. For example, technology is able to alert motorists at the time that a Vehicle Registration Number (VRN) has been inputted incorrectly, based on the VRNs which have been captured by ANPR cameras. This is preferable to models based on correcting users’ behaviour by issuing parking charges after the event.

36. We accept the argument that the display of a Pay and Display ticket is part of the contract and that failure to do so in the local authority system represents a contravention. In keeping with our objective of greater consistency, we have removed this ground from the Appeals Charter.

37. Taking into account the responses to the latest consultation, we propose the following appeals charter.

a) Motorist has paid the tariff but made a keying error when registering their vehicle (for example, 0 instead of o; I instead of L;1 instead of I; letters wrong or missing; characters swapped; motorist entered the wrong car registration (eg. their previous car or another vehicle from their household).

b) Evidenced mitigation on land where parking is invited (for example, illness, accident, medical appointments, childcare, overrunning, unforeseen events).

c) Evidenced vehicle breakdown

d) Failure to display permit (copy of permit then supplied)

e) Failure to display Blue Badge (copy of Blue Badge and parking ticket where required supplied; where a driver is not themselves the Blue Badge holder, a statement from the Blue Badge Holder confirming the details of the appeal supplied)

f) Exempt vehicle (as defined in the Parking Code of Practice)

g) Payment machines out of operation and no alternative payment options available (evidence supplied)

h) Potential operator breach of Code of Practice that prevents the motorist being able to adhere to the terms and conditions, or parking charge was only issued because the operator potentially did not adhere to the Code of Practice, e.g. issued a parking charge within the grace period (evidence supplied).

38. This Appeals Charter will be appended to the Parking Code of Practice, with further guidance on the obligations on operators.