UKPC 2x windscreen PNC's claimform - - forgot permit - appealed - res parking my own space - East Croft House, 86 Northolt Road, South Harrow, HA2 0ES - *** Claim Dismissed ***

[dbuk2000]

Hi

 I have an upcoming hearing at Willesden County Court on the 22nd of April and am looking for some support.

Today I received an email from DBC with their Client's witness statement and they confirm that it has been filed with the court.

Appreciate any help or direction.

my primary questions are as below.

As per the court letter I have 14 days to deliver any documents that I wish to rely upon to the other party.

I presume in this case its the court and the claimant DCB. 

1) In the lease there is a section about the property that I own which states it includes the parking spot. Should I be sending a copy of this page?

2) I am unaware of anything else I should send. 

3) Can any of the defence documents be sent electronically or does it have to be sent via post.

I presume if via post this means I need to really send by latest Friday to ensure they have it 14 days before the court date of 22nd of April.

 

Thanks

 

[FTMDave]

The claim form was issued in January 2022.  It has taken two years and three months to get to a hearing.  Are you sure it's the same case?

[lolerz]

Just had a quick read of this response and will aim to give a proper response tonight.

I'm amazed that UKPC are pushing ahead with this but they're not the brightest of sparks. Providing of course that it is the same case.

Meanwhile, can you get the paragraph of your lease that explicitly states that's your demised parking space (it's usually towards the top) and redact/upload it please to go alongside what you uploaded earlier in the thread.

Can you also upload their witness statement please so that we can see what they're trying to argue?

[dbuk2000]

Just looking its a different case, but the exact same details where I received a ticket for my own spot.

Hopefully its still relevant to keep it in this thread,

That one from Jan 2022 was discontinued prior to the court date whilst this one they unfortunately didnt issue the same. 

[AndyOrch]

Best to start a new topic and we can move todays posts over and mark this one discontinued.

[dbuk2000]

Hi

 

As requested I have set up a new thread. Details as below. Used the initial questions from my previous thread.

1 The date of infringement? 05/07/2018 and 11/07/2018

2 Have you yet appealed to the parking company yet? [Y/N?] Yes and gone through all the steps. Currently have a small claims court date at Willesdon county court for 22nd of April 2024.

5 Who is the parking company? UKPC. DCB are the claimants solicitors

6. where exactly [Carpark name and town] did you park? Not a carpark, it was in my designated space outside my block of flats in South Harrow

I need help in preparing the witness bundle.

At the moment I only know to put in an excerpt from my lease that the parking spot is mine.

I cant see anything in the lease about the management agent/freeholder hiring a 3rd party (UKPC) to issue tickets etc if a valid permit isnt display

. I am struggling what else I can put in the witness statement. 

[AndyOrch]

Have you received the claimants statement yet ?

[dx100uk]

posts moved from existing thread.

please complete this:

 

scan up to one mass PDF all comms in/out in date order (bothsides of ALL: letters) inc your appeal and the defence you filed .

we also need their complete WS inc all exhibits.

dx

[FTMDave]

You've left this late - but not too late.

I'll have a read through both threads this evening when I knock off work and will try to help.

However, we need to see the PCNs and what you wrote in the appeals.  Until then we'll have no idea if they respected POFA times, whether you outed yourself as the driver, etc.

We also need to see their WS.

I've just got to the end of page two of your other thread and it's damn confusing with so many tickets.

Please be clear with us for each ticket. 

When you got the windscreen ticket. 

When you got the PCN. 

What you wrote in the appeal. 

Uploads of both the windscreen ticket and the PCN.

It would be helpful if you would do these things without having to be asked all the time. 

You've come to us at the last minute for help before a court hearing regarding two disputed invoices, yet you haven't shown us the invoices or what your opponent is arguing in their WS.

Ok, I've read through both threads.

1.  Sequence of Events.  A brief description of how you got the tickets.

2.  Supremacy of Contract.  Your ace.  You show your lease.  You did a lot of good work on this in your original thread.  You can use the info in these links and quote the persuasive cases

http://parking-prankster.blogspot.com/2016/11/residential-parking.html

http://parking-prankster.blogspot.com/2016/11/link-parking-lose-in-wrexham-flat-owner.html

http://parking-prankster.blogspot.com/2017/05/ukpc-lose-residential-case-will-vicim.html?m=0

http://parking-prankster.blogspot.com/2017/07/ukpc-lose-residential-case-tenant-can.html

3.  Interest.  It is unreasonable for the Claimant to delay litigation for nearly six years and accrue so much interest.

4.  Double recovery.  You can copy this section virtually verbatim from Mystic Bertie's thread as the PPCs always do the same thing.  Mystic Bertie's WS is on this page  https://www.consumeractiongroup.co.uk/topic/459507-ukpcdcbl-anpr-pcn-appealed-paploc-now-claimform-mcdonalds-bristol-patchway-562-bs34-5tq/page/5/#comments  Mystic Bertie quotes a persuasive case which is attached.

Unfortunately that's it. 

There is probably stuff about UKPC's contract with the landowner being rubbish, about their PCNs not respecting POFA, about rubbish arguments they've made in their their WS, but you've shown us none of that so we can't just guess.

G4QZ465V Excel v Wilkinson.pdf

[lookinforinfo]

You never came back to us on your previous thread about the time you were doing your WS. Did you end up going to Court or did it all just peter out?  Have you checked that they haven't sneaked a ccj through?

Dave has done a great job for you on what needs to be done this time.And it would help your case bigly [as Donald Trump might say] if you could post up the original PCN if you still have it as that should contain so much info  and usually doesn't. If the latter that is good news for your case and is why we need to see it asap.

[dbuk2000]

Hi 

Apologies for the delay. I will be checking and posting here as regularly as possible.

I have just spent the last couple of hours combining PDF, is there anyway to send larger file sizes on here as the attachment is 17mb?

2 hours ago, lookinforinfo said:

You never came back to us on your previous thread about the time you were doing your WS. Did you end up going to Court or did it all just peter out?  Have you checked that they haven't sneaked a ccj through?

Regarding this earlier PCN I a few weeks prior to the court date they issued a notice of discontinuance. I had a few other tickets as well which I settled with DCB.

I didn't want to settle but unfortunately my mother had an operation for a large brain tumour last summer which has severe complications and I am currently her full time carer.

My priorities hence then change and with everything going on I had let the court claim I have been posting about today slip through the cracks.

I want to try and fight this one with there being a resolution either way on the 22nd of April. 

Ignore my previous post I have managed to compress the PDF

up to page 21 is everything I have received and then from page 22 onwards in the witness statement I received from DCB Legal today.

 

 

Claimants WS .pdf

[dx100uk]

  please complete this:

 

[FTMDave]

Thank you for all this.  You've uploaded a huge amount which must have taken some doing.

I'm slowly reading through it.

Regarding both appeals, UKPC have logged you as "Driver and Registered Keeper".  It seems that you outed yourself as the driver.  Can you remember if you clicked some box with "Driver and Registered Keeper"? 

If you can't - it was six flippin' years ago! - are any of these tickets outstanding?  If so, can you start a mock appeal, without actually finishing the appeal, and see if such a box flashes up?

Forget what I wrote above.  Even a mock appeal won't work as more than the 28 days or whatever UKPC allow for appeal have passed.  However, can you remember admitting to being the "driver and registered keeper"?

[dx100uk]

PS next time remove barcodes and stop using a pdf editor to redact things ...follow upload redact as jpg ONLY... then the convert and merge using the websites listed there.

all your redactions could be removed using a pdf editor.

done now

thread title updated

dx

 

[FTMDave]

OK, having read everything, the main points of the WS are suggested below.

You have until Monday to file, and even then a short delay as you are a LiP would be accepted by the court.  So -

1.  Sequence of Events.  A brief description of how you got the tickets.

2.  Supremacy of Contract.  Your ace.  You show your lease.  You did a lot of good work on this in your original thread.  You can use the info in these links and quote the persuasive cases

http://parking-prankster.blogspot.com/2016/11/residential-parking.html

http://parking-prankster.blogspot.com/2016/11/link-parking-lose-in-wrexham-flat-owner.html

http://parking-prankster.blogspot.com/2017/05/ukpc-lose-residential-case-will-vicim.html?m=0

http://parking-prankster.blogspot.com/2017/07/ukpc-lose-residential-case-tenant-can.html

Ridicule their para 24 ii "If the Defendant did not understand the Terms on the signs, they should have exited the land and found alternative parking" and point out that you were on your own land!

Ridicule their para 33 and point out that it is not unreasonable behaviour to have the temerity to park on your own land.

3.  Prohibition.  The signs are wholly prohibitive and cannot form a contract.

4.  No locus standi.  I'm carp with contracts.  However, forum regular LFI is an expert.  I'm sure he'll be on tomorrow to weave his magic.

5.  No keeper liability.  UKPC have not written anything about you outing yourself as the driver.  Forget my posts above.  They've done your work for you with their lazy copy & paste WS!  Ho!  Ho!  Ho!  Therefore point out where they have not respected POFA, and ridicule their para 21 where they state "My Company reasonably believes that the Defendant was the Driver because they would otherwise have nominated a driver, and therefore the Defendant is pursued on that basis" which is laughable. 

You can tweak paras 14, 15 & 19 of Mystic Bertie's WS which is on this page  https://www.consumeractiongroup.co.uk/topic/459507-ukpcdcbl-anpr-pcn-appealed-paploc-now-claimform-mcdonalds-bristol-patchway-562-bs34-5tq/page/5/#comments is

I'm sure LFI will have other POFA comments.

6.  Interest.  It is unreasonable for the Claimant to delay litigation for nearly six years and accrue so much interest.

7.  Double recovery.  You can copy this section virtually verbatim from Mystic Bertie's thread as the PPCs always do the same thing.    Mystic Bertie quotes a persuasive case which is attached.

G4QZ465V Excel v Wilkinson.pdf

[dbuk2000]

Which Court have you received the claim from ? County Court Business Center 

Name of the Claimant :  UKPC         

Claimants Solicitors: DCB Legal

Date of issue – 14/09/2022

Date for AOS - Completed 21/06/2022

Date to submit Defence - Submitted 21/06/2022

What is the claim for – 

1. The Defendant is indebted to the Claimant for Parking Charges issued to vehicle (redacted) at East Croft House, 86 Northolt Road, South Harrow, HA2 0ES. 

2. The PCN was issued on private land owned or managed by Claimant.

3. The vehicle was parked in breach of the Terms on Claimant's signs (the contract), thus incurring the PCNS.

4. The driver agreed to pay within 28 days but did not. Driver is liable as the driver or keeper.

5. Despite requests, the PCNs is outstanding.

The contract entitles C to damages.

And the Claimant Claims.

1. £320 Being the total of the PCN(s) and Damages

2. interest at a rate of 8% per annum pursuant to s69 of the County Courts Act 1984 from the date hereof at a daily rate of £0.04 until judgement or sooner payment.

3. costs and court fees.

What is the value of the claim? 

Amount Claimed £440

court fees £50

legal rep fees £50

Total Amount £540

Have you moved since the issuance of the PCN? (y/N - if Y state Date too) Yes 11/07/2023

Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claimform? Unsure on I&E?, however did not receive any sort of reply pack before the claim form

.....................

I do know that I appealed one of the two tickets this claim was for through their website.

This is when they responded saying the parking charge was correctly issued but as a gesture of goodwill they will reduce to £15.

I didnt pay this and ignored along with everything else they sent up until the claim form was received.

I imagine this appeal is essentially where I am admitting to being the "Driver and registered keeper"

FTM . Thank you thats super helpful and I am going to make a good crack at my response in the next few hours.

I have looked for an email address for Willesden County Court but can not find  I presume I need to send by Saturday latest so they can get it 14 days before (next Monday)

[FTMDave]

Willesden County Court and Family Court - Find a Court or Tribunal - GOV.UK

WWW.FIND-COURT-TRIBUNAL.SERVICE.GOV.UK

---

Willesden County Court and Family Court - Find contact details, opening times, how to get to here, types of cases managed, disabled access to the...

 

[dx100uk]

thread title updated.

you left a part off the POC:

And the Claimant Claims.

1. £320 Being the total of the PCN(s) and Damages

2. interest at a rate of 8% per annum pursuant to s69 of the County Courts Act 1984 from the date hereof at a daily rate of £0.04 until judgement or sooner payment.

3. costs and court fees.

damages?? they cant claim that ...

[dbuk2000]

So I have given the witness statement a start and have the following points/questions to note

1) Completed sequence of events and supremacy of contract. For supremacy of contract I have added in as exhibits extracts from the lease and the official copy of register of the title. Am I missing anything?

2) Prohibition I have added in the one line as per your post Dave, is anything else needed.

3) No Locus Standi - Need help with this

4) No Keeper Liability - Is there a reason this is needed? I did initially appeal one of the tickets so at this point I would have admitted that it was my vehicle. I am just struggling on what to put here.

5) Double Recovery - I have checked the signage from the claimants witness statement and it does state on the signage that £60 will be added if this gets passed onto the debt collectors. That totals £160 per ticket and the claim is for two tickets so I can see where they have got the £320 for as part of their claim. Again I am struggling on how I can turn this into a strong point as in Mystic Berties WS the whole point was that it wasnt stated on any signage that they could add anything onto the original PCN

6) Dave although you didnt have it in your layout, I have added in a section for the breach of code of practise. Point I am making here is that when I initially appealed, they could have told me that I could have gone through my management company to cancel the ticket rather than saying they will reduce it to £15. Again not sure if its relevant.

Looking forward to hearing your thoughts and appreciate all the help so far. 

 

DBUK2000 WS Redacted.pdf

[lookinforinfo]

Thanks for posting up their WS. You have nothing to worry about . if it ever gets to Court you can be as near as 100% that you will win.

We can start off with Joel Little's statement...............says he is a case manager. Couldn't manage a purse.

At Point 6 he makes the point that at all material times his company was accredited by the BPA trying to give the impression that his company is an upstanding pillar of rectitude while taking motorists who allegedly breach their rules  off to Court  for the slightest of misdemeanours. They can count themselves extremely lucky that they were not prosecuted in 2015 when the DVLA banned them from accessing motorists's records because "photographic evidence had been falsified." They were still banned for two months. They were further banned in 2018 for problems with "obligation of contract". 

Point 8 their PCNs state they were  issued because the car was not displaying a valid permit. Yet when they show their signage around the area of Eastcote House all the signs state "NO Unauthorised parking" which is incapable of forming a contract because being prohibitory it offers nothing  contractually the motorist and no mention of Permits in the headlines. It does though state the charge of £90 for any breach but UKPC has decided to breach their own terms by demanding £100.

Point 10 "The Landowner agreement has been extended by mutual agreement". The agreement originally for three months has now been going for another 6 years  and no apparent confirmation for either company. Indeed we do not know which  parties were involved in the extension, how many extensions there may  have been and what changes have been made and agreed.   

Point 11 that decision is an outlier and as UKPC should know even if their case manager doesn't, under PoFA there must be a contract that starts from the land owner. Definition -relevant contract” means a contract (including a contract arising only when the vehicle was parked on the relevant land) between the driver and a person who is—a)

the owner or occupier of the land; or b)

authorised, under or by virtue of arrangements made by the owner or occupier of the land, to enter into a contract with the driver requiring the payment of parking charges in respect of the parking of the vehicle on the land;(a)

the owner or occupier of the land; or (b)

authorised, under or by virtue of arrangements made by the owner or occupier of the land, to enter into a contract with the driver requiring the payment of parking charges in respect of the parking of the vehicle on the land;

Point 12 it would be helpful if the signs exhibited by the Claimant were all legible. As it is one must assume they all state the same things.

Point 13 does the case manager really believe that a prohibitory sign can offer a contract in spite of UKPC and others losing countless cases because there is no contract.  doubtless he will be unable to attend court possibly because he does not want to be challenged on the veracity of his oath.

Point 14 there is no evidence that the driver accepted the contract.  The keeper is a resident with supremacy of contract. Surely something as basic as that should be known to a case manager  as they have lost cases in the past for the sae reason. Goes to veracity again.

Point 22 the alternative option was that the keeper did not believe that the case would be held any more unfairly as the first appeal.

Point 24 [1] surely the Claimant and their patrols were aware that the keeper does have a valid parking permit and they surely know which resident has a permit, even though it is not a requirement under the terms of their lease. The whole case is a complete farce ,totally unnecessary and a waste of the Courts time. It is petty and the charge at best is de minimis.

[ii] he keeper lives on the estate with a proper lease so the idea of parking elsewhere is ludicrous.

[iii] the keeper enjoys supremacy of contract so does not accept that anything is owed. And to quote Parking Eye v Beavis when a residential parking area is involved is completely irrelevant.

[vii] It's a bit rich the Claimant asking the Defendant to act justly and at proportionate cost when they are the ones bringing a ridiculous no chance of winning case to Court . 

[viii] there is nothing evident from the landowner contract. The signatures are redacted so who signed for Trinity estates. A director of the company,  a director of the managing agent, or somebody else. neither are there any witnesses to the contract and we do not even  know who signed for UKPC. As they have been caught out in the past, one would have thought that if they now want to prove everything is above board it would seem important to get signatories transparent. Plus providing proof that 6 years later what the current contract is, who the current signatories are  what changes have been effected would be the minimum necessary.

Point 30 Nominal contribution? It is an additional 60% which definitely puts it into being a penalty. Not only that but those "operational costs" were already included in the £100 that their Lordships agreed in the Parking Eye v Beavis case which the case manager should be well aware of especially as the Courts throw out those double recovery charges when claims are disputed. Excel v Wilkinson is included as confirmation. Furthermore many years ago the Office of Fair Trading ruled that charges  for debt collection could not be made in car parks since motorists had not signed any agreement with them.

It appears that either Mr. Little is almost completely unaware of how PoFA works or he has signed a document  which is tantamount to perjury. No  wonder he does not want to appear in Court.

[FTMDave]

Very quickly as I'm in a rush at work.

On 04/04/2024 at 02:24, dbuk2000 said:

5) Double Recovery - I have checked the signage from the claimants witness statement and it does state on the signage that £60 will be added if this gets passed onto the debt collectors.

So what?  If it were written on the signs that, should you not pay, you authorise them to smash in your car windows with baseball bats, could they legally do so?  Of course not. 

The law is quite clear.  Both the Beavis judgment at the High Court and the Protection of Freedoms Act 2012 state that the original £100 is the maximum that can be charged.  All you have to do here is copy from Mystic Bertie's WS.

On 04/04/2024 at 02:24, dbuk2000 said:

4) No Keeper Liability - Is there a reason this is needed? I did initially appeal one of the tickets so at this point I would have admitted that it was my vehicle. I am just struggling on what to put here.

But UKPC haven't realised you outed yourself as the driver!

They have just copied & pasted their generic WS.  Your mistake wasn't noticed.  So you can turn that to your advantage.  Tweak the below to make it relevant to your case.

Mush rush.

No keeper liability

14. Schedule 4 of the Protection of Freedoms Act 2012 requires the parking
company to quote the parking period. Schedule 4 S9[2][a] states -
“(2)The notice must—
(a)specify the vehicle, the relevant land on which it was parked and the period
of parking to which the notice relates”.

15. There is no period of parking mentioned on the PCN at all.

16. In the persuasive judgement K4GF167G - Premier Park Ltd v Mr Mathur -
Horsham County Court – 5 January 2024 it was on this very point that the
judge dismissed this claim.

19. All this means that the charge cannot be transferred from the driver to
the keeper. Only the driver is responsible for the charge.

So ...

1.  Sequence of Events.  Done.  Good.

2.  Supremacy of Contract.  Done.  Good.  After your current (9) add a paragraph to make it crystal clear.

"I enjoy Supremacy of Contract as, when I purchased the property in 2016, the contract did not include any mention of a parking company or need to show a permit to park on my own property" .

3.  Prohibition.  You can use some of these arguments I found in another WS -

7. The Claimant claims Breach of Contract. For there to be a contract with the
driver there must be an offer, consideration and acceptance .
In this situation the vehicle was parked in a bay with signage stating “Permit
Holders Only. All vehicles must clearly display and valid permit within the
windscreen of the vehicle” There is no offer to accept other than to display a
permit for the bay the vehicle was parked in, and the signage for that bay is
therefore ‘forbidding signage’, not an invitation to park on certain terms. It
disallows other parking and could be construed as only applying to permit
holders, not others who are forbidden from parking. If this is the case, it only
offers to permit holders. This notice forbids any parking at all except by permit
holders and is not an offer at all. It does not make a contractual offer, so
there can be no breach of contract. This therefore means this is a landowner
issue for trespass, and the agreement between PPC and landowner does not
allow for the Claimant to collect for trespass issues.

8. In the case of C5GF17X2 Horizon Parking v Mr J. Guildford 23/11/2016 where
the defendant was parked in an area for permit holders only District Judge
Glen dismissed the claim “because the notice is a prohibition and claimants
are not entitled to pursue for trespass, they are not the landowner.”

9. In the case of C8GF4C12 ES Parking Enforcement v Ms A. Manchester
29/11/2016 District Judge Iyer stated that the signage was forbidding, there
was no mention of the word 'contract' on them. The word 'breach' was on the
signage. As a result of this, the only person that could bring a claim was the
landowner for trespass.

10. In the case of B4GGF26K6 – PCM(UK) -v- Mr Bull (& 2 others) 21/4/16 District
Judge Glen stated in reference to the “ No Parking at any time” sign that
“This notice is an absolute prohibition against parking at any time, for any
period, on the roadway. It is impossible to construct out of this in any way,
either actually or contingently or conditionally, any permission for anyone to
park on the roadway. All this is essentially saying is you must not trespass on
the roadway. If you do we are giving ourselves, and we are dressing it up in
the form of a contract, the right to charge you a sum of money which really
would be damages for trespass, assuming of course that the claimant had
any interest in the land in order to proceed in trespass.

4.  No locus standi.  Use LFI's arguments.

5.  No keeper liability.  Explained above.

6.  Interest.  Done.  Good.

7.  Double recovery.  You have all this in Mystic Bertie's WS as explained above.  Plus, add that they are claiming for damages which is not permitted.

[dbuk2000]

hi LFI and thank you so much for your help so far.

Are your points above for the No Locus Standi section of the WS?

Sorry if I ask basic questions but its just a little daunting having never had to put one of these together before. 

Hi Dave

I have added in the double recovery element from Mystic Bertie's WS and amended the amounts.

Also added in the above for the No keeper liability and amended so it also states that the relevant land was not mentioned in the PCN.

I presume I should take our the breach of contract section I added in as point 25 as that effectively goes against the No Keeper liability and I am stating that I appealed and let them know I was the driver?

Thanks for all the help so far. Latest WS attached

DBUK2000 WS Redacted 04042024.pdf

[lookinforinfo]

With regards to No Locus standi if you look at my post about their WS you will see on Point 6 and point 24 [viii] that there is a number of arguments why the contract doesn't provide enough information on who signed it to be proof that it is a legal document. 

[FTMDave]

The WS is very good and likely to win as it is.  But if it can be tweaked and improved, why not?

In Supremacy of Contract I would expand your (11) and make it into a summary/conclusion of the section. 

11.  I enjoy Supremacy of Contract as, when I purchased the property in 2016, the contract did not include any mention of a parking company or need to show a permit to park on my own property.  i invite the court to dismiss the claim in it's entirety.

In Prohibition your (12) really makes various points so the para needs to be split up and some persuasive cases added. 

The matter of the £90/£100 is a separate legal point.  How about -

12.  The PCNs state they were issued because the car was not displaying a valid permit.  Yet when the Claimant shows their signage around the area of Eastcroft House all the signs state "No Unauthorised Parking" which is incapable of forming a contract because being prohibitory it offers nothing contractually to the motorist. 

13.  The signs make no mention of the need to display permits.

14. In the case of C5GF17X2 Horizon Parking v Mr J. Guildford 23/11/2016 where the defendant was parked in an area for permit holders only, District Judge Glen dismissed the claim “because the notice is a prohibition and claimants are not entitled to pursue for trespass, they are not the landowner.”

15.  In the case of C8GF4C12 ES Parking Enforcement v Ms A. Manchester 29/11/2016 District Judge Iyer stated that the signage was forbidding, there was no mention of the word 'contract' on them. The word 'breach' was on the signage. As a result of this, the only person that could bring a claim was the landowner for trespass.

The PCN

16.  The Claimant's signage refers to "a £90 parking charge" yet both PCNs demand £100.

17.  A charge of £100 per PCN is also the basis of the Claimant's Particulars of Claim (to which they have added a further £60 which i refer to below).

[FTMDave]

Are you sure about?

1.  The signs make no mention of the need to display permits - UKPC's WS is of such poor quality that I can't make the signs out.  However, on the close-up of the standard sign there is a mention of permits half.way down where they have the four little pictures.

2.  There is no location of the relevant land mentioned on the PCN at all - again, it's impossible to read what is written on the NTD or the PCN.  Do they really make no mention of Eastcroft House or similar?

You have to be sure about this, you don't want to undermine your own case with inaccuracies.

There are some other small points re the rest of the WS but I don't want us to get lost in minutiae.  Please come back to us about this, then we can add the finishing touches.

In fact if you are comfortable with the changes I suggested in the last post, then please make them and then upload a new version of the WS, to avoid confusion.

Edited April 5 by FTMDave
Extra info added