please can you check the reply and offer any suggestions many thanks
Subject: Response to Parking Charge Notice [STN1350423]
Dear Sir or Madam,
I am writing as the hirer of the vehicle in relation to the above Parking Charge Notice.
Your notice was received on [29/10/2025], almost [ 84 days] after the alleged parking event on [07/08/2025]. This is well outside the timeframe allowed under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) for transferring liability to the keeper or hirer.
Furthermore, APCOA has previously confirmed in many cases that it does not rely on PoFA to establish keeper or hirer liability. As such, there is no legal basis to pursue me as the hirer.
I am the Hirer. APCOA cannot hold a Hirer liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, APCOA will be well aware that they cannot use the PoFA provisions because Stansted Airport is not 'relevant land'.
If Stansted Airport wanted to hold owners or 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 APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOA’s own profit (as opposed to a bylaws penalty that goes to the public purse) and APCOA has relied on contract law allegations of breach against the driver only.
The Hirer 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. APCOA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
I therefore request that this charge be cancelled immediately. Please confirm this in writing. Should you disagree, please provide evidence of full compliance with all relevant PoFA provisions, including copies of any documentation received from the hire company that meet the statutory requirements.
Kind regards,