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@John U.K. just FYI, I had a look and when you make a representation line, the PCN is already known, as you start off by entering it and then making the rep. In that sense, it might not be necessary to include it in the letter (as they'll already know). And then when making reps against the ones that haven't been delivered by post, I can explicitly mention this.

OP, IMO you have 3 distinct PCN types, it's not one size fits all.

The first = did not receive reminder, unblemished record, pl exercise discretion;

2-13 = continuous contravention, where is the council's authority to issue multiple PCNs when other enforcement methods were available i.e. removing and should have been considered. Why weren't they? Contravention did not occur and Penalty exceeded etc;

14= penalty exceeded because a PCN should not have been issued, other methods should have been considered and implemented earlier; Procedural Impropriety as in you did not provide 'reps' information as required which also = reason for lateness. 

I'm not sure if there is a way to add collapsable sections here. For now, I've drafted the two appeals. One for the first PCN and the other that will be used for PCNs 2-13.

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Notice to Owner for PCN number ZN12128S1A

I am writing to make a representation about the Penalty Charge Notice (PCN) ZN12128S1A, issued to me on 07/05/2024 at 09:33.

I have been a resident of Haringey for over five years, and I have always ensured that my parking permit is kept up to date. The council's reminder emails have been invaluable in helping me renew my permit on time.

As a five-year resident with a consistent permit history, I've held three consecutive permits with Haringey Council since purchasing my car:

• May 2022 (1 Year)
• May 2023 (6 Months)
• October 2023 (6 Months)

As you can see from these dates, I have been very reliable and consistent in renewing my permit as soon as I receive the reminder. However, in this instance, I did not receive the reminder nor am I able to locate it. I also received no other follow-up emails, text messages, or letters.

I understand the council's limited resources, but I believe more could have been done to reach or communicate with me. I've learned that Hackney Council sends multiple reminders for permit renewals to their residents. I would hope Haringey Council could implement similar measures to mitigate the risk of a single communication not being received by residents.

Closing Request

Given my circumstances of being abroad, but also being a permanent resident who has demonstrated a reliable record of holding consistent permits and renewing them promptly, I hope the council will consider this representation with fairness and discretion.

My hope is that we can reach a fair resolution that takes into account my good permit history and the unique circumstances that led to this situation.

Thank you for your understanding and consideration.

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Notice to Owner for PCN number ___

I am writing to make a representation against the Notice to Owner (NTO) that has been issued to me for PCN ____. This also appeals 12 other PCNs: ZN12266976, ZN12353988, ZN12354086, ZN12354326, ZN12354417, ZN12354552, ZN12354734, ZN12355191, ZN12411612, ZN12411827, and ZN12413039, for which I am making representations separately.

Before explaining the details, I hope the council will consider being flexible and taking my history as a responsible resident into account, along with the unfortunate circumstances that have led to what I believe is an unreasonable and exceeded penalty.

Summary of Circumstances

As a Haringey resident for over five years now, I've held three parking permits (October 2023 - 6 Months, May 2023 - 6 Months, and May 2022 - 1 Year) and have always renewed them promptly.

From April 12th to July 12th, 2024, I was out of the country for work. Unfortunately, during that time, my permit expired on April 25th, and I don't recall getting the renewal reminder that the council usually sends.

Because of this, my car was without a valid permit for 61 days. This resulted in a continuous stream of parking tickets being issued while I was abroad, without me being aware of this in any way.

The council eventually removed my car on May 31st. On June 1st, my sister and a family friend recovered the car for me, paying the necessary fees for the ticket and the removal.

I understand my car was without a permit, but there isn’t much more I could have done here. I feel that potentially having to pay £1690 for being late on my permit renewal is too much. This is especially since I've demonstrated my reliability as a permanent resident with a good permit history and also these essentially all referring to the same continuous contravention.

The Vehicle Should Have Been Removed Sooner

My car remained in the same place throughout the period these PCNs were issued. Tickets were issued almost daily from 07/05/2024 to 30/05/2024 (Appendix 1.1), often just minutes after 24 hours had passed. For instance, PCNs ___ were issued at 08:20 on 22/05, 08:28 on 24/05, and 08:10 on 25/05.

All PCNs except one (ZN12411827) were for contravention code 12(i) at the same location on Cornwall Road, which are all appealing to what is essentially the same continuous contravention. While I understand the importance of parking enforcement, I believe this pattern of issuance and the excessive number of tickets are unfair and exorbitant.

Upon returning to the country, I emailed ___, Head of Highways and Parking, about this situation (Appendix 2.1). She responded:
"Normally after 3 PCNs the vehicle is flagged for removal... I can see from the PCN issued on 30th May that there were 5 PCNs attached to the vehicle and agree that the vehicle should have been removed sooner."

Given that my car was stationary in the same place during this entire period, I would have hoped the council would have carefully considered whether this was the most appropriate approach, especially when other enforcement methods were available.

I would have expected the council to:

• Use its power to remove the vehicle more quickly, or
• In case of no available space at the impound, communicate with the CEOs to exercise discretion in not issuing more tickets for the same contravention, or
• Explore other methods of getting in touch with me or removing the vehicle given these unique circumstances.

The excessive number of tickets issued before the car's removal seems unfair, particularly given Ms ___ acknowledgment that it should have been removed sooner.

I'm willing to provide any additional information that might assist the council in reviewing this aspect of my case. My hope is that we can reach a fair resolution that takes into account these unique circumstances.

@John U.K. Good point!

Going to add the following to the list:

"4. Consider the principle of 'continuous contravention'. Multiple penalties for the same ongoing issue wasn't the most fair approach and parking adjudicators often support this view."

@cp8759 - good shout! I'll get that submitted. That'll be handy as I prepare the rep for the 14th PCN (assuming the out-of-time req gets approved).

@John U.K. - thank you for that edit, I'll include that in and make it the first point.

I haven't prepared the draft for the 14th PCN yet, but will post as soon as I have something. I'm quite keen to get these initial reps finalised and out of the door first, given I have just over a week now before the deadline.

@inst1nct103 I think you need to add an out-of-time representation against the removal PCN, and you need to add some wording explaining that because no representations paperwork was provided at the pound you were not aware of your right to make representations, nor were you aware of the 28 day time limit, and you were only alerted to the fact that you could make representations against that PCN when you sought legal advice.

@John U.K. - I'll have to dig it out as I've already submitted it. It was essentially a paraphrase from @cp8759's comment here and was only a small box on the out of time form.

Here is my attempt to tidy up your draft:

(in the box)

I am making representation against the above NtO issued on (Date). For the reasons outlined in the attached representations, I wish this representation to be considered together with those against the NtOs for the following PCNs (insert list with dates).

(Insert as appropriate: I should point out that this PCN/this NtO was/were not received by me -see attached representations.)

(For the attached PDF)
Notice to Owner for PCN number ___

I am writing to make a representations against the following Notices to Owner (NTOs) that have been issued against my vehicle (insert Reg Mark)to me for the following PCNs (insert complete list of PCNs with dates of both PCN and of NtO for each and 'not received' against PCN/NtO as appropriate) The list as below at the moment is not complete. 

I ask for the reps against the above NtOs to be considered together.


Before explaining the details, I hope the council will consider being flexible and taking my history as a responsible resident into account, along with the unfortunate circumstances that have led to what I believe is an unreasonable and exceeded penalty.

As a Haringey resident for over five years now, I've held three parking permits (October 2023 - 6 Months, May 2023 - 6 Months, and May 2022 - 1 Year) and have always renewed them promptly.

From April 12th to July 12th, 2024, I was out of the country for work. Unfortunately, during that time, my permit expired on April 25th, and I don't recall getting did not get the renewal reminder that the council usually sends.

Because of this, my car was without a valid permit for 61 days. This resulted in a continuous stream of parking tickets being issued while I was abroad, without me being aware of this in any way.

The council eventually removed my car on May 31st. On June 1st, my sister and a family friend recovered the car for me, paying the necessary fees for the ticket and the removal.

I understand my car was without a permit, but there isn’t much more I could have done here. I feel that potentially having to pay £1690 for being late on my permit renewal is too much. This is especially since I've demonstrated my reliability as a permanent resident with a good permit history and also these essentially all referring to the same continuous contravention.

The Vehicle Should Have Been Removed Sooner - Continuous Contravention

My car remained in the same place throughout the period these PCNs were issued. Tickets were issued almost daily from 07/05/2024 to 30/05/2024 (Appendix 1.1), often just minutes after 24 hours had passed (don't even raise the subject of 24hours!). For instance, PCNs ___ were issued at 08:20 on 22/05, 08:28 on 24/05, and 08:10 on 25/05.

All PCNs except one (ZN12411827) (what was this one for??? Is thjis relevant to your reps?) were for contravention code 12(i) at the same location on Cornwall Road, which are all appealing to what is essentially the same continuous contravention. While I understand the importance of parking enforcement, I believe this pattern of issuance and the excessive number of tickets are unfair and exorbitant.

Upon returning to the country, I emailed (insert name) ___, Head of Highways and Parking, about this situation (Appendix 2.1)(where are the appendices in your draft?). She responded:
"Normally after 3 PCNs the vehicle is flagged for removal... I can see from the PCN issued on 30th May that there were 5 PCNs attached to the vehicle and agree that the vehicle should have been removed sooner."

Given that my car was stationary in the same place during this entire period, I would have hoped the council would have carefully considered whether this was the most appropriate approach, especially when other enforcement methods were available.

I would have expected the council to:

    1. Have considered the principle of 'continuous contravention'. It is a fundamental principle that one may not be punished more than once for the same offence. Therefore imposing 13 further penalties is not merely disproportionate, it was contrary to this fundamental principle as has been upheld by numerous adjudicators as the Council should be aware.
2. Use its power to remove the vehicle more quickly, or
    3. In case of no available space at the pound impound, communicate with the CEOs to exercise discretion in not issuing more tickets for the same contravention, or
    4. Explore other methods of getting in touch with me or removing the vehicle given these unique circumstances.


The excessive number of tickets issued before the car's removal seems unfair, particularly given Ms (name's) acknowledgment that it should have been removed sooner.

I'm willing to provide any additional information that might assist the council in reviewing this aspect of my case. My hope is that we can reach a fair resolution that takes into account these unique circumstances.