"No only but also"
The adjudication was by the Chief Adjudicator of the Traffic Penalty Tribunal, no less. In addition to the decision, she stated this: -
"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. Nor is there a power for the charging authority to refuse to
allocate a payment made for a crossing to that crossing, and hold it, possibly indefinitely, for
future use."
Not that there are two sentences here, each one referring to powers of the enforcing authority. Note the use of the word"nor", which separates the two sentences. This means that the second sentence has no link to the first.
YOur PCN is therefore not compliant with Regulation 7 if Caroline Sheppard is correct, and as such is a procedural impropriety.