Subject: Formal Complaint – Non-receipt of Notice to Keeper / PCN [XXXXXXXXXX], Vehicle [AA11BBB], Manchester Airport
Dear APCOA Complaints Team,
This is a formal complaint regarding your failure to serve a Notice to Keeper (NtK) for the above-referenced Parking Charge Notice.
No NtK has ever been received at my address. The first correspondence I received was a debt recovery letter from Debt Recovery Plus (DRP). Accordingly, I dispute that any valid NtK was ever issued or served.
Under the Private Parking Single Code of Practice (PPSCoP), Section 11.2, you are required to treat any complaint relating to a parking charge as an appeal. Therefore, this complaint is also to be treated as a formal appeal against the charge.
Grounds of complaint and appeal1. No NtK received – presumption of delivery rebutted
I put APCOA to strict proof that any NtK was created, correctly addressed, and actually posted. You are required to provide:• A copy of the NtK allegedly sent;
• Proof of posting (such as a Mailmark/Smart stamp or postal manifest linking this PCN to a posted item);
• The address used and the DVLA data source relied upon;
• Any audit trail evidencing handover to Royal Mail or your postal provider.
Without such evidence, the alleged NtK cannot be presumed delivered. The presumption of service is expressly rebutted.
2. Keeper liability not established
I was not the driver, and there is no obligation upon a keeper to identify the driver. Furthermore, Manchester Airport is not “relevant land” for the purposes of Schedule 4 of the Protection of Freedoms Act 2012, as it is subject to airport byelaws. You therefore cannot hold the keeper liable in any event.
Required outcome
Given that no NtK was received and no keeper liability can arise, this charge must be cancelled immediately.
If you refuse, you must:• Treat this complaint as a formal appeal under Section 11.2 of the PPSCoP; and
• Provide a POPLA verification code so that the matter may be referred to independent adjudication.
While this complaint and appeal are under consideration, you must place the charge on hold and instruct DRP to cease all contact. DRP has no standing to pursue any alleged contract.
Please confirm cancellation or provide the POPLA code within 28 days.
Yours faithfully,
[Your Full Name]
Registered Keeper (not the driver)