Airport Land Isn't "Relevant Land" — They Can't Pin the Driver's Charge on You as Keeper
Where the airport land you were charged on is covered by CONFIRMED airport byelaws that regulate the parking of vehicles there, that land is NOT "relevant land" under Schedule 4 of the Protection of Freedoms Act 2012 (para 1 defines the scope; para 3 excludes land on which parking is subject to statutory control, expressly including byelaws). The Schedule 4 keeper-liability route — which lets an operator make the registered keeper pay when the driver isn't named — only works on relevant land, so on byelaw-controlled airport land it never opens. Absent an independent basis to hold you liable, they must pursue the actual DRIVER, whom you are under no duty to name. IMPORTANT limits: (1) this removes ONLY the Schedule 4 keeper-transfer route — para 4(6) preserves any OTHER basis they might have to hold you liable, so it's a "you can't pin the driver's charge on the keeper" point, not an automatic cancellation; (2) it works only while you appeal as the registered keeper and never name the driver; (3) it is NOT automatic from the word "airport" — you need that airport's specific confirmed byelaws to cover the exact spot and regulate parking there (some approach roads are instead under road-traffic law, which can make them relevant land); (4) it is a Protection of Freedoms Act point and so applies in ENGLAND & WALES; and (5) assessors apply it inconsistently — treat it as a strong ground to be evidenced, not a guaranteed win.
Legal basis
Protection of Freedoms Act 2012, Schedule 4 — para 1 (scope: keeper/hirer liability on "relevant land"), para 3 (definition of "relevant land", excluding land on which parking is subject to statutory control, expressly including byelaws), paras 4-5 (the keeper-liability transfer, which arises only on relevant land), and para 4(6) (Schedule 4 does not affect any other remedy against the keeper). Airports Act 1986, s.63 (power to make confirmed airport byelaws that may regulate the parking of vehicles — for designated airports, and only where the byelaws actually cover the location). Contextual support: the Protection of Freedoms Act 2012 (Definition of Relevant Land) (Amendment) Order 2025 (SI 2025/1256) brought certain railway car parks (land subject to specified Railway Byelaws) within "relevant land" in England & Wales — illustrating that byelaw-controlled land otherwise sits outside it. POFA keeper liability applies in England & Wales.
How to identify this in your case
Applies (England & Wales) when the charge is on airport land covered by that airport's confirmed byelaws regulating parking, AND you are appealing as the registered keeper without naming the driver. Look for an airport landowner/location and a private operator (e.g. APCOA, NCP). NOT automatic from "airport": check the specific airport's byelaws cover the exact spot and regulate parking there — an approach road under road-traffic law may instead be relevant land. Does NOT help if the driver has been identified or is appealing in their own name; it removes only the Schedule 4 keeper-transfer route (para 4(6) preserves other remedies), not the charge's validity.
Sample appeal wording
Sample wording to adapt and send yourself — it may not fit your notice or the stage you are at.
The land where this charge was issued is covered by that airport's confirmed byelaws, made under section 63 of the Airports Act 1986, which regulate the parking of vehicles there. Under paragraph 3 of Schedule 4 to the Protection of Freedoms Act 2012, land on which the parking of vehicles is subject to statutory control — expressly including byelaws — is not "relevant land", and the keeper-liability provisions in paragraphs 4 and 5 apply only to relevant land. Schedule 4 therefore does not permit you to transfer the driver's liability to me merely because I am the registered keeper. If you contend that I am personally liable on another basis, please identify that basis and provide the supporting evidence; otherwise I ask you to cancel this charge.
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