Yes. Just copy and paste into the response webform. You cannot attach or format anything.
I also advise you to send the following to Initial Parking at complaints@initialparking.co.uk and CC info@britishparking.co.uk; kadoeservice.support@dvla.gov.uk and yourself as a follow up to the formal complaint:
Subject: Your false “no byelaws” claim – gross incompetence by Initial Parking and your solicitor
To: complaints@initialparking.co.uk
Cc: info@britishparking.co.uk; kadoeservice.support@dvla.gov.uk
Dear Initial Parking,
Your previous correspondence contained the astonishing claim that “no byelaws have been made” for Cornwall Airport Newquay. That is categorically false and displays an embarrassing lack of due diligence for a company purporting to operate airport parking.
The Cornwall Airport Newquay Airport Byelaws 2017, made under sections 63–64 of the Airports Act 1986, are published openly on the airport’s own website:
https://www.cornwallairportnewquay.com/wp-content/uploads/2025/10/CAL-Airport-Byelaws-January-2017.-1-1.pdf
It took me less than five minutes to locate this document and I attach it to this email to prove the point. If your legal adviser — the same individual who also represents the British Parking Association — failed to locate a public document and advised you that no byelaws exist, that speaks volumes about their competence and your own operational oversight.
The byelaws contain explicit provisions governing No Waiting or Parking (5(12)), Parking Charges (5(13)) and Parking and Airside Driving (5(14)), which clearly place the land under statutory control. Accordingly, Cornwall Airport Newquay is not “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012, and you therefore have no lawful basis whatsoever to hold a keeper liable.
Your continued use of Notices to Keeper asserting PoFA liability on airport land constitutes:
[indent[• A breach of the Private Parking Single Code of Practice, paragraph 8.1.1(d); and
• A breach of your DVLA KADOE contract, as it involves the misuse of keeper data for an unlawful purpose.[/indent]
I have copied this email to both the BPA AOS Compliance Team and the DVLA KADOE Compliance Team, who will wish to review how a supposedly professional parking operator and its solicitor managed to make such an elementary legal error.
For the avoidance of doubt, I am not seeking cancellation of the PCN, as the matter is already before POPLA. However, should this proceed to litigation, I will draw the court’s attention to your misrepresentation of PoFA, your reliance on incompetent legal advice, and your clear non-compliance with both the PPSCoP and KADOE contract.
Your firm has demonstrated a breathtaking level of ignorance in assuming that you could rely on PoFA when operating on airport land governed by byelaws. You would be well advised to immediately:
1. Remove all references to PoFA or “keeper liability” from your NtKs for airport sites;
2. Undertake a full compliance audit of all such sites; and
3. Seek competent legal advice — ideally from someone capable of locating a document that appears on the airport’s own website.
I will also be drawing local media attention to this matter, highlighting your company’s apparent incompetence and disregard for statutory law. The public deserves to know that you are misrepresenting legal obligations and operating unlawfully on airport land. You may deal with the reputational consequences that follow.
Yours faithfully,
[Name]
Registered Keeper of [VRM]
Here is a link to a reduced size PDF of the byelaws that you can download and attach to the email:
https://www.dropbox.com/scl/fi/q93oo637vtchk0amd2qsa/CAL-Airport-Byelaws-January-2017.-1-1-2.pdf?rlkey=5zykrli10m3savi9glca0634s&st=fc6ca2ip&dl=0
As suggested in the email, you should be making contact with the media, especially local press, TV and radio about this farce, so that other recipients of PCNs at this location hnow their rights and not to identify the driver.
Why are you only telling us now that the driver is not an England/Wales resident?
They mentioned it in their opening post.
My bad. Too much to trawl back through.
Anyway, you should also send the following email, addressed to both the BPA and the DVLA at info@britishparking.co.uk and kadoeservice.support@dvla.gov.uk and CC yourself:
Subject: Formal Complaint – Initial Parking Ltd: Misuse of DVLA Data and Misrepresentation of Keeper Liability under PoFA (Cornwall Airport Newquay)
Dear [BPA/DVLA] Investigations Team,
This complaint has been submitted simultaneously to the British Parking Association (AOS Compliance Team) and the DVLA (KADOE Compliance Team) as both are responsible for oversight of operator compliance and data handling.
I write to lodge a formal complaint against Initial Parking Ltd (AOS Member, BPA) for systemic breaches of both the Private Parking Single Code of Practice (PPSCoP) and their KADOE contract with the DVLA. This complaint concerns the company’s repeated misrepresentation of keeper liability under the Protection of Freedoms Act 2012 (PoFA) in relation to parking charge notices issued at Cornwall Airport Newquay (P2 East, TR8 4RQ).
1. Summary of Misrepresentation
Initial Parking’s Notice to Keeper (NtK) for PCN [reference] explicitly invokes PoFA keeper liability on airport land that is not “relevant land” under Schedule 4, paragraph 3(1) of the Act. Cornwall Airport Newquay is owned by Cornwall Council, a statutory body, and designated under the Airport Byelaws (Designation) Order 2009 for the purposes of section 63 of the Airports Act 1986. Airport land subject to statutory control is excluded from PoFA by definition.
The operator’s misstatement of PoFA liability therefore constitutes a breach of PPSCoP section 8.1.1(d), which explicitly states:
“The parking operator MUST NOT serve a notice or include material on its website which in its design and/or language states the keeper is liable under the Protection of Freedoms Act 2012 where they cannot be held liable.”
This unlawful claim of keeper liability is aggravated by the operator’s access to DVLA data under a contract which expressly prohibits such misuse.
2. Operator’s Misleading Response
Following a formal complaint, Initial Parking’s written response (dated 30 September 2025) stated:
“No Byelaws have yet been made further to the Airport Byelaws (Designation) Order 2009… Accordingly, the PCN remains valid.”
This is factually incorrect. Cornwall Airport Limited has published Airport Byelaws dated January 2017, available publicly at:
https://www.cornwallairportnewquay.com/wp-content/uploads/2025/10/CAL-Airport-Byelaws-January-2017.-1-1.pdf
These byelaws include sections on parking and vehicle control, confirming that the airport is under statutory control. Initial Parking’s false claim that “no byelaws have been made” demonstrates both incompetence and reckless disregard for their statutory obligations.
3. Breach of KADOE Contract
By misrepresenting PoFA liability on non-relevant land and issuing NtKs implying lawful transfer of liability, Initial Parking have breached their KADOE contract, which requires:
• Full compliance with the applicable Code of Practice (now the PPSCoP);
• Use of keeper data only for lawful purposes consistent with the Code and PoFA.
Initial Parking’s misuse of DVLA data to issue an invalid PoFA-based NtK constitutes unlawful processing of personal data obtained from the DVLA.
4. Requested Action
I request that both the BPA and DVLA:
1. Conduct a compliance investigation into Initial Parking’s use of PoFA wording on all NtKs issued at Cornwall Airport Newquay and any other sites under statutory control.
2. Require Initial Parking to amend all NtK templates and correspondence to remove unlawful PoFA references for non-relevant land.
3. Confirm what sanctions will be applied for these serious breaches of the PPSCoP and KADOE contract.
4. Require Initial Parking to contact all affected data subjects to correct their previous misstatements of legal liability.
Attached/available on request:
• Copy of Initial Parking’s NtK
• Complaint correspondence and their written reply
• Link to Cornwall Airport Byelaws (2017)
This is a serious matter of systemic legal misrepresentation and unlawful data use. I expect acknowledgment and confirmation of investigation.
Yours faithfully,
[Full name]
[Address]
Registered Keeper of vehicle [VRM]
You can respond to the Muppets at Initial with the following:
Subject: Formal Complaint – Misrepresentation of Law and PoFA Keeper Liability (PCN [reference])
Dear Initial Parking,
Your latest response is as embarrassing as it is wrong. It confirms that your company has absolutely no grasp of the law you’re attempting to rely on. I will try and simplify this or you may want to pass it to a responsible adult within your firm, who has at least a basic grasp of the law.
Cornwall Airport Newquay was designated under The Airport Byelaws (Designation) Order 2009 for the purposes of section 63 of the Airports Act 1986. That designation places the land under statutory control, and that’s all that matters. Whether or not local byelaws have subsequently been drafted, signed, laminated, or nailed to a wall is completely irrelevant. The land’s legal status was fixed the moment it was designated.
You might want to have the responsible adult in your office actually read the Protection of Freedoms Act 2012, Schedule 4, paragraph 3(1)(c). It excludes from “relevant land” any land “on which parking is subject to statutory control.” Once excluded, you cannot — under any circumstances — invoke PoFA to pursue a registered keeper. No amount of wishful thinking or creative fiction changes that.
Your attempt to claim that the land isn’t “subject to statutory control” because byelaws “have not yet been made” is laughable. That’s like claiming the Highway Code doesn’t apply until someone prints it in colour. The statutory control is there by virtue of the Airports Act and the Designation Order — it doesn’t need your approval, comprehension, or participation.
It’s astonishing that a company authorised to obtain DVLA keeper data still doesn’t understand such a basic point of law. Misstating keeper liability in this way breaches both the Private Parking Single Code of Practice and your KADOE contract. You are operating outside the terms of your authorisation and misleading the public.
Here’s what’s going to happen next:
1. You should cancel PCN [reference].
2. You should cease misrepresenting PoFA on any airport land.
3. You should correct your NtK templates before another one of these embarrassing legal blunders leaves your office.
If you do not confirm compliance within 14 days, this correspondence will be forwarded in full to the BPA Compliance Department and DVLA AOS Investigations, along with a copy of the Designation Order and your legally illiterate response.
Yours sincerely,
[Name]
Registered Keeper of [VRM]
Depending on their response, remind me in two weeks to give you the follow up to the BPA and the DVLA.
It never ceases to amaze how intellectually malnourished these greedy, unregulated private parking firms are. They have obviously not read the the Airport Byelaws (Designation) Order 2009 (https://www.legislation.gov.uk/uksi/2009/2576/pdfs/uksi_20092576_en.pdf) which clearly states:
(https://i.ibb.co/cmKmVBS/uksi-20092576-en.jpg)
For the avoidance of doubt, here is a link to the relevant byelaws under section 63(1) of the Airports Act 1986(a) (https://www.legislation.gov.uk/ukpga/1986/31/section/63/data.html).
Use the following as your POPLA appeal and upload the this PDF (https://www.legislation.gov.uk/uksi/2009/2576/pdfs/uksi_20092576_en.pdf) with the appeal on their portal:
POPLA Verification Code: [POPLA code]
Operator: Initial Parking Limited
PCN: [reference]
Site: Cornwall Airport Newquay – P2 Car Park (East), TR8 4RQ
Date: [date]
I am the registered keeper. I am under no legal obligation to identify the driver to an unregulated private parking firm and I decline to do so.
Preliminary point for the POPLA Assessor
Before looking at any “merits” arguments (signs, times, payments, etc.), the first thing POPLA must evaluate is whether the person being pursued can be liable at all. If the land is not “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), then keeper liability cannot arise and there is nothing further for POPLA to consider. This is that case.
Why this is not relevant land
PoFA Schedule 4 only applies on “relevant land”. Paragraph 3(1)(c), read with 3(3), excludes land where parking is “subject to statutory control”. Cornwall Airport Newquay is under statutory control by airport byelaws made under section 63 of the Airports Act 1986. The Secretary of State has designated Newquay Airport for the purposes of section 63 by statutory instrument: “The Airport Byelaws (Designation) Order 2009”. Statutory control = not relevant land = PoFA cannot be used to transfer liability from driver to keeper.
Operator’s legal misunderstanding
The operator’s Notice to Keeper states or implies PoFA keeper liability on this airport land. That is a basic legal error. Schedule 4 paragraph 3(1) shuts the door on keeper liability where byelaws apply. The operator’s reliance on PoFA here simply demonstrates a failure to comprehend the threshold question POPLA must decide first.
Driver not identified, so the keeper cannot be pursued
I am the keeper and I have not been identified as the driver. There can be no presumption or inference that the Keeper is the driver. This is confirmed in the persuasive appellate case law in VCS v Edward (2023) where the judge confirmed that without evidence, there can be no inference.
Because this is not relevant land, PoFA does not apply and there is no lawful route to hold the keeper liable. That ends the matter. POPLA must allow the appeal on this single ground.
Evidence supplied
Copy of “The Airport Byelaws (Designation) Order 2009” (PDF attached).
Link to section 63 Airports Act 1986 (byelaw-making power): https://www.legislation.gov.uk/ukpga/1986/31/section/63/data.html
Legal references for ease
• PoFA 2012 Schedule 4, paragraph 3(1)(c) and 3(3)
• Airports Act 1986, section 63
• The Airport Byelaws (Designation) Order 2009
Conclusion
This airport land is not relevant land for PoFA. The driver is not identified. The keeper cannot be liable. The appeal must be allowed.
I do not think that the attempted payment is relevant for the initial appeal. It can be saved for POPLA if necessary. It is a wasted effort for what is invariably a rejection, irrespective of the actual facts.
Byelaws vs “relevant land” in simple terms:
• PoFA keeper liability only works on “relevant land”. That means ordinary private land without special laws controlling parking.
• Airports, some rail stations and similar places are under “statutory control” via byelaws. That makes them not “relevant land”.
• If it’s not relevant land, PoFA cannot be used to make the registered keeper pay. Only the driver could be liable under contract law.
• At Newquay Airport, byelaws/statutory control apply, so Initial Parking cannot use PoFA to chase the keeper. Only the driver could be pursued, and they still have to prove a contract breach.
So, whether the Keeper was driving or not, our advice is to never identify the driver. Unless the keeper identifies the driver, inadvertently or otherwise, the operator has no way of knowing the drivers identity and only the driver can be liable.
There is no need for the Keeper to "lie", even if they were the driver. The burden of proof is on the operator to prove that the Keeper was also the driver. All the Keeper has to do is refer to the driver in the third person. No "I did this or that". only "the driver did this or that".
The driver liable for any charge is the one who drives the vehicle on to the property, not the one who drives it off, if they are different entities. However, that is not really relevant here because the location is not relevant land for the purposes of PoFA as it is under statutory control of airport byelaws.
As long as the unknown (to them) driver is not identified by the known Keeper (no legal obligation to do so to an unregulated private parking firm) they cannot transfer liability to the Keeper. You now have to do two things as the Keeper:
Appeal the PCN (only as the 'Keeper' or 'other') with the following:
I am the registered keeper. Initial Parking cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, Initial Parking will be well aware that they cannot use the PoFA provisions because Cornwall Airport Newquay is not 'relevant land'.
If the landowners wanted to hold keepers liable under Airport Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because Initial Parking is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for Initial Parking’s own profit (as opposed to a bylaws penalty that goes to the public purse) and Initial Parking has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Initial Parking have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
At the same time, send the following email to info@initialparking.co.uk and CC yourself, as a formal complaint to Initial Parking:
Subject: Formal complaint – Breach of PPSCoP 8.1.1(d) and DVLA KADOE (misstated PoFA keeper liability at Cornwall Airport Newquay) – PCN [reference]
Dear Initial Parking Complaints Team,
I write as the registered keeper regarding PCN [reference] for vehicle [VRM] at Cornwall Airport Newquay (P2 East), TR8 4RQ, on [date]. This is a formal complaint about your misrepresentation of keeper liability under Schedule 4 to the Protection of Freedoms Act 2012 (PoFA), placing you in breach of the Private Parking Single Code of Practice (PPSCoP) section 8.1.1(d). As you know, non-compliance with the PPSCoP is also a breach of your DVLA KADOE contract, which requires adherence to the applicable Code as a condition of data access.
Why PoFA keeper liability cannot apply here
• Cornwall Airport Newquay is subject to statutory control (airport byelaws/designation), so it is not “relevant land” for the purposes of PoFA Schedule 4.
• Your Notice to Keeper (NtK) states or implies that you may hold the keeper liable under PoFA. That assertion is wrong for this site and constitutes a clear breach of PPSCoP 8.1.1(d), which prohibits stating or implying keeper liability where Schedule 4 does not apply.
This complaint is separate from my Keeper only appeal
For clarity, I am submitting a no Keeper-liability appeal via your portal at the same time. This complaint is distinct: it concerns your systemic compliance failure in misstating PoFA keeper liability on land under statutory control.
Required remedies (within 14 days)
1. Cancel PCN [reference] and confirm that you will not assert PoFA keeper liability at Cornwall Airport Newquay (or any other site under statutory control).
2. Rectify all NtK templates, website wording and automated correspondence to remove any statement or implication that keeper liability arises on non-relevant land.
3. Conduct an audit of outstanding NtKs for Cornwall Airport Newquay (and any other sites under statutory control), write to affected keepers to correct the misstatement, and confirm you have done so.
4. Provide details of the compliance steps, staff guidance and training you will implement to prevent recurrence.
5. Confirm cessation of any third-party data sharing for this PCN and either erase my personal data under UK GDPR Article 17 or, at minimum, restrict processing under Article 18 pending conclusion of this complaint.
Regulatory escalation
If you do not provide a full and satisfactory response addressing each point within 14 days, I will refer this complaint and evidence to the BPA compliance team and the DVLA AOS Investigations Team for investigation of a PPSCoP/KADOE breach.
Please respond by email or post (your choice). Do not require telephone contact, web portals or third-party platforms to progress this complaint. Treat this 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 [VRM]
PCN: [reference]