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       #Post#: 80904--------------------------------------------------
       Split: MET Parking Services ticket
   DIR By: JulianB
       Date: July 14, 2025, 6:36 am
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       The car of which I am the keeper has also been pictured at
       Stansted when McDonald's car park was full parking in what I
       thought was a legitimate overflow car park. I have appealed on
       the basis that the car park is not 'relevant land' under the
       PoFA 2012, Paragraph 3(1)(c) Schedule 4 nor section 2.31(c) of
       the BPA "Private Parking Sector Single Code of Practice" 27th
       June 2024 v1 because it lies within the boundary of Stansted
       Airport, and thus on land under 'statutory control'(i.e. land
       with bylaws).
       I have now found that Met Parking Services are deliberately
       playing 'fast and loose' with the POPLA appeal process and in
       the process bringing POPLA themselves and their process into
       disrepute - here's how:
       I have detailed my case for appeal (above) along with boundary
       maps of the Stansted perimeter (attached) within which lies
       'Southgate Park' on the two occasions open to under the MET
       Parking appeal process and on neither occasion have they EVER
       RESPONDED  DIRECTLY to the actual point I'm making, simply
       sending me boilerplate replies about signage and then refusing
       my appeal and referring me to POPLA.
       Once engaged with the POPLA process, where I only have seven
       days to respond (why? and how come MET get to dictate when the 7
       days starts by lodging their own evidence?), MET suddenly
       respond for the first time, in process terms 'at the last
       minute', to my original appeal basis with a complicated legal
       argument that I as a working layman need time to respond to.
       They're playing the system - waiting till the last possible
       minute to respond so I don't have time to put together a
       coherent counter argument. I don't have my own legal team and
       this isn't my day job, but it is a point of principle with me
       and I'll stick it out till the bitter end.
       I've been away for 5 days on holiday and not looking at my
       email, so here's what I've returned to with 6 hours to compose a
       response:
       MET Parking Services - EW
       Operator Case Summary
       In the appeal to POPLA Mr XXX raises the following grounds for
       appeal: • No keeper liability/non-relevant land As we have not
       been provided with the name and address of the driver of the
       vehicle, we are pursuing the registered keeper under Schedule 4
       of The Protection of Freedoms Act 2012. Please see our compliant
       Notice to Keeper in Section B of our evidence pack. Please also
       see a full explanation of why we may pursue the registered
       keeper under Schedule 4 of PoFA 2012 in Section C of our
       evidence pack. As stated in paragraph 3 of Schedule 4 of the
       Protection of Freedoms Act 2012, Relevant Land is any land that
       is not a) a highway maintainable at the public expense, b) a
       parking place which is provided or controlled by a traffic
       authority, or c) anyland excepting the aforementioned on which
       the parking of a vehicle is subject to statutory control.
       Paragraph 3 subsection 3 states that parking is subject to
       statutory control if any statutory provision imposes a liability
       in respect of the parking of vehicles on that land. The Stansted
       Airport byelaws do not impose a penalty for vehicles parking
       within Southgate Park. We have included in section E of this
       evidence pack excerpts from the Protection of Freedoms Act 2012
       and also the Airport byelaws. The full airport byelaws may be
       viewed online at:
  HTML https://assets.live.dxp.maginfrastructure.com/f/73114/x/46195467c9/stansted-byelaws.pdf<br
       />In light of this, the site is not excluded by the definitions
       laid out in paragraph 3 of Schedule 4 of the Protection of
       Freedoms Act 2012 and as such is considered Relevant Land. For
       the sake of clarity: Southgate Park is a pay-by-phone car park,
       by definition a place in which to park vehicles. The Stansted
       Airport byelaws do not impose a liability in respect of parking
       vehicles within the Southgate Park car park. In light of this we
       believe the site is not excluded by the definitions laid out in
       paragraph 3 of Schedule 4 of the Protection of Freedoms Act 2012
       and as such is considered Relevant Land. • Breach of KADOE As
       stated above, we have complied with all aspects of PoFA 2012 and
       therefore there has been no such breach. We believe we may
       continue to process Mr Brearley’s data under the following legal
       bases: &#61607; Contract – The processing is necessary for the
       parking contract that has been entered into when vehicles enter
       and remain in the location. &#61607; Legitimate Interests –
       Processing is required to protect and enable pursuit of
       legitimate interests in ensuring the car park is effectively
       managed, pursuing unpaid parking tariffs and charges due and
       promoting the safety and security of the location. We have not
       been contacted by the BPA in relation to this charge. Turning to
       the charge itself: In this instance, the driver had not
       registered the vehicle for the free parking period. As advised
       on the signs, only customers are entitled to the free parking
       period, and they must register their vehicle on arrival. The
       driver did not make payment for their stay as an alternative and
       as such the parking charge was issued. In line with F.3(g) of
       the Appeals Charter, we requested evidence of custom during the
       initial appeal process (as only customers are entitled to park
       for free). At no point has evidence of custom been provided and
       as such Mr Brearley was not entitled to the further discount
       when his appeal was rejected. PLEASE NOTE: regarding the further
       reduction of a charge under Annex F, the Sector Single Code of
       Practice specifically states that ‘in all cases the Appeals
       Charter would require the motorist to provide the evidence.’. As
       such, without the appellant providing supporting evidence then
       there is no requirement for an operator to offer the further
       reduction. We are confident that there are sufficient signs in
       place in this car park and that the signs are prominently
       displayed and clearly state the terms and conditions. In Section
       E of our evidence pack we have included images of the signs in
       place and a site plan of the location. We are confident that our
       signage complies with all relevant legislation and regulations.
       A motorist does not have to have read the terms and conditions
       of parking to enter into a parking contract, there is only the
       requirement that the parking operator affords them the
       opportunity to do so. As stated, we are confident that there is
       sufficient signage at the site in order to afford motorists the
       chance to read the terms and conditions that are in place. Upon
       entry to the site, it is the motorist’s obligation to seek out
       any terms and conditions that may be in place before choosing to
       park or remain on site. The terms and conditions of parking are
       clearly stated on the signs that are prominently displayed at
       the entrance to and around the car park. These include that the
       car park is for the use of Southgate Park customers only and
       that to receive the 60-minute maximum free stay for customers,
       drivers must enter their vehicle registration on arrival.
       Visitors may extend their stay up to 3 hours by using the pay by
       phone service. As the evidence we have provided in Section E of
       our evidence pack demonstrates, the vehicle remained in the car
       park without being registered for the free parking period and no
       payment was made as an alternative. It remains the driver’s
       responsibility to check the signs where they park and comply
       with the stated terms and conditions. Therefore, we believe that
       the charge notice was issued correctly, and the appeal should be
       refused.
       [/i][/color]
       [attachment deleted by admin]
       #Post#: 80924--------------------------------------------------
       Re: Split: MET Parking Services ticket
   DIR By: jfollows
       Date: July 14, 2025, 8:01 am
       ---------------------------------------------------------
       I’m not reading that wodge of text, sorry. Can you not format it
       more nicely?
       #Post#: 81365--------------------------------------------------
       Re: Split: MET Parking Services ticket
   DIR By: b789
       Date: July 16, 2025, 5:58 pm
       ---------------------------------------------------------
       Just do a search for other identical POPLA appeals here on the
       forum and use the response to the operators evidence from one of
       those.
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