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#Post#: 128205--------------------------------------------------
My appeal to APCOA, please take a look
DIR By: TrabatDave
Date: August 19, 2026, 6:50 am
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Hi all,
I'm constantly receiving this dross from APCOA and have put this
appeal together with an additional paragraph suggesting that
they whitelist the car to prevent them incurring printing and
postal costs in future.
I'd be interested to know if anybody else has tried this
approach - and if it worked.
Thanks in advance,
I am the registered keeper of the vehicle and appeal against
this Parking Charge Notice solely as keeper.
APCOA cannot rely upon Schedule 4 of the Protection of Freedoms
Act 2012 (“POFA”) to transfer any liability of the driver to me
as registered keeper. Heathrow Airport, including the Terminal
Drop-Off Zone, is subject to statutory control, including the
Heathrow Airport Byelaws. Land subject to statutory control is
expressly excluded from the definition of “relevant land” in
Schedule 4 POFA.
Accordingly, there is no statutory keeper liability under POFA
in this case.
If APCOA contends that I am nevertheless personally liable, it
must identify and establish the legal basis upon which that
liability arises. The mere fact that I am the registered keeper
does not establish that I was the driver, nor does it create
contractual liability for a charge incurred by the driver.
I do not admit to being the driver and I decline to identify the
driver. There is no general legal requirement for a registered
keeper to identify the driver in circumstances such as this, and
APCOA cannot circumvent the absence of POFA keeper liability
simply by inviting or pressuring the keeper to provide driver
details.
Nor can liability be transferred to the registered keeper merely
by an assertion of agency. If APCOA's case is that a contract
was breached, it must establish that the person it seeks to hold
liable was a party to that contract and incurred the alleged
liability. Keeper status alone is insufficient.
I therefore require APCOA either to cancel this Parking Charge
Notice or, if it rejects this appeal, to provide the appropriate
POPLA verification code so that the matter can be independently
determined.
For the avoidance of doubt, I am appealing solely as the
registered keeper. I do not identify the driver and I do not
accept any liability for this Parking Charge Notice.
Please also ensure that no further requests for driver
identification are treated as an admission of liability or as
evidence that the registered keeper was the driver.
I invite APCOA to cancel the Parking Charge Notice now rather
than incur the unnecessary costs of pursuing a charge for which
it has no basis in keeper liability.
As a practical matter, and to avoid unnecessary correspondence
and costs arising from future notices issued in respect of this
vehicle, I also invite APCOA to add this vehicle registration to
an appropriate whitelist or otherwise flag the vehicle against
my keeper details. I have made my position clear that, as
registered keeper, I do not accept liability for driver-only
charges where no statutory keeper liability applies. It would
therefore be disproportionate and wasteful for APCOA to
repeatedly issue and pursue charges against me in circumstances
where the same issue has already been explained.
Kindly confirm receipt of this email and provide confirmation
that the Parking Charge Notice has been cancelled. I would also
ask you to confirm that the vehicle registration has been added
to your whitelist, or otherwise flagged to prevent similar
notices being issued in future.
#Post#: 128214--------------------------------------------------
Re: My appeal to APCOA, please take a look
DIR By: DWMB2
Date: August 19, 2026, 7:42 am
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I'd be amazed if they added your vehicle to any sort of
whitelist. APCOA have been hired by Heathrow to enforce
parking/drop off - the drop off charges almost certainly go to
the airport, with APCOA retaining PCN income. If they put your
vehicle on a 'whitelist', they would potentially be breaching
the terms of their contract with Heathrow by allowing drivers of
a particular vehicle to be exempt from the charges Heathrow have
put in place.
At face value (leaving aside arguments around signage etc.) the
driver enters into a contract, and flowing from that ends up
owing money to APCOA. Whilst they can't rely on PoFA to hold you
liable, they can send you PCNs in the hope that you pay up or
dob in the driver. If the driver(s) of your vehicle don't pay
the drop off charges, the consequence is PCNs that you will have
to appeal each time.
Based on DVLA data, APCOA issue about 6,200 PCNs every day,
yours will be a drop in the ocean.
#Post#: 128220--------------------------------------------------
Re: My appeal to APCOA, please take a look
DIR By: TrabatDave
Date: August 19, 2026, 8:16 am
---------------------------------------------------------
--- Quote from: DWMB2 link ---
>
> I'd be amazed if they added your vehicle to any sort of
whitelist. APCOA have been hired by Heathrow to enforce
parking/drop off - the drop off charges almost certainly go to
the airport, with APCOA retaining PCN income. If they put your
vehicle on a 'whitelist', they would potentially be breaching
the terms of their contract with Heathrow by allowing drivers of
a particular vehicle to be exempt from the charges Heathrow have
put in place.
>
> At face value (leaving aside arguments around signage etc.)
the driver enters into a contract, and flowing from that ends up
owing money to APCOA. Whilst they can't rely on PoFA to hold you
liable, they can send you PCNs in the hope that you pay up or
dob in the driver. If the driver(s) of your vehicle don't pay
the drop off charges, the consequence is PCNs that you will have
to appeal each time.
>
> Based on DVLA data, APCOA issue about 6,200 PCNs every day,
yours will be a drop in the ocean.
>
--- End Quote ---
You are probably right, but there's nothing to lose from my
perspective; If I DO hit the jackpot I'll be sure to post here!
#Post#: 128226--------------------------------------------------
Re: My appeal to APCOA, please take a look
DIR By: tincombe
Date: August 19, 2026, 8:47 am
---------------------------------------------------------
What's the 'jackpot'?
You have received a Notice to Keeper.
Post the notice pl.
You can put together a standard response which you simply lift
off the shelf as and when needed.
This is superfluous IMO, your first para. is sufficient. The
more you write, the more they think they've got to you.
If APCOA contends that I am nevertheless personally liable, it
must identify and establish the legal basis upon which that
liability arises. The mere fact that I am the registered keeper
does not establish that I was the driver, nor does it create
contractual liability for a charge incurred by the driver.
I do not admit to being the driver and I decline to identify the
driver. There is no general legal requirement for a registered
keeper to identify the driver in circumstances such as this, and
APCOA cannot circumvent the absence of POFA keeper liability
simply by inviting or pressuring the keeper to provide driver
details.
Nor can liability be transferred to the registered keeper merely
by an assertion of agency. If APCOA's case is that a contract
was breached, it must establish that the person it seeks to hold
liable was a party to that contract and incurred the alleged
liability. Keeper status alone is insufficient.
I therefore require APCOA either to cancel this Parking Charge
Notice or, if it rejects this appeal, to provide the appropriate
POPLA verification code so that the matter can be independently
determined.
For the avoidance of doubt, I am appealing solely as the
registered keeper. I do not identify the driver and I do not
accept any liability for this Parking Charge Notice.
Please also ensure that no further requests for driver
identification are treated as an admission of liability or as
evidence that the registered keeper was the driver.
I invite APCOA to cancel the Parking Charge Notice now rather
than incur the unnecessary costs of pursuing a charge for which
it has no basis in keeper liability.
As a practical matter, and to avoid unnecessary correspondence
and costs arising from future notices issued in respect of this
vehicle, I also invite APCOA to add this vehicle registration to
an appropriate whitelist or otherwise flag the vehicle against
my keeper details. I have made my position clear that, as
registered keeper, I do not accept liability for driver-only
charges where no statutory keeper liability applies. It would
therefore be disproportionate and wasteful for APCOA to
repeatedly issue and pursue charges against me in circumstances
where the same issue has already been explained.
Kindly confirm receipt of this email and provide confirmation
that the Parking Charge Notice has been cancelled. I would also
ask you to confirm that the vehicle registration has been added
to your whitelist, or otherwise flagged to prevent similar
notices being issued in future.
#Post#: 128247--------------------------------------------------
Re: My appeal to APCOA, please take a look
DIR By: TrabatDave
Date: August 19, 2026, 10:55 am
---------------------------------------------------------
--- Quote from: tincombe link ---
>
> What's the 'jackpot'?
>
> You have received a Notice to Keeper.
>
> Post the notice pl.
>
> You can put together a standard response which you simply lift
off the shelf as and when needed.
>
> This is superfluous IMO, your first para. is sufficient. The
more you write, the more they think they've got to you.
>
> If APCOA contends that I am nevertheless personally liable, it
must identify and establish the legal basis upon which that
liability arises. The mere fact that I am the registered keeper
does not establish that I was the driver, nor does it create
contractual liability for a charge incurred by the driver.
>
> I do not admit to being the driver and I decline to identify
the driver. There is no general legal requirement for a
registered keeper to identify the driver in circumstances such
as this, and APCOA cannot circumvent the absence of POFA keeper
liability simply by inviting or pressuring the keeper to provide
driver details.
>
> Nor can liability be transferred to the registered keeper
merely by an assertion of agency. If APCOA's case is that a
contract was breached, it must establish that the person it
seeks to hold liable was a party to that contract and incurred
the alleged liability. Keeper status alone is insufficient.
>
> I therefore require APCOA either to cancel this Parking Charge
Notice or, if it rejects this appeal, to provide the appropriate
POPLA verification code so that the matter can be independently
determined.
>
> For the avoidance of doubt, I am appealing solely as the
registered keeper. I do not identify the driver and I do not
accept any liability for this Parking Charge Notice.
>
> Please also ensure that no further requests for driver
identification are treated as an admission of liability or as
evidence that the registered keeper was the driver.
>
> I invite APCOA to cancel the Parking Charge Notice now rather
than incur the unnecessary costs of pursuing a charge for which
it has no basis in keeper liability.
>
> As a practical matter, and to avoid unnecessary correspondence
and costs arising from future notices issued in respect of this
vehicle, I also invite APCOA to add this vehicle registration to
an appropriate whitelist or otherwise flag the vehicle against
my keeper details. I have made my position clear that, as
registered keeper, I do not accept liability for driver-only
charges where no statutory keeper liability applies. It would
therefore be disproportionate and wasteful for APCOA to
repeatedly issue and pursue charges against me in circumstances
where the same issue has already been explained.
>
> Kindly confirm receipt of this email and provide confirmation
that the Parking Charge Notice has been cancelled. I would also
ask you to confirm that the vehicle registration has been added
to your whitelist, or otherwise flagged to prevent similar
notices being issued in future.
>
--- End Quote ---
It goes beyond a simple 'one-off' appeal. I'm attempting to
short-circuit their processes (as is apparent from my email) to
issue an INVOICE for each use of the drop-off zones; pushing the
envelope for want of a better term. As a family with a number of
vehicles - self, wife, two daughters, and a son, I am looking to
reduce my administrative burden by stopping the issue at source.
I'm not a commercial operator of vehicles; I have a family who
own vehicles and frequently have to take family members to
Heathrow; currently we have two very ill old relatives in
European countries and am not prepared to pay APCOA to drop my
kids off to visit their gran weekly. It's enough to pay £8 to
pick them up when I collect them from the car park - assuming
there's no hold-up in baggage reclaim. If there is a way to
mitigate their greed and make my life easier, I'll use it and
hopefully if my 'jackpot' (whitelisting/flagging) pays off, I'm
happy to share it. By suggesting this, I am suggesting they
don't waste their resources issuing invoices that will be
appealed. In addition I have asked HAL to provide some info
relating to their contract with APCOA to ensure that their
authority is not being exceeded. I don't want my reply to be
construed as combative as I do know that the Airports are by-law
land etc.
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