Free Traffic Legal Advice

two things here -
1. Any reps submitted must say why the person parked there, and not in the usual place, (doctor at hospital etc)

2. The PCN is flawed and positively misleading in the penultimate paragraph on the rear of the PCN. They have worded it such that only if further representations are to be sent, they must be submitted against the PCN. This is in direct contradiction to the wording in the regulations. See3 here in chapter 1, Regulation 3(1)(c) :-
https://www.legislation.gov.uk/ukdsi/2022/9780348232752/part/2/chapter/1

The point of this clause is to warn a PCN recipient who may also be the owner, that even if informal reps are submitted against the NtO, the reps must be submitted again if a Notice to Owner is received. If no reps are submitted against the NtO because the owner thinks to himself that they have already been submitted, the matter will progress to the Charge Certificate stage, and the matter cannot be reverted because the NtO has been ignored.

@Incandescent, the PCN states:

..serve a NTO on the owner of the vehicle. The person on whom a NTO is served may then make a formal representation to the council against the PCN...
If representations against the PCN are received before the NTO is served they will be considered. However, once an NTO is served any further representations must be made in the form and manner and within the time specified in the NTO.

The regs specify that the meaning of the following must be included in a PCN:

3.—(1) A regulation 9 penalty charge notice must include the following information—

(a)that a person on whom a notice to owner is served may, in accordance with these Regulations, make representations to the enforcement authority against the penalty charge and, if those representations are rejected, appeal to an adjudicator;

(b)that if, before a notice to owner is served, representations against the penalty charge are received at such address as may be specified in the notice for the purpose those representations will be considered by the enforcement authority;

(c)that if a notice to owner is served despite the representations mentioned in sub-paragraph (b), representations against the penalty charge must be made to the enforcement authority in the form and manner and at the time specified in the notice to owner.

I cannot see any material difference between these two, what have I missed?

OP, hang fire on advising your friend pl. The 14-day period ends on 17th.

Given that the words themselves aren't necessary, but the meaning must be conveyed(albeit that to depart from the verbatim regs carries a risk) we'll have to disagree on this one.

As it's probable that this line would be rejected, I think the OP should wait to see whether other ideas are forthcoming.

On the contravention the 2 hours plus 10 mins grace were accounted for from the first observation so this seems solid.

There are two signs by the bay and although set back on the verge they look clear - did he think it was a free bay?

You can always ask for discretion - maybe there was something urgent - but the £25 discount is the lowest PCN amount anywhere in the UK so not the end of the world.

I don't know about the wording issue but it seems not worthwhile to save £25 to carry this on.