Free Traffic Legal Advice

Appeal only as the Keeper with the following:

I am the registered keeper. APCOA cannot hold a registered keeper 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 Birmingham Airport is not 'relevant land'.
If Birmingham 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 APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOAS's own profit (as opposed to a byelaws penalty that goes to the public purse) and APCOA 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. APCOA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

The hire company don't know who was driving, so the only person they can have sent it to is the hirer.

Is the notice addressed to the hirer, or to the hire company?

If the latter then it's a matter for the hire company to deal with as its addressed to them. What they should do (and the hirer should contact them to make sure they do), is provide the name of the hirer, who will receive a notice in his own name, which can then be appealed.

I wish posters would give the full background when posting. If you were the Hirer, then, as advised, when you receive a Notice to Hirer (NtH) in your own name, send the following appeal as above but adapted for a Hirer rather than a Keeper:

I am the Hirer of the vehicle. 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 Birmingham Airport is not 'relevant land'.

If Birmingham Airport wanted to hold owners or keepers/hirers 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 APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOAS's own profit (as opposed to a byelaws 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.

It will be cancelled.