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       #Post#: 92375--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: willowweb
       Date: October 1, 2025, 10:36 am
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       I thought it was included.  Please see here;
  HTML https://ibb.co/zhVLnTq2
       #Post#: 92376--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: DWMB2
       Date: October 1, 2025, 10:42 am
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       But where is that within the evidence pack? And where is the
       'link' they refer to?
       #Post#: 92378--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: willowweb
       Date: October 1, 2025, 10:44 am
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       I have realised that the link does not show the full objection
       document .  I don't have Adobe and I can't download the full
       thing to save it.
       #Post#: 92381--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: willowweb
       Date: October 1, 2025, 10:47 am
       ---------------------------------------------------------
       I think the document is too large.  I just tried uploading the
       full doc but the last pages are not viewable.
       #Post#: 92385--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: willowweb
       Date: October 1, 2025, 10:59 am
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       The only way I could do it was to print off the rest of the
       document and scan it.  Please see here:
  HTML https://ibb.co/yBPxBd6k
       #Post#: 92391--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: DWMB2
       Date: October 1, 2025, 11:11 am
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       Link for reference:
  HTML https://assets.live.dxp.maginfrastructure.com/f/73114/x/df8f2e7b97/stn-injunction-stansted-airport-court-order.pdf?_gl=1*vi0z7d*_gc_au*NzgzOTEyMzEzLjE3NTkxNjMzNDE<br
       />
  HTML https://assets.live.dxp.maginfrastructure.com/f/73114/x/df8f2e7b97/stn-injunction-stansted-airport-court-order.pdf?_gl=1*vi0z7d*_gc_au*NzgzOTEyMzEzLjE3NTkxNjMzNDE
       I'm not convinced by their inference that the map in that court
       order is a map defining the boundaries for the application of
       byelaws. It identifies the land that is to be considered
       "Stansted Airport" for the purposes of that case, which would
       seem to be a different matter. It's hard to see how that map
       would amend or supercede any map that forms part of the byelaws.
       #Post#: 92407--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: InterCity125
       Date: October 1, 2025, 12:44 pm
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  HTML https://assets.publishing.service.gov.uk/media/64d0fc30e5491a00134b5946/Design___Access_Statement_-_checked.pdf
       Scroll to page 8 for existing site plan.
       #Post#: 92415--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: b789
       Date: October 1, 2025, 1:36 pm
       ---------------------------------------------------------
       Below is text you can paste into your POPLA “Comments on
       operator evidence” box. It keeps the original point intact, adds
       the operator-pack rebuttal, includes HTML links to each map
       source, and explains why there can be no keeper liability.
       --- Quote ---
       > Section E – Operator’s map and boundary claim
       >
       > The operator’s “boundary” plan in Section E is not an airport
       estate boundary at all. It is a red-line taken from a High Court
       interim protest injunction that defines where protest-control
       measures apply for a limited legal purpose and period. The Order
       itself defines “Stansted Airport” only as “the land shown…on
       Plan 2 to the Claim Form,” and it includes review and service
       provisions (e.g. notices at locations marked “X”) that underline
       its narrow, enforcement nature. See:
       >
       >
  HTML https://www.stanstedairport.com/injunction/
       >
       > This is not an operator boundary plan, does not purport to fix
       the airport’s statutory/operational extent, and is therefore
       irrelevant to the “relevant land” analysis under Schedule 4
       PoFA.
       >
       > By contrast, the appellant’s map is drawn from the airport
       operator’s own planning submission—the Stansted Terminal
       Extension Design & Access Statement (July 2023)—which describes
       the airport landholding and shows the site plan used by the
       operator and the planning authority to define the estate context
       (“the land within the airport’s boundaries is approximately 957
       hectares”). This is precisely the type of authoritative operator
       material POPLA should prefer when understanding the airport
       boundary as a whole. Source:
       >
       >
  HTML https://assets.publishing.service.gov.uk/media/64d0fc30e5491a00134b5946/Design___Access_Statement_-_checked.pdf<br
       />(page 8, ‘Site Plan’).
       >
       > Accordingly, POPLA should dismiss the injunction red-line as a
       litigation exhibit with a limited purpose and no bearing on the
       airport estate’s full extent, and instead rely on the operator’s
       own planning document for boundary context. On that basis—and as
       shown in the appellant’s evidence—Southgate Park sits within the
       airport estate notwithstanding any narrower area delineated for
       protest-injunction enforcement.
       >
       > Keeper liability (PoFA) cannot arise. Schedule 4 only applies
       on “relevant land”. Land subject to statutory control/byelaws
       (such as airport land within the operator’s boundary) is
       excluded from the definition of “relevant land”, so PoFA keeper
       liability is unavailable. The operator has not produced any
       operator or planning-authority boundary plan that displaces the
       airport operator’s own material; instead they rely on a
       protest-injunction map that is not a boundary instrument. POPLA
       should therefore find that this site is not “relevant land” and
       that the keeper cannot be held liable under Schedule 4 PoFA.
       >
       > For ease of reference:
       >
       > Operator’s injunction map –
  HTML https://www.stanstedairport.com/injunction/
       >
       > Appellant’s authoritative boundary/context map –
  HTML https://assets.publishing.service.gov.uk/media/64d0fc30e5491a00134b5946/Design___Access_Statement_-_checked.pdf
       >
       >
       --- End Quote ---
       #Post#: 92435--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: InterCity125
       Date: October 1, 2025, 3:28 pm
       ---------------------------------------------------------
       It seems most likely that the difference in maps is down to land
       ownership / control.
       If you examine the contract between the landowner and the
       parking company you'll see that the parking company's contract
       is with 'Tabacon Stansted 2 Limited' and not with 'Manchester
       Airport PLC' (who own the bulk of Stansted Airport) and
       therefore it would seem that there is more than one packet of
       land which is under statutory control at the airport.
       It therefore seems reasonable that 'Manchester Airport Ltd' only
       included the land under their control in their injunction
       attempt v Just Stop Oil - land deemed outside of their control
       was not therefore included in the 'injunction map' which of
       course is the map which the parking company desperately use in
       their communications etc.
       Lazy work from the parking company but we know that they are
       desperate people.
       #Post#: 92472--------------------------------------------------
       Re: MET Stansted PCN not sure which car park
   DIR By: willowweb
       Date: October 2, 2025, 3:03 am
       ---------------------------------------------------------
       Thank you, I have pasted the response you gave and will wait to
       hear....
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