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       #Post#: 53995--------------------------------------------------
       MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: whydothistome
       Date: January 18, 2025, 6:25 pm
       ---------------------------------------------------------
       Received this in the post as the registered keeper. Is this
       real? I assume MET isn't the Metropolitan police right?
       Google seems to show this exact situation happening alot with
       loads of people receiving it.
       May have anonymised a bit too much can give exacts if needed
       later :
       - Date of Contravention: Day Zero - Jan 2025
       - Date of Issue of this Notice: 3 days later - Jan 2025
       - Received in post: 15 days from date of contravention - Jan
       2025
       - Length of stay: <= 20 mins
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       #Post#: 54002--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: mickR
       Date: January 18, 2025, 6:36 pm
       ---------------------------------------------------------
       presume you (hopefully) haven't made contact with MET at all
       yet?
       #Post#: 54003--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: whydothistome
       Date: January 18, 2025, 6:39 pm
       ---------------------------------------------------------
       Not replied to them, only logged into the link to see the
       evidence they speak of which is just the same 2 pictures on the
       notice to keeper but in colour.
       #Post#: 54007--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: b789
       Date: January 18, 2025, 7:04 pm
       ---------------------------------------------------------
       No, MET is an unregulated private parking company.
       Easy one to defeat... as long as the unknown drivers identity is
       not revealed. There is no legal obligation on the known keeper
       (the recipient of the Notice to Keeper (NtK)) to reveal the
       identity of the unknown driver and no inference or assumptions
       can be made.
       The location is not relevant land for the purposes of PoFA which
       means that if the unknown driver is not identified, they cannot
       transfer liability for the charge from the unknown driver to the
       known keeper.
       Use the following as your appeal. No need to embellish or remove
       anything from it:
       --- Quote ---
       > I am the registered keeper. MET cannot hold a registered
       keeper liable for any alleged contravention on land that is
       under statutory control. As a matter of fact and law, MET 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 MET is not the
       Airport owner and your 'parking charge' is not and never
       attempts to be a penalty. It is created for MET’s own profit (as
       opposed to a bylaws penalty that goes to the public purse) and
       MET 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.
       MET have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       #Post#: 54041--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: whydothistome
       Date: January 19, 2025, 8:05 am
       ---------------------------------------------------------
       Thanks I've sent the appeal off. Says they'll respond within 28
       days. Will update here with their response.
       #Post#: 56447--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: whydothistome
       Date: February 3, 2025, 3:08 pm
       ---------------------------------------------------------
       So got this reply today asking for a receipt and saying it is
       private land.
       They seem to think I was the driver with the constant references
       to "your" when I wasn't.
       What's the next step just wait for their final decision?
  HTML https://i.imgur.com/jLqHeY5.png
       #Post#: 56485--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: b789
       Date: February 3, 2025, 6:07 pm
       ---------------------------------------------------------
       The morons at MET can’t comprehend that it doesn’t matter if the
       land is “private”. The fact that the “private” land sits within
       the airport boundary and is therefore under statutory control,
       whether they like it or not.
       Simply respond with the following:
       --- Quote ---
       > Dear MET Parking Services,
       >
       > Re: Parking Charge Notice Number [Insert PCN Number]
       > Site: (346) Southgate Park
       >
       > I refer to your recent letter, in which you attempt to claim
       that Southgate Park is "privately owned land" and somehow
       qualifies as "relevant land" under Schedule 4 of the Protection
       of Freedoms Act 2012 (PoFA). Your argument demonstrates a
       staggering level of intellectual malnourishment and complete
       ignorance of statutory control principles.
       >
       > To clarify for your benefit: Stansted Airport, including
       Southgate Park, is subject to statutory control under airport
       byelaws. As such, it is unequivocally not "relevant land" as
       defined in PoFA, regardless of whether the land is privately
       owned. You should already be aware of this fundamental
       limitation on your ability to hold the registered keeper liable.
       >
       > Further, your demand for evidence of purchases or Starbucks
       use is both irrelevant and baseless. The burden of proof lies
       with MET Parking Services to demonstrate:
       >
       > [indent]• That the terms of parking were clearly displayed and
       prominently visible;
       >
       > • That a contract was formed with the driver (not the
       registered keeper);
       >
       > • That any alleged breach occurred; and
       >
       > • That you are pursuing the correct party.[/indent]
       >
       > As you are fully aware, no presumption or inference can be
       made that the registered keeper was the driver. Any attempt to
       suggest otherwise is not only flawed but also undermines your
       credibility. I will not engage in speculation regarding the
       driver’s identity, as I am under no legal obligation to do so.
       >
       > You now have two options:
       >
       > [indent]1. Cancel the Parking Charge Notice immediately; or
       >
       > 2. Issue a POPLA code without delay.[/indent]
       >
       > Should you continue this ridiculous pursuit of an
       unenforceable charge, I will look forward to exposing your lack
       of knowledge at POPLA or in court.
       >
       > This is your final opportunity to resolve this matter
       sensibly. Kindly confirm cancellation of the Parking Charge
       Notice or provide a POPLA code within 14 days. Should I not
       receive a response, I will consider the matter closed.
       >
       > Yours faithfully,
       >
       > [Your Name]
       --- End Quote ---
       #Post#: 60114--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: whydothistome
       Date: March 1, 2025, 12:13 pm
       ---------------------------------------------------------
       Hello so received a rejection today with a POPLA code. I guess
       next step is to draft my popla appeal?
  HTML https://i.imgur.com/3w3dAvk.png
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       #Post#: 60118--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: b789
       Date: March 1, 2025, 12:27 pm
       ---------------------------------------------------------
       A recent POPLA appeal for the same location that was not
       successful was complained about and this is what the POPLA
       complaints assessor, Paul Garrity,  said in response to the
       complaint:
       --- Quote ---
       > In this instance, you are correct in stating that airport land
       is not relevant land and as such, POFA does not apply and I
       agree that the assessor is incorrect in considering POFA during
       this assessment.
       >
       > The Airports Act1986 confirms that Stansted Airport is an
       Airport and Highways Authority and this site falls under
       statutory control and as such, MET Parking can only pursue the
       driver and it cannot use POFA to transfer liability to you as
       the registered keeper.
       >
       > I note in your initial appeal to POPLA you state: “….This is
       insufficient to comply with the BPA Code of Practice and not
       enough to hold me liable in law to pay MET (not that a keeper
       can be liable anyway on non-relevant land and MET cannot enforce
       byelaws themselves)…”.
       >
       > Therefore, while you did not elaborate this in your appeal,
       you did provide more detail at the comments stage and as such,
       the assessor is wrong to state you raised new grounds. It is
       clear on reviewing your case and comments this is an expansion
       on your initial grounds of appeal and therefore, the assessor
       should have addressed this within the decision.
       >
       > Having reviewed your case, while the assessor has misapplied
       POFA in this instance, it is clear that the assessor has
       considered all of the evidence provided.
       >
       > In order to improve the quality of future appeal decisions, I
       will, of course uphold your complaint and provide the relevant
       feedback to the assessor. However, as all of the evidence
       provided has been considered, no procedural error has occurred
       and therefore, the outcome will not change.
       --- End Quote ---
       So, you can see that some POPLA assessors are utter feckwits and
       don't do their job properly. However, you will also note that
       even though the lead assessor agrees that the decision was
       wrong, they do not change those decisions. What more proof do
       you require that they are not fit for purpose.
       Anyway, have a search through the forum as there are already
       some POPLA appeals for this location that can be used. Before
       you send anything, show us here and we can check for any errors
       or omissions.
       Also, we can use that official response from POPLA in a formal
       complaint to MET who are breaching the PPSCoP by stating PoFA
       liability in their NtK when they are clearly not allowed to do
       so and they will be required to explain this as they are in
       breach of the KADOE contract and are using Keeper DVLA data
       unlawfully.
       #Post#: 60119--------------------------------------------------
       Re: MET Parking Services - Southgate Park - Stansted Airport
       Starbucks/McDonalds - Notice To Keeper
   DIR By: DWMB2
       Date: March 1, 2025, 12:31 pm
       ---------------------------------------------------------
       I'd be minded to refer to this comment from the lead adjudicator
       in the appeal.
       Do you have a case number to reference?
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