Free Traffic Legal Advice

If you're moving to Canada, I think you can safely ignore them because they cannot enforce in Canada

What vehicle? CAZ and ULEZ should be the same. Have you put on or removed a cherished plate recently?

It’s a 2002 Toyota Yaris Verso petrol that I bought as part of the scrappage scheme to become exempt from ULEZ (and is definitely ULEZ exempt in the TFL database)

From my understanding exemption is generally based on Euro 4 standard, but that didn’t exist before 2006, but they manually whitelist some older vehicles in their database.

My V5C lists emissions that seem to be slightly higher than the euro 4 standard: CO 1.02, HC 0.12, NOx 0.09

The important value being NOx, the euro 4 standard being 0.08 I think? So on that basis it should not even be ulez compliant?

Very confusing, and maybe at least a reasonable basis for appeal?

What answer do you get with this:

Pl post the PCN.

When will you be moving to Canada and for how long?

Then IMO you should include with your reps against the PCN the following:

The authority should note that you will be moving to Canada on *** for an indeterminate period. All correspondence initiated after ** May* to the following address:

Your name
*****
CANADA

They would be obliged to comply with this instruction which would be enough to put them off IMO if accompanied by reps which focus on your account i.e. being clear for ULEZ. If they did not, then IMO this would be improper.

* - this date should count back two working days for service. For example, if you were to move on Mon. 18 May then the effective date would be Thur. 14th May(Sat and Sun are excluded in the calculation).

I’ve contacted Toyota’s homologation department to request a certificate of conformity. Fingers crossed that gets me what I need to convince them. It does have a wait time of 10-15 days though..

I guess I wait for that to come through before submitting any appeals?

No, you mustn't miss any deadline on the PCN or it's game over. Best to submit something and say that you will be sending the homologation certificate of conformity for your car, but it takes 10-15 days, so request the PCN is put on hold until you submit copies.

So I paid the £75 to get a Certificate of Conformity from Toyota. Unfortunately it just had the same details as my V5C, NOx emissions of just above the Euro 4 standard.

I’m planning on sending an appeal of something along the lines of the following. Would really appreciate any comments or suggestions before I send it off!

Dear Sir/Madam,

I am writing to formally appeal the above-listed Penalty Charge Notices (PCNs) issued for driving within the Bristol Clean Air Zone (CAZ). While I acknowledge that the vehicle was driven in the zone, I kindly ask the Council to consider the significant mitigating circumstances surrounding these contraventions and to exercise its discretion in this matter.

1. Honest Mistake and ULEZ Exemption Discrepancy
My vehicle is a 2002 Toyota Yaris Verso Petrol. I was under the genuine and honest belief that my vehicle was exempt from the Bristol CAZ because it is officially recognised as compliant and exempt from charges in the London Ultra Low Emission Zone (ULEZ). (I have attached proof of my vehicle’s ULEZ compliance for your reference). Because these schemes share similar environmental goals, I understandably assumed that a vehicle permitted freely in the London ULEZ would meet the national framework standards for Clean Air Zones. The discrepancy between the two schemes caused genuine confusion and led directly to this honest mistake.

2. Multiple PCNs Accrued Before First Notification
Because of the slowness of the system and the time it takes to process and post PCNs, I did not receive the very first notice until approximately a month after my first entry into the zone. During those weeks, I continued to drive in the zone completely unaware that I was committing a contravention or accruing charges.

3. Immediate Corrective Action Taken
As soon as the very first PCN landed on my doormat and I was alerted to my error, I took immediate corrective action. I immediately paid any daily CAZ fees that were still within the payable time window to prevent further fines, and I completely ceased driving my vehicle within the Bristol CAZ. Had I been notified by the Council immediately after my first entry, none of the subsequent contraventions would have occurred. I submit that these ~13 PCNs should be viewed as a single, ongoing misunderstanding rather than a deliberate flouting of the rules.

4. Disproportionate Penalties
The cumulative total being demanded for these PCNs is an extortionate amount of money that I simply cannot afford, and enforcing them will cause me severe financial hardship. I am respectfully asking for leniency, as penalising a driver with roughly a dozen fines for an honest mistake made before a single warning was received is highly punitive and disproportionate.

I acted in good faith at all times, and I rectified my behaviour the very day I was made aware of the issue. Therefore, I respectfully request that the Council exercises its discretion to cancel these PCNs.

Yours faithfully,