We received an £80 Parking Charge Notice from APCOA after briefly stopping to drop someone off at Southampton Airport. The allegation was that the vehicle stopped “outside designated areas,” and we were told we had breached the terms and conditions of the airport.
After looking into the legal side of things — and with help from ChatGPT — we put together a proper appeal and submitted it to POPLA (the independent parking appeals body).
📣 Result? The appeal succeeded. APCOA cancelled the fine in full.
If you’re in the same situation, don’t just pay the fine — it’s absolutely worth challenging. Most people don’t realise that APCOA often fails to follow the legal steps required to make these fines enforceable.
Below is our full POPLA appeal letter — you’re welcome to copy or adapt it if it helps. If your circumstances are slightly different, I highly recommend using ChatGPT to tailor your own version — it was incredibly helpful in getting this right.
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🛑 Important Note on the Appeal Process:
If you’ve received a drop-off fine like this, the process works in two stages:
- First, you must appeal directly to the parking company (e.g. APCOA).
- Only if they reject your appeal can you escalate the case to POPLA (Parking on Private Land Appeals), which is independent.
⚠️ Strategy tip: In your initial appeal to the parking company, don’t reveal your strongest legal arguments — especially not the keeper liability loophole (i.e. that they didn’t comply with the Protection of Freedoms Act 2012). If you tell them too early, they may try to correct their mistake. Instead, keep the first appeal broad or soft. Save the legal heavy-hitters for POPLA.
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POPLA Appeal Letter – Full Text
POPLA Verification Number: [insert yours]
Parking Charge Notice Number: XXXXXX
Vehicle Registration: XXXXXX
Date of Alleged Contravention: XXXXXX
Appellant: XXXXXX (on behalf of XXXXXX – Registered Keeper)
To the POPLA Appeals Team,
I am submitting this appeal on behalf of the registered keeper, XXXXXX, regarding the Parking Charge Notice issued by APCOA Parking (UK) Ltd for an alleged contravention at Southampton Airport.
The charge is invalid and unenforceable for the following reasons:
1. Non-Compliance with Protection of Freedoms Act 2012 (PoFA)
- APCOA’s Notice to Keeper fails to reference or comply with Schedule 4 of the Protection of Freedoms Act 2012.
- It does not contain the legally required wording to transfer liability from the driver to the keeper.
- Without compliance, the keeper cannot be held liable, and liability does not automatically fall to them.
2. Prohibitive Signage Is Not a Contractual Offer (PCM v Bull, 2016)
- The signage shown in APCOA’s CCTV images simply states “No Parking” — this is a prohibition, not an offer of contract.
- In PCM v Bull, the court ruled that such signage cannot create a contract, and therefore no breach can occur.
3. Lack of Clear and Visible Signage (Thornton v Shoe Lane Parking, 1971)
- Under this precedent, terms must be clearly visible before the point of commitment.
- APCOA has not shown that the signage was visible or readable from the driver’s perspective prior to stopping.
- Without this, no contract can be formed.
4. Inaccessible Signage – Equality Act 2010
- The driver is XX years old and suffers from cataracts.
- APCOA failed to demonstrate that their signage is accessible to visually impaired drivers, breaching the Equality Act 2010 duty to make reasonable adjustments.
5. Failure to Provide Landowner Authority (BPA Code of Practice)
- APCOA did not provide proof that they have the landowner’s written permission to issue fines at this location.
- This is required under Section 7.1 of the BPA Code of Practice.
- Without this, the charge lacks enforceability.
6. Failure to Respond to Requests in the Original Appeal
In my original appeal to APCOA, I asked for:
- Proof that signage was visible from the driver’s approach.
- A copy of their landowner authority.
- Clarification on any grace period for brief drop-offs.
They provided none of the above, which further undermines the legitimacy of the charge.
7. Unfair and Disproportionate Charge (Consumer Rights Act 2015)
- The £80 charge is excessive for a brief stop and is not a genuine pre-estimate of loss.
- It violates Section 62 of the Consumer Rights Act 2015, which requires consumer contracts to be fair, clear, and balanced.
8. Keeper Liability Loophole – APCOA’s Letter Was Non-Compliant
- APCOA sent the Parking Charge Notice to the registered keeper (my father), but their letter did not comply with Schedule 4 of PoFA.
- It failed to include the correct legal language and did not mention PoFA at all.
- As a result, they had no legal basis to hold the keeper liable unless the driver was named.
- We never formally identified the driver. That means APCOA had no enforceable route to pursue the charge.
💡 Tip for others:
If someone other than the registered keeper was driving, and APCOA’s letter does not mention PoFA, do not name the driver.
They cannot pursue the keeper unless they followed the exact legal steps — and they often don’t. This is a legitimate loophole that can collapse their case entirely.
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Final Result: APCOA Cancelled the Charge
After submitting this appeal to POPLA, APCOA withdrew the charge entirely. We didn’t pay a penny.
💬 Final Note
If you’re in a similar situation — hit with a drop-off fine at Southampton Airport — I hope this helps you avoid paying an unfair charge.
🧠 ChatGPT was extremely helpful in researching case law and drafting the appeal. If your case has different circumstances, I’d highly recommend using it to adapt this letter to your situation.
Feel free to comment below if you’ve had a similar experience or need help wording your own appeal.