They have amended their PCN:
This is correct:
https://www.legislation.gov.uk/ukla/2003/3/section/4/enacted
(v)that, if the penalty charge is not paid before the end of the 28 day period, an increased charge may be payable;
However, they cannot take steps to enforce the increased charge until 28 days from the date of service:
https://www.legislation.gov.uk/ukla/2003/3/schedule/1/enacted
Charge certificates
5(1)Where a penalty charge notice is served on any person and the penalty charge to which it relates is not paid before the end of the relevant period, the enforcing authority may serve on that person a statement (in this paragraph referred to as a “charge certificate”) to the effect that the penalty charge in question is increased by 50 per cent.
(2)The relevant period, in relation to a penalty charge notice is the period of 28 days beginning—
(a)where no representations are made under paragraph 1 above, with the date on which the penalty charge notice is served;
(b)where such representations are made and a notice of rejection is served by the enforcing authority and no appeal against the notice of rejection is made with the date on which the period within which an appeal could have been made expires; or
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I'll draft a collateral challenge tomorrow. Please prod me as I am super busy.
I make these formal representations against the PCN.
1. The alleged infraction is de minimis.
2 I make this collateral challenge regarding the validity of the PCN:
The council cannot "take steps to enforce recovery of the increased charge" until 28 days from the date of service of the PCN as provided at Para 5 ff. of
https://www.legislation.gov.uk/ukla/2003/3/schedule/1/enactedCharge certificates
5(1)Where a penalty charge notice is served on any person and the penalty charge to which it relates is not paid before the end of the relevant period, the enforcing authority may serve on that person a statement (in this paragraph referred to as a “charge certificate”) to the effect that the penalty charge in question is increased by 50 per cent.
(2)The relevant period, in relation to a penalty charge notice is the period of 28 days beginning—
(a)where no representations are made under paragraph 1 above, with the date on which the penalty charge notice is served;(b)where such representations are made and a notice of rejection is served by the enforcing authority and no appeal against the notice of rejection is made with the date on which the period within which an appeal could have been made expires; or
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BEFORE you do this please screenshot the representations page.