My appeal:
Dear Sir or Madam,
I write to make formal representations against the two PCNs issued to my vehicle for Code 12 (parked in a residents’ bay without clearly displaying a valid permit).
I respectfully request that both PCNs be cancelled on the grounds of procedural impropriety, improper service, duplicate enforcement, and failure to act fairly and proportionately.
**1. Failure to Properly Serve the First PCN**
At the time the first PCN is stated to have been issued, I was present at the vehicle and observed CEO 870 inspecting it. When I approached him to ask about the situation, he refused to engage in any meaningful conversation and walked away. No PCN was affixed to the vehicle and none was handed to me.
Under Regulation 9 of the Civil Enforcement of Parking Contraventions (England) General Regulations 2007, a PCN must either be fixed to the vehicle or handed to the person appearing to be in charge. Neither occurred.
If the authority asserts that the PCN was issued at that time, I require strict proof of lawful service, including CEO notes, photographs, and any body-worn camera footage.
If the PCN was not properly served, it is invalid and unenforceable.
**2. Incorrect Recorded Time of Issue**
The first PCN is recorded as having been issued at the time of my interaction with CEO 870. However, no PCN was placed on the vehicle at that time, and the officer left the location.
If records indicate that the PCN was served at that moment, this would be factually incorrect and constitutes a serious procedural defect.
**3. Two PCNs for a Continuous Contravention**
There was no ticket visible on the vehicle on the first day. The following day, two PCNs appeared.
The vehicle had not been moved. This represents a single continuous contravention. Issuing multiple PCNs for the same continuous state of affairs is excessive and contrary to established enforcement principles.
I request confirmation of the observation times for both PCNs and justification for issuing multiple penalties.
**4. Failure to Act Fairly and Proportionately**
Had I been clearly informed that a contravention was being enforced, I could have immediately moved the vehicle to my private driveway.
Instead, the officer disengaged and left without clearly advising me that a PCN was being issued. While I understand officers are not obliged to provide warnings, enforcement authorities remain under a duty to act fairly and proportionately.
This was not deliberate non-compliance. My resident permit had expired inadvertently and has since been renewed.
**5. Access Issues with Parking Account**
I have also been unable to access my online parking account. I attempted to reset my password; however, even after doing so, the system does not allow me to log in. This has caused additional difficulty in managing my permit and reviewing the PCNs.
I request that this access issue be investigated and resolved as a matter of urgency.
**6. Formal Complaint**
I have submitted a formal complaint regarding the conduct of CEO 870. I was advised by CEO 391 to include these matters within my written representations.
Given the defective service, evidential concerns, duplicate enforcement, and the technical issues accessing my account, I respectfully request that both PCNs be cancelled.
Should the authority be minded to reject these representations, please treat this letter as a formal request for:
* Full CEO notes
* All photographic evidence
* Body-worn camera footage
* Evidence of lawful service of both PCNs
I look forward to your confirmation that these PCNs have been cancelled.
