Free Traffic Legal Advice

The PCN is misleading in the section "How to challenge".

It states in the 3rd paragraph: -

"If challenges against the PCN are received at the specified address 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 at the time specified in the NTO"

The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 state, (in Chapter 1)

Information to be included in regulation 9 penalty charge notices and enforcement notices
Information about right to make representations or appeal to be included in regulation 9 penalty charge notices and enforcement notices
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 have marked in bold the relevant item of mandatory information. You can see that Gloucester, for reasons only known to themselves, have cast aside this sentence and put in their own which has a different meaning. They refer to "further representations" thus implying that if you have already submitted a representation, (your informal challenge) and are happy with it and have no more things to add, that there is no need to submit any representations against the Notice to Owner.  This is highly misleading, because it is essential that a Notice to Owner is either paid or representations made; doing nothing is not an option.

For me, this is a procedural impropriety in that the information mandated to be included has not been included in the PCN.

I didn't make the point before, so I will now.
My last post outlined what I think is a procedural impropriety in the PCN content. It is important to bear in mind that councils never accept this, as it obviously reflects on their own management, so will reject the argument, thus forcing you to stand your ground and take them to adjudication.
The inadequate signage argument suggested by CP8759 directly challenges their signing practices. Of ocourse they will reply with what I call a Fob-Off letter. However, we're not at that stage yet !

The signing is acceptable IMO, your parking place, and it is separate, is no more than 5 cars' length.

You overstayed because you didn't know the significance of the parking place road markings therefore did not consult the sign at all. Yes? As we know from pepipoo, the changes were introduced around July, so if you parked after this then either you've been very fortunate or the council did not enforce until ***. This in itself could be a line because normal practice would be to issue warning notices for a period. But you're implying that none was served on this car.

Also, are you the registered keeper because it's pretty certain GCC would reject informal reps and therefore the real battle would be fought at the Notice to Owner and subsequent stages.

I am not the registered keeper. The vehicle is leased.

What are the terms of your lease agreement re settling PCNs?