Free Traffic Legal Advice

Thank you all for your invaluable, quick and professional assistance it is greatly appreciated as always:

I have tried to take your helpful inputs and amended.

Dear Sir/Madam,

I write further to your letters of 27 May 2026. Their contents are noted.

I have no further representations to make, and I decline your invitation to identify the driver. My reasons are set out below so that my position is unambiguous and on record.

1. There is no existing route to keeper liability.

You expressly acknowledge in your own letters that responsibility “lies with the driver.” Leeds Bradford Airport roadways are not “relevant land” within the meaning of Schedule 4 of the Protection of Freedoms Act 2012, being subject to statutory control. PoFA keeper liability is therefore unavailable to you, and you have not purported to invoke it. There is accordingly no lawful mechanism by which I, as registered keeper, can be held liable for an alleged contravention by the driver.

2. I am under no obligation to identify the driver, and I will not.

Absent applicable PoFA provisions, no statute or contract compels a keeper to name the driver in these circumstances. Your request that I supply my insurance policy, the driver’s full name and serviceable address, or a signed authority is a request I am entitled to refuse, and I exercise that right.

For the avoidance of any doubt, my silence is the deliberate exercise of a legal right in circumstances where the law imposes no duty to speak—it is not, and should not later be characterised as, any admission as to the identity of the driver. In this regard, I note the decision in Vehicle Control Services Ltd v Edward, in which the Court of Appeal confirmed that where keeper liability under Schedule 4 of the Protection of Freedoms Act 2012 is unavailable, there is no general obligation upon a registered keeper to identify the driver and no automatic basis upon which liability can be transferred from driver to keeper. My decision not to identify the driver should therefore not be treated as evidence that I was the driver, nor as giving rise to any presumption of liability.

3. No contract was formed as alleged.

Your case rests on an alleged contract with the driver. You have neither identified the driver nor established that the asserted terms were communicated and accepted such that any contract arose. That is a matter you would have to prove; it is not for me to disprove.

I note your “goodwill” offer and your schedule of escalating sums and threatened debt-recovery costs. I do not accept that any sum is lawfully due. Should you nonetheless pursue this, I will rely on this correspondence, and I put you on notice that I consider continued pursuit in these circumstances to be without merit.

I consider this matter closed and do not intend to enter into protracted correspondence.

Yours faithfully,

Thank you both

Thank you all so much for assisting which is greatly appreciated

Kind regards

Yes of course

1- We appealed the 2 notices using the exact wording and submitting this for both notices:

Your Reason for Appealing the Charge Notice:
Please complete the following screen, outlining the reason for your appeal. Please provide as much information as possible that will help our team to investigate the matter and attach any evidence you may have that supports your case. When supplying attachments we accept photographs in JPEG format and will accept documents in either scanned pdf format or word documents. We cannot accept zip files.
Reason: *

There was no signage at the car park/location indicating any restrictions

Explanation: *

I am appealing this charge on the following legal grounds:

As the registered keeper, I wish to make clear that VCS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, VCS will be well aware that they cannot use the PoFA provisions because Leeds Bradford Airport is not 'relevant land'.

If Leeds Bradford Airport wanted to hold owners or keepers liable under Airport Byelaws, 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 VCS is not the Airport owner and this 'parking charge' is not and never attempts to be a penalty. It is created for VCS's own profit and VCS 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. The Notice to Keeper can only hold the driver liable. I require this charge notice to be cancelled immediately.

Yours faithfully

2- Please find the wording of the 2 letters that they have sent us on the 27th of May:

Re: Parking Charge Notice Number: VCS - Vehicle:
Site: Leeds Bradford Airport Roadways Post Code: LS19 7TU
Contravention Date: 12/04/2026
We refer to correspondence received from you concerning the above numbered Charge Notice.
Please note that responsibility for this Charge lies with the driver of the vehicle at the time the parking contravention
was observed. However, it appears from what you have stated in your appeal that you were not the driver on the date
in question.
We therefore require documentary evidence of your insurance policy, confirming any individuals who are authorised
to drive your vehicle in addition to yourself.
In addition, in order for us to process your appeal correctly, please follow the instructions below:
1. If you were the driver on the day in question, please confirm this within your next correspondence.
2. Notify the driver of the vehicle that they will need to appeal to us directly, including their FULL NAME (Forename
and Surname) and a valid FULL SERVICEABLE ADDRESS within 14 days.
3. If you are representing the driver we require a signed and dated statement from the driver of the vehicle confirming
that you are authorised to appeal on his/her behalf; this needs to be an original signature and not a photocopy or a
stamp. The statement MUST contain the drivers FULL NAME (Forename and Surname) and a valid FULL
SERVICEABLE ADDRESS.
Please ensure that correspondence is submitted through the portal www.myparkingcharge.co.uk in order to correctly
adhere with the appeals process.
OR
4. Pay the PCN. Payments can be made online at www.myparkingcharge.co.uk by following the links for "Pay Now",
or over the phone by calling 0845 226 9138 and using a valid Credit or Debit Card to make payment. It is your
responsibility to ensure that payment is received within our office by the date specified.
As a gesture of goodwill we have placed the charge on hold for an additional period of 14 Days to enable one of the
above actions to be complied with.
We are willing to re-offer you the original discounted charge of £60 as full and final settlement of this Notice, if
payment is received within our office on or before the 10/06/2026.
If payment is not received by this date, the amount payable will revert to £100, payable by 24/06/2026. Failure to pay
this charge within the stated times, may result in Debt Recovery action been taken and further costs up to an
additional £70.00 being incurred.
Yours sincerely
Appeals Administration Team
CENTRAL PROCESSING OFFICE

Kind regards

Good evening, I’m really struggling at the moment and was wondering if anyone could assist me with exactly how to appeal these two fines.

Good morning

Firstly I would like to thank you both for your responses and input its greatly appreciated I am still not sure of the next steps but looks like your suggestion is that we try going down an appeal firstly and waiiting. Unfortuntaely i have to be perpared for a rejection.

Kind regards

I was unclear earlier — apologies for any confusion.

I will be selecting the following option on the APCOA portal, as per the guidance provided:
Appellant Type: Vehicle’s Keeper
Selected: I was the Vehicle’s Keeper when the contravention occurred.

I now understand that this is the correct and accurate choice, and that selecting “Keeper” does not constitute an admission of being the driver as mentioned.

Kind regards

I have received a Parking Charge Notice (PCN) from APCOA regarding an alleged contravention at Manchester Airport – Terminal 1, Lower Drop-Off Forecourt

The PCN Details are as follows:

    Issuer: APCOA Parking (Manchester Airport)

    Location: Lower Drop-Off Forecourt, Terminal 1

    Date of event: 30/09/2025

    Entry time: 23:15:52

    Exit time: 23:16:53

    Duration: approx. 1 minute

    Reason given: “Use of Pick-Up / Drop-Off Zone Without Making a Valid Payment”

Timeline and circumstances:

    I briefly entered the drop-off area to collect family and was there for about one minute.

    I made payment at the drop-off zone and have a credit-card transaction record confirming this.

    It is unclear from the PCN whether APCOA believe no payment was made or whether the payment didn’t fully cover the stay.

    I could of exited around a minute after the paid period.

    I did not intentionally avoid payment, and I believe a one-minute difference should fall within reasonable tolerance (“de minimis”), especially since payment was made.

A few days later, I received the PCN by post.

Questions:

    Is this PCN enforceable under airport byelaws or private parking rules?

    Would a 1-minute overstay normally count as de minimis or be covered by any grace period?

    What’s the best way to word an appeal to APCOA?

    You can view the redacted PCN here: https://postimg.cc/B89tGwSH

What I can provide:

    Redacted PCN. https://postimg.cc/B89tGwSH

Thank you very much for any advice or guidance — I just want to make sure I phrase my appeal correctly and don’t weaken my position.

Kind regards,

AMG