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The regulations:-

https://www.legislation.gov.uk/uksi/2013/1783/made

(4) A charging scheme is to specify whether a penalty charge referred to in paragraph (1) or (2) is payable in addition to the road user charge or instead of such charge.

My bold.

Were this not the case I could take a non compliant lorry, get a £120 penalty and pay it at £60 rather than paying the £100 caz charge.

So, for me anyway, the CAZ fee can be demanded with the penalty as set out in the charging order.

Now therefore the Council, in exercise of the powers conferred on it by Part III and Schedule
12 of the Transport Act 2000, Parts 2 and 6 of The Road User Charging Schemes (Penalty
Charges, Adjudication and Enforcement) (England) Regulations 2013, and all other powers
enabling it in that behalf, hereby makes the following Order

Unless it is a different piece of legislation that enables penalty charges.

Edit: just realised the same observation had already been made.

Your view is that any PCN issued which includes the underlying charge is unlawful. Presumably all Bristol CAZ charges (and Dart and Bath too).

If they want the charge paying they should ask for it seperately and provide a means to pay it - this doesn't appear to exist since the payment service only allows a few days either side.

That would be an odd state of affairs - but entirely plausible.

If the authority accepted representations they could then, presumably, issue a fresh PCN in the sum of the penalty only under regulation 9 (2).

Being fixated on Reg 7 doesn't make sense when all that says is the mandatory content.
Especially when Reg 4 specifically allows the authority to claim the charge as well as the penalty if they choose.

The mandatory content is the bits that must be on a PCN.
Unless specified it does not prohibit other bits being added, if it did you could probably damn each and every parking PCN as there will be bits that are not in the regs.

Added charges are a no no in most cases but these are sanctioned, they cannot be  unlawful.
They were deemed to be in Moran as they were levied despite him having paid them and didn't give him the option to pay the penalty alone.
Simply put, you can demand the charge but not if it has been paid.

It does make you wonder on what would happen should a lorry owner pay the penalty bun not the charge.
Likely Bristol would allocate the £60 to the charges, regard the penalty as unpaid and issue a CC for the 150% plus the outstanding charge.
I can see that being a right dog's breakfast                                                                                                               

So, basically, you disagree with this sentence in Caroline Sheppard's adjudication verdict : -
"There is no power in Regulation 7 for the PCN to require the road user charge to be paid in addition to the penalty charge."

I agree totally with the statement above.

But there is also nothing in Reg 7 to prohibit
And I do think it needs to be taken in context and when read as a whole, along with the Regulations and the Bristol CAZ Order.

.......
There doesn't need to be a prohibition: it's a statutory notice and to make a demand for money, there needs to be a positive statutory power. Otherwise councils could make up PCNs for sneezing and just say that there's no statute prohibiting them from doing so.

If there is nothing authorising the PCN to demand the outstanding toll, then a PCN that demands the outstanding toll is demanding an amount that exceeds the amount due by law.

If this is wrong, then any PCN for not paying in a pay and display bay could demand payment of the P&D fee on top of the penalty.

https://www.legislation.gov.uk/uksi/2013/1783/regulation/4/made
Reg 4(4)
Authorises the charging authority to claim the outstanding toll as well as the Penalty.

To compare road charging to a parking PCN is comparing apples to pears.
There is nothing within TMA 2004 or its regs that remotely allows an additional cost over and above the penalty. That was confirmed by the High Court years back.
There is within road charging.

We all know that an adjudication decision does not set precedent, yet one is being bandied about as gospel, pinning all on a single sentence and a single reg while ignoring the elephant in the room that within the case in question, the guy had paid, the authority were double charging.
And that they may not do.

Put in the challenge that it is a fee not allowed by all means.
The authority may drop the ball.
Take it to adjudication, an adjudicator may take the view that it cannot be on the PCN and that the authority should use other means to claim.

But we should be clear that it is not a silver bullet that cannot fail or point to alternative legislation to seek to justify.

@DancingDad I don't really disagree with anything you say, but it's another point to add to the 0870 ground.

I'm fine with adding it.
But we should be clear that it is not 100%.
After all, it is not our money we are risking and if an OP is to decide on whether or not to risk, we should be clear it is a gamble.
Sooner or later cases will go though adjudication and possibly HC and it will be clearer.

The 0870 is a different matter, you have been careful to work out which authorities are gaining from the charge and those where the charge is taken solely by the provider.
An important distinction, that there is a cost is not the issue, there is a cost in a postage stamp if someone chooses to pay by post. 

I assume that you had the 0870 number and the penalty plus toll in the challenge ?

It does seem as though they are very reluctant to see the penalty plus toll issue get in front of an adjudicator.

My memory might be playing tricks, but I recall a Bristol case where a £9 cheque was sent ro pay the toll and they cancelled.