The law is that one can pay the discount at any time within the discount period despite submitting a representation. So if Havering are saying on their documents that if you submit reps you are not entitled to the discount they are wrong in law, and need to be dragged over the coals on this.
I don't know is this answers your comment - from 22 July Havering Council removed the opportunity of the 50% discount if appeal overturned
Not really. A case in Nottingham some years ago went to the adjudicators because the recipient sent in an appeal, then attempted to pay the discount before the discount period expired, and was prevented from doing so on the payment entry screen. The appeal at TPT was won, and the adjudicator stated that there was the absolute right in law to pay the discount within the discount period irrespective of any representations having been submitted. Havering cannot override laws approved by Parliament.
So what do the Havering PCNs say ?