So you now have 33 days in which to appeal to POPLA. My advice is to make a single point appeal to POPLA, only as the Keeper, with the image of the airport boundary map embedded, as follows:
POPLA Appeal: MET Parking Services – PCN [Insert PCN Number]
I challenge this Notice to Keeper on the basis that the location of the alleged contravention—McDonald's, Southgate Park, Stansted Airport—is not “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). Therefore, MET Parking Services cannot hold the registered keeper liable.
Schedule 4 of PoFA only applies where the land is “relevant”, meaning it is not subject to statutory control. Stansted Airport is subject to statutory control under the Airports Act 1986 and regulated by the Civil Aviation Authority. The land in question falls within the official boundary of Stansted Airport, as confirmed by the airport’s own site plan.
Whether the land is leased to a private company is irrelevant. Statutory control applies to all land within the airport boundary unless the Secretary of State has formally revoked that status for a specific parcel. No such revocation exists for Southgate Park or the McDonald's site.
I enclose an official boundary map issued by Stansted Airport, which clearly shows that McDonald's in Southgate Park is located within the airport boundary. This map is not speculative—it is an authoritative document issued by Stansted Airport.
(https://i.imgur.com/ei1R0nR.jpeg)
The registered keeper has not been identified as the driver and is under no legal obligation to do so. Under PoFA, keeper liability can only arise if the land is relevant and the operator has complied with all conditions of Schedule 4. Since the land is not relevant, keeper liability is excluded. MET Parking Services must prove that the person they are pursuing is the liable party. They have failed to do so.
Now to address the operator’s attempt to mislead with the following statement:
“Please note that McDonald’s is not part of Southgate Park. Please note that this is private land and does not fall under airport byelaws.”
This is pure fiction. The site is clearly within Southgate Park, and Southgate Park is within the Stansted Airport boundary. The operator’s claim is not supported by any credible evidence and is contradicted by the airport’s own site plan. The suggestion that the land “does not fall under airport byelaws” is legally illiterate. Byelaws apply to all land within the airport boundary unless the Secretary of State has revoked them for a specific parcel—which has not happened. The leasehold status of the land is irrelevant to whether statutory control applies.
In short, MET Parking Services is attempting to rewrite statutory definitions to suit its own narrative. Their claim is not only wrong—it’s embarrassing.
I respectfully request that POPLA uphold this appeal and instruct MET Parking Services to cancel the charge.
I would respond to the intellectually malnourished goons at MET with the following:
Re: PCN [Insert Reference Number] – Southgate Park (Stansted Airport)
Your latest reply is a classic example of intellectual malnourishment. The assertion that Southgate Park is not part of Stansted Airport is not only factually incorrect but legally incoherent. Southgate Park lies squarely within the Stansted Airport boundary, as confirmed by official maps and multiple adjudications. That boundary is not subject to your whims or wishful thinking—it is defined by law and enforced under the Stansted Airport Byelaws.
Let me spell it out for you, since your grasp of statutory control appears to be on par with a damp sponge:
• Stansted Airport is subject to statutory control.
• Southgate Park is within Stansted Airport.
•Therefore, Southgate Park is subject to statutory control.
• Land under statutory control is not “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012.
• PoFA keeper liability does not apply.
Your Notice to Keeper is therefore legally impotent. You cannot hold the registered keeper liable. You cannot rely on PoFA. You cannot rewrite statutory boundaries to suit your revenue model. And you certainly cannot pretend that your signage or internal delusions override the law.
If you are genuinely confused about the legal status of the land you operate on, I suggest you consult the Stansted Airport Byelaws, available here... https://www.stanstedairport.com/about-us/byelaws/ Better yet, ask your legal department—assuming you have one that isn’t staffed by lobotomised interns.
Your continued reliance on PoFA in this context is not just wrong—it’s a breach of the BPA Code of Practice and your KADOE contract with the DVLA. If you persist, I will escalate this to the DVLA and the ICO for unlawful data use. You are not entitled to pursue keeper liability on land that is excluded by statute, and your misuse of DVLA data will be formally reported.
You now have two options:
1. Cancel the PCN immediately.
2. Issue a POPLA code and prepare to be humiliated in adjudication.
Should you choose the latter, I will submit the official Stansted Airport boundary map, cite the relevant statutory exclusions under PoFA, and include precedent from prior POPLA decisions confirming your legal impotence on this land.
This is your final opportunity to avoid further embarrassment. Choose wisely.
Yours,
[Your Name]
Registered Keeper
Feel free to be even more derisory with these scamming bar stewards.