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#Post#: 127242--------------------------------------------------
APCOA - Heathrow T4 - Use of Drop Off Zone without making a
valid payment
DIR By: bigred247
Date: August 8, 2026, 8:10 am
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Hi folks, this PCN arrived in the post from APCOA.
It is for "Use of Drop Off Zone without making a valid payment"
at Heathrow Terminal 4.
Are there any grounds for appeal?
I have seen templates for appealing on the forum previously, not
sure of they are relevant in this exact circumstance? if so, can
somebody can post a link to the template.
The discount period expires on the 11th August (in 3 days) so
any quick advice would be greatly appreciated.
Apologies for the late notice, I was away on hols and only just
got back.
Thanks.
HTML https://i.postimg.cc/rFxXSJSK/PCN-apoca-HF20339638-1.jpg
HTML https://i.postimg.cc/X7dSw8wr/PCN-apoca-HF20339638-2.jpg
#Post#: 127256--------------------------------------------------
Re: APCOA - Heathrow T4 - Use of Drop Off Zone without making a
valid payment
DIR By: RichardW
Date: August 8, 2026, 9:52 am
---------------------------------------------------------
If you do a search on here on airport you will see that they are
covered by bylaws, and therefore not relevant land for POFA
purposes and the parking co have no route to transfer liability.
In your case, it being a hire car adds a further layer of
complication - presumably there were no accompanying documents
with the NTH? In general APCOA don't litigate, and often roll
over if a decent appeal is put before them. You have 2 points:
1. Airport so not relevant land and there is no route via POFA
for transfer of liability
2. Not withstanding 1, the vehicle was on hire, and they have
not supplied the required paperwork to transfer liability, so
even if 1 didn't apply, they would not be able to hold the hirer
liable.
Just make sure in any appeal you do not identify the driver,
even incidentally by saying 'I did'!
#Post#: 127362--------------------------------------------------
Re: APCOA - Heathrow T4 - Use of Drop Off Zone without making a
valid payment
DIR By: bigred247
Date: August 10, 2026, 3:11 am
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[member=885]RichardW[/member]
Thanks for the advice.
I have just drafted a template using one sourced from another
post and your advice.
Does this seem to cover it?
--- Quote ---
>
>
> I am appealing this Parking Charge Notice in the capacity in
which APCOA has purported to pursue me, without any admission as
to who was driving the vehicle on the date in question.
>
> 1. Heathrow Airport is not "relevant land" - there is no
statutory route to keeper (or hirer) liability
>
> APCOA will be well aware that Heathrow Airport operates under
statutory byelaws made under the Airports Act 1986 and is not
"relevant land" for the purposes of Schedule 4 of the Protection
of Freedoms Act 2012. Where land is excluded from Schedule 4 in
this way, there is no statutory mechanism to transfer liability
from the driver to the registered keeper, and, by extension, no
mechanism to transfer liability onward from the keeper to a
hirer under paragraph 14 either, since that provision only
operates within a valid Schedule 4 scheme.
>
> If Heathrow Airport wished to hold owners, keepers, or hirers
liable, that would be a matter for the landowner acting under
the airport byelaws, not for APCOA, which is not the landowner,
has not pleaded any byelaw contravention, and has instead framed
this charge purely as a contractual breach by the driver.
APCOA's "parking charge" is not a penalty payable to a public
authority; it is a sum retained for APCOA's own commercial
benefit, further confirming this is a contract law claim against
the driver alone, with no keeper or hirer liability provisions
available to it in law.
>
> 2. In any event, no valid transfer of liability under the hire
provisions
>
> Without prejudice to point 1 above, and notwithstanding that
POFA does not apply to this site at all, I note that the
registered keeper of this vehicle is Arval UK Limited, not
myself. Paragraph 14 of Schedule 4 only permits liability to
move from a hire company to a hirer where the hire company has,
within the prescribed period, supplied the creditor with a copy
of the hire agreement and a statement signed by the hirer
accepting liability. No hire agreement or hirer's statement has
been supplied to APCOA. In the absence of this, APCOA has no
mechanism even setting point 1 aside entirely, by which
liability could ever pass from Arval UK Limited to any hirer.
>
> Conclusion
>
> The registered keeper cannot be presumed or inferred to be the
driver, and liability cannot be pursued via a strained
interpretation of agency law. APCOA's Notice can only ever have
bound the driver, and, for the reasons above, has no lawful
basis to bind either the registered keeper or any hirer of this
vehicle on this site. APCOA has no realistic prospect of success
at POPLA. I invite APCOA to save both parties the wasted time of
a POPLA appeal and cancel this Parking Charge Notice now.
>
>
--- End Quote ---
#Post#: 127393--------------------------------------------------
Re: APCOA - Heathrow T4 - Use of Drop Off Zone without making a
valid payment
DIR By: RichardW
Date: August 10, 2026, 6:34 am
---------------------------------------------------------
--- Quote from: bigred247 link ---
>
>
>
> 2. In any event, no valid transfer of liability under the hire
provisions
>
> Without prejudice to point 1 above, and notwithstanding that
POFA does not apply to this site at all, I note that the
registered keeper of this vehicle is Arval UK Limited, not
myself. Paragraph 14 of Schedule 4 only permits liability to
move from a hire company to a hirer where the hire company has,
within the prescribed period, supplied the creditor with a copy
of the hire agreement and a statement signed by the hirer
accepting liability. No hire agreement or hirer's statement has
been supplied to APCOA. In the absence of this, APCOA has no
mechanism even setting point 1 aside entirely, by which
liability could ever pass from Arval UK Limited to any hirer.
>
>
--- End Quote ---
The point here should be that APCOA are required to send the
documents(*) with the NTH, regardless of whether or not they
were supplied by the hire co.
* - confirmation that from hire company that the vehicle was
hired, copy of hire agreement, a copy of statement of liability
signed by hirer, a copy of the original NtK
Rest looks good.
#Post#: 129220--------------------------------------------------
Re: APCOA - Heathrow T4 - Use of Drop Off Zone without making a
valid payment
DIR By: bigred247
Date: August 31, 2026, 7:30 am
---------------------------------------------------------
Hi [member=885]RichardW[/member],
Apcoa accepted the appeal. Thanks for your help
--- Quote ---
> We refer to your recent correspondence relating to Parking
Charge HF20339638.
> We have carefully reviewed your appeal, taking into
consideration the points you have raised. On this
> occasion, we have decided to cancel this Parking Charge.
> The Heathrow Terminal Drop-Off Zone operates within a
chargeable area. A charge of £7.00 applies for
> each visit.
> Payment must be made online or via the automated telephone
service by midnight on the day following
> the visit. Payments may also be made in advance, with prepaid
credit remaining valid for 12 months. An
> Autopay option is also available.
> The site is monitored using ANPR cameras, which record vehicle
registrations on entry and exit.
> Payments must therefore be made using the correct vehicle
registration number.
> Failure to make a valid payment in accordance with the terms
and conditions may result in a Parking
> Charge being issued.
> As this Parking Charge has been cancelled, no further action
is required.
--- End Quote ---
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