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#Post#: 105160--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 9, 2026, 3:02 am
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HTML https://www.ftla.uk/private-parking-tickets/notice-to-keeper-met-stansted-southgate-carpark/msg102996/#msg102996
My last post in this thread is the tabulated version of the
POPLA appeal - I know it would come in handy!
The interesting comments from the assessor are... "While the
parking operator has provided a Parking Enforcement Agreement
from Tabacon Stansted 2 Limited (Tabacon).
The agreement sets out that Met Parking is permitted to manage
parking on the land and that the land is relevant land for the
purpose of POFA 2012.
However, I don’t consider Tabacon’s unqualified statement that
the land is relevant land for the purposes of PoFA 2012 to hold
any significant weight in what a complex land boundary dispute."
#Post#: 105215--------------------------------------------------
Re: Stansted starbucks
DIR By: DWMB2
Date: January 9, 2026, 9:03 am
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[member=7649]Gooner063[/member] - you may want to refer to that
POPLA assessment in your case. POPLA decisions are not binding,
so the assessor in your case is not obliged to reach the same
decision, but there is little harm drawing their attention to
it. The relevant reference number is 3862825089.
#Post#: 105244--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 9, 2026, 11:16 am
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Framework for comments on MET Parking evidence at POPLA...
Keeper's response to operator evidence supplied by MET Parking
relating to PoFA compliance at Stansted Airport.
1. Many of the assertions made by MET Parking in their
submission are false and totally unsupported by any relevant
evidence.
2. The assertions which MET Parking make demonstrate that MET
Parking do not appear to understand how the designation of 'Land
under statutory control' actually works - this appears to be
deliberate behaviour on the part of MET Parking.
3. The plan submitted by the vehicle keeper is a plan obtained
from an official Government website relating to the proposed
expansion of Stansted Airport and was used in the planning
application dated 7th August 2023.
4. The assertion that this plan is 'outdated' and 'superseded'
(when land was sold in 2011) is therefore completely untrue and
demonstratable false.
5. By comparison, the parking operators plan is totally
irrelevant and their own narrative defeats the legal argument on
which they are seemingly reliant - the parking operator openly
admits that their submitted plan is one which was one used by
Manchester Airport PLC (Stansted's owners) when they sought an
injunction against Just-Stop-Oil on 3rd July 2024 - the plan
used by Manchester Airport PLC simply encompasses the land which
is under their control.
6. By MET Parking's own admission, Southgate Park is not owned
by Manchester Airport PLC but by some other independent entity
and as such Manchester Airport PLC did not include the packet of
land at Southgate Park in their court injunction application
since it was not their land.
7. The owner of the land is irrelevant when determining whether
that particular area of land is subject to statutory control -
it does not matter how many times a particular area of land
changes hand, that area of land remains under statutory control
regardless.
8. Areas of statutory control are determined by central
government and not airport owners or others who may own packets
of land within the designated statutory area.
9. By-laws apply to all areas of the designated statutory area
regardless.
10. The extract from the title deeds is of no relevance as the
sale has no bearing whatsoever on the designation of the land -
MET Parking are trying to project a narrative which suggests
that the sale of the land somehow removed it from the area of
land under statutory control.
11. Regardless of MET Parking's subjective waffle, it is clear
that the area of land which encompasses Southfield Park remains
firmly inside the area of land under statutory control.
12. The plan summitted by MET Parking never purports to
represent the entirety of the area of statutory control - MOST
CRITICAL - the plan is only ever used to show areas which
Manchester Airport PLC wished to include in their injunction.
13. The link included in their submission does not link to the
Stansted Airport website but instead links to court documents
associated with the Just-Stop-Oil injunction - this further
reinforces the fact that this map is not some kind of official
Stansted Airport plan.
14. That MET Parking are in clear breach of their own Code of
Conduct since their PCN's clearly state that they can pursue the
Keeper using PoFA - The Code of Conduct expressly prohibits
operators from either mentioning or implying that PoFA can be
used in locations where PoFA is not applicable.
15. That by breaching their Code of Conduct, MET Parking are
also in breach of their KADOE agreement with the DVLA since the
DVLA require operators to agree to follow the Code of Conduct.
16. That it appears that MET Parking are deliberately avoiding
the acknowledgement of the true designation of the land they are
controlling as this would have a significant impact on revenues
- as a business, MET Parking are expected to operate
professionally - how can a parking operator operate in a
professional manner if it is incapable of correctly ascertaining
the nature of the land on which they wish to establish
enforcement activities - in order to correctly issue compliant
PCNs, the operator must first establish the true nature of the
land on which it is operating, MET Parking have clearly failed
to do this.
17. I would further draw your attention to the outcome of POPLA
case 3862825089 which appears to hinge on similar factors.
#Post#: 105295--------------------------------------------------
Re: Stansted starbucks
DIR By: Gooner063
Date: January 10, 2026, 12:46 am
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Good Morning Guys
Sorry for the late reply, work got in the way.
Thanks for spending your valuable time on this for me.
I have uploaded what I think may be useful rather than all of
what MET replied to the POPLA appeal.
I have tried to put it into some semblance of order, but
computer skills are not my forte, so bear with me.
HTML https://freeimage.host/i/fk09Il1
HTML https://freeimage.host/i/fk0FIlp
HTML https://freeimage.host/i/fk0f4Va
HTML https://freeimage.host/i/fk0q1qJ
HTML https://freeimage.host/i/fk0BNyB
HTML https://freeimage.host/i/fk0CyWF
HTML https://freeimage.host/i/fk0nm74
HTML https://freeimage.host/i/fk0xAtS
HTML https://freeimage.host/i/fk0zGgs
HTML https://freeimage.host/i/fk0IW6F
Thanks in advance for some guidance and patience
G
#Post#: 105299--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 10, 2026, 4:11 am
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Everything uploaded fine.
Everything is pretty much as expected and MET Parking continue
to struggle with the fact that the ownership of the land has no
bearing on the fact that the land is still under statutory
control.
I can tweak the Keeper comments to cover slight changes in their
re-hashed arguments plus the extra email which suggests that
statutory control is only limited to areas owned by the airport
- this email;
HTML https://freeimage.host/i/starbucks-4.fk0FIlp
The contents of this email are incorrect - land under statutory
is by definition land covered by by-laws - that is the
definition of statutory control and ownership of the land is
irrelevant.
#Post#: 105342--------------------------------------------------
Re: Stansted starbucks
DIR By: Gooner063
Date: January 10, 2026, 1:59 pm
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Thanks for looking at this intercity and i appreciate your time
and the other other guys.
If you could provide a defense for popla that would be
outstanding, i have a few days left
#Post#: 105358--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 11, 2026, 2:33 am
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No problem. Give me 24 / 48 hours.
#Post#: 105463--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 12, 2026, 2:15 am
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Keeper's response to operator evidence supplied by MET Parking
relating to PoFA compliance at Stansted Airport.
1. Many of the assertions made by MET Parking in their
submission are false.
2. The assertions which MET Parking make demonstrate that MET
Parking do not appear to understand how the designation of 'Land
under statutory control' actually works - this appears to be
deliberate behaviour on the part of MET Parking - as a result,
the contents of their evidence pack is utterly shambolic.
3. The plan submitted by the vehicle keeper is a plan obtained
from an official Government website relating to the proposed
terminal expansion at Stansted Airport and was used in the
planning application dated 7th August 2023.
4. The assertion that this plan is 'outdated' and 'superseded'
(when a packet of land was sold in 2011) is therefore completely
untrue and demonstrably false.
5. Furthermore, and by comparison, the parking operators
provided airport plan (titled 'Stansted Airport - Plan 2) is
totally irrelevant and their own narrative inadvertently defeats
the legal argument on which they are seemingly reliant.
6. The parking operator openly admits that their submitted
airport plan is one which was one used by Manchester Airport PLC
(Stansted's operators) when they sought a High Court injunction
(to protect a number of their airports) against 'Just-Stop-Oil'
on 3rd July 2024 - the parking operators airport plan is a
rudimentary 'copy and paste' taken directly from the High Court
injunction application documents filed by Manchester Airport PLC
on that date.
7. The areas inside the 'red line' (on the parking operator's
airport plan / injunction plan) used by Manchester Airport PLC
(in their injunction application) simply encompasses the land
which is either owned by them and/or under their control - basic
legal protocol means that Manchester Airport PLC are not able to
apply for an injunction which covers land which is not under
their control.
7a. Section 8 of the Manchester Airport PLC 'Skeleton Argument'
document in their injunction application states the following;
"A summary of the details of Claimant's title to the Airports is
set out at Annex A to this skeleton
argument. There, too, are the details explaining which Claimants
relate to which Airports.
In short, the land within the “red line” is private land to
which Claimant's have freehold or
leasehold title, save for certain exceptions, explained next:"
7b. Section 9 of the Manchester Airports PLC 'Skeleton Argument'
document in their injunction application then states the
following;
"Third Party Areas: First, there are certain areas within each
airport over which third
parties have interests which, in point of law, have the effect
that Claimant's do not have an
immediate right to possession or occupation in relation to those
areas, (or none that they
seek to assert in these proceedings). These are referred to as
the “Third Party Areas”.
For the most part, the Third Party Areas are only accessible by
members of the public if
they first use areas to which Claimant's are entitled to
possession, occupation and control by
virtue of their unencumbered proprietary interests."
The Skeleton Argument;
HTML https://assets.live.dxp.maginfrastructure.com/f/73114/x/a229707c4a/mag_injuntions_airports-skeleton_v1.pdf?
7c. It is clear from the statements in S8 and S9 that it is
accepted that "there are certain areas within each airport"
which are not controlled by Manchester Airport PLC and as such
these areas are not included inside the 'red line' on the
airport injunction plan.
7d. Therefore, it stands to reason that, there must be areas
outside the 'red line' that are areas still 'within the airport
area' - otherwise there would be no need for that specifically
stated exclusion.
8. The injunction application specifically mentions this 'point
of law' - MOST CRITICAL - it determines that 'thirds party
areas' within the airport area are not included in the
injunction application - this clearly explains the many
differences between the MET Parking provided airport plan and
the official Government plan which sets out the entire airport
area which is under statutory control - those differences being
areas which are owned by parties other than Manchester Airport
PLC and thus not included in the injunction application.
9. Furthermore, by MET Parking's own admission, Southgate Park
is not owned by Manchester Airport PLC but by some other
independent entity (their client) and as such Manchester Airport
PLC did not include the packet of land at Southgate Park in
their High Court injunction application since it was a 'third
party area' and therefore not land under their control even
though it sits inside the statutory airport area.
10. The owner of the land is irrelevant when determining whether
that particular area of land is subject to 'statutory control' -
Indeed, it does not matter how many times a particular area of
land changes hands, that area of land remains under statutory
control regardless of property sales.
11. Areas of statutory control are determined by central
government (Department of Transport) and not airport operators
or others who may own packets of land within the designated
statutory airport area. (Reference 'The Airports Act (1986)' for
more details on this)
12. Furthermore, byelaws apply to all areas of the designated
statutory airport area regardless - that is precisely what makes
it an area under statutory control: the presence of local
byelaws.
13. The email (in the parking operators evidence) from someone
at the Stansted Airport operator is legally illiterate - The
'Coffee Date email' contains a statement which is obviously
incorrect - the suggestion that bylaws only apply to areas under
their direct control - bylaws actually apply to all areas within
the area of statutory control - once again, that is exactly what
defines it as an area under statutory control - obviously, you
cannot have an area within the area of statutory control which
is not under statutory control!
14. The assertion of the coffee date email is also a
contradiction of the evidence set out in the injunction
application - namely that it is legally accepted that there are
third party areas which are within 'the airport area' but not
under direct control of the airport operator.
15. That the presence of the coffee date email clearly
demonstrates the incompetence shown by MET Parking - MET Parking
have been enforcing this area for quite some period of time yet
they are still fumbling in the dark with regard to the nature of
the land designation - MET Parking could quite easily resolve
this matter with some simple local authority enquires but they
elect not to - there is a requirement to do this BEFORE
enforcement can even start.
16. That each episode of apparent incompetence by the parking
operator ALWAYS ends up favouring the parking operator - this is
not by accident but by design - the operator is keen to continue
the use of PCN's which state PoFA keeper liability when they
must know that there is no keeper liability at that site.
17. The extract(s) from the title deeds etc are of absolutely no
relevance as the sale of the land has no bearing whatsoever on
the designation of the land - MET Parking are trying to project
a narrative which suggests that the sale of the land somehow
removed it from the area of land under statutory control - this
is demonstrably false.
18. Regardless of MET Parking's subjective waffle, it is clear
that the area of land which encompasses Southfield Park remains
firmly inside the area of land under statutory control set out
by the Secretary of State for Transport and this area is covered
by 'The Stansted Airport - London Byelaws (1996)'.
19. Somewhat bizarrely, the plan summitted by MET Parking never
actually purports to represent the entirety of the area of
statutory control - MOST CRITICAL - the plan is only ever used
to show areas which Manchester Airport PLC wished to include in
their injunction - MET Parking are deliberately using this
particular plan to hoodwink individuals into believing that they
can use PoFA to pursue keeper liability at a location within the
Stansted London Area of Statutory Control.
20. The link included in their submission does not link to the
Stansted Airport website but instead links to court documents
associated with the Just-Stop-Oil injunction - this further
reinforces the fact that this map is not some kind of official
Stansted Airport plan and, when examined, the other
documentation contained within that weblink clearly confirms
that fact.
21. That MET Parking are in clear breach of their own Code of
Conduct since their PCN's clearly state that they can pursue the
Keeper using PoFA - The Code of Conduct EXPRESSLY PROHIBITS
operators from either mentioning or implying that PoFA can be
used in locations where PoFA is not applicable - Southgate Park
is within the Stansted Airport Area of Statutory Control and yet
MET Parking are still issuing PCN's which specifically mention
Keeper liability under PoFA.
22. That, by breaching their Code of Conduct, MET Parking are
also in breach of their KADOE agreement with the DVLA since the
DVLA require operators to agree to adhere to the Code of Conduct
before accessing keeper records.
23. That it appears that MET Parking are deliberately avoiding
the acknowledgement of the true designation of the land they are
controlling as this would have a significant impact on revenues
- as a business, MET Parking are expected to operate
professionally - how can a parking operator operate in a
professional manner if it is incapable of correctly ascertaining
the nature of the land on which they wish to establish
enforcement activities? - In order to correctly issue compliant
PCNs, the operator must first establish the true nature of the
land on which it is operating, MET Parking have clearly failed
to do this.
24. I would further draw your attention to the outcome of POPLA
case 3862825089 which appears to hinge on similar factors.
#Post#: 105466--------------------------------------------------
Re: Stansted starbucks
DIR By: DWMB2
Date: January 12, 2026, 3:30 am
---------------------------------------------------------
The above looks good to me - POPLA used to have a 10,000
character limit for responses, which the above may exceed. If it
does, removing paragraph 25, and changing point one to "Many of
the assertions made by MET Parking in their submission are
false" would get this under 10,000 without losing any meaning.
#Post#: 105554--------------------------------------------------
Re: Stansted starbucks
DIR By: InterCity125
Date: January 12, 2026, 11:30 am
---------------------------------------------------------
--- Quote from: DWMB2 link ---
>
> The above looks good to me - POPLA used to have a 10,000
character limit for responses, which the above may exceed. If it
does, removing paragraph 25, and changing point one to "Many of
the assertions made by MET Parking in their submission are
false" would get this under 10,000 without losing any meaning.
>
--- End Quote ---
Good spot.
I have now updated the keeper response document using your
suggestions.
I believe that I have included evidence not previously raised in
appeals at Southgate Park.
It will be interesting to see how this one goes.
The operator may well pull out but let's hope that POPLA have to
examine this.
Hopefully the OP will pick this up in time to add to the POPLA
appeal.
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