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Private parking tickets / Re: Notice to keeper - MET Stansted Southgate Carpark
« on: November 23, 2025, 02:08:31 pm »
Not Hijacking the post, but I am also submitting my first response to POPLA with the following:
I am appealing this Parking Charge Notice as the registered keeper of the vehicle. I am under no legal obligation to identify the driver to a private parking company, and I have not done so. This appeal is made solely in my capacity as Keeper.
This appeal is made on the basis that MET Parking Services is attempting to rely on the Protection of Freedoms Act 2012 (PoFA) in a location where it does not apply. The land in question is not “relevant land” as defined in PoFA Schedule 4. Therefore, MET has no lawful basis to pursue the registered keeper for the Parking Charge.
The vehicle was parked at Starbucks, Southgate Park, which lies within the boundary of Stansted Airport. Whilst the carpark is privately owned by Tabacon Stansted 2 Limited, it still remains within the byelaws boundary (See attached Stanstead map) and MET have not provided any evidence in their refusal of my initial appeal to contradict the byelaw boundary upheld by the Secretary of State and Stanstead Airport Limited. MET have not provided any evidence which supports in the identification of the driver at the time, therefore they are relying on PoFA 2012 Schedule 4 to pursue the registered keeper, where by law they are not permitted to do so.
The Stansted Airport Byelaws 1996 (See attached ByLaw notice) clearly define “the airport” as the land delineated on the plan deposited with the Secretary of State. That plan includes Southgate Park within the boundary of “London Stansted Airport”. Ownership of the land by a private company does not remove it from statutory control. The byelaws apply to all land within the defined airport boundary regardless of ownership.
The Byelaws confirm that penalties are already being imposed on the land to vehicles, as stated in Section 2, 5(3), 6(1) and 6(3) of the byelaws, and therefore confirms that the land is under statutory control.
PoFA Schedule 4 paragraph 3 excludes from “relevant land” any area where parking is subject to statutory control. The evidence here is statutory status, not ownership. Since Southgate Park sits within the Stansted Airport Byelaws boundary, parking there is governed by those byelaws, and the land is not relevant land. Keeper liability under PoFA therefore cannot apply, regardless of MET’s assertions or the contents of their Notice to Keeper
On another note, since this is not 'relevant land' MET have breached the private parking sector single code of practice section 8.1.1(d) by serving a notice to a keeper to be held liable under the Protection of Freedoms Act 2012 where they cannot be held liable
Conclusion
Southgate Park is located within the legally defined Stansted Airport byelaws boundary. The byelaws apply to Southgate Park irrespective of private ownership by Tabacon Stansted 2 Limited. Consequently, the site is excluded from the definition of “relevant land” under PoFA 2012, and MET cannot hold the registered keeper liable.
I am appealing this Parking Charge Notice as the registered keeper of the vehicle. I am under no legal obligation to identify the driver to a private parking company, and I have not done so. This appeal is made solely in my capacity as Keeper.
This appeal is made on the basis that MET Parking Services is attempting to rely on the Protection of Freedoms Act 2012 (PoFA) in a location where it does not apply. The land in question is not “relevant land” as defined in PoFA Schedule 4. Therefore, MET has no lawful basis to pursue the registered keeper for the Parking Charge.
The vehicle was parked at Starbucks, Southgate Park, which lies within the boundary of Stansted Airport. Whilst the carpark is privately owned by Tabacon Stansted 2 Limited, it still remains within the byelaws boundary (See attached Stanstead map) and MET have not provided any evidence in their refusal of my initial appeal to contradict the byelaw boundary upheld by the Secretary of State and Stanstead Airport Limited. MET have not provided any evidence which supports in the identification of the driver at the time, therefore they are relying on PoFA 2012 Schedule 4 to pursue the registered keeper, where by law they are not permitted to do so.
The Stansted Airport Byelaws 1996 (See attached ByLaw notice) clearly define “the airport” as the land delineated on the plan deposited with the Secretary of State. That plan includes Southgate Park within the boundary of “London Stansted Airport”. Ownership of the land by a private company does not remove it from statutory control. The byelaws apply to all land within the defined airport boundary regardless of ownership.
The Byelaws confirm that penalties are already being imposed on the land to vehicles, as stated in Section 2, 5(3), 6(1) and 6(3) of the byelaws, and therefore confirms that the land is under statutory control.
PoFA Schedule 4 paragraph 3 excludes from “relevant land” any area where parking is subject to statutory control. The evidence here is statutory status, not ownership. Since Southgate Park sits within the Stansted Airport Byelaws boundary, parking there is governed by those byelaws, and the land is not relevant land. Keeper liability under PoFA therefore cannot apply, regardless of MET’s assertions or the contents of their Notice to Keeper
On another note, since this is not 'relevant land' MET have breached the private parking sector single code of practice section 8.1.1(d) by serving a notice to a keeper to be held liable under the Protection of Freedoms Act 2012 where they cannot be held liable
Conclusion
Southgate Park is located within the legally defined Stansted Airport byelaws boundary. The byelaws apply to Southgate Park irrespective of private ownership by Tabacon Stansted 2 Limited. Consequently, the site is excluded from the definition of “relevant land” under PoFA 2012, and MET cannot hold the registered keeper liable.