Appeal IMO.
Yet again a complete failure to advise the owner of their rights to appeal:
3Where any representations are made under paragraph 1 above but the enforcing authority do not accept that a ground has been established, the notice served under sub-paragraph (7) of the said paragraph 1 (in this Schedule referred to as “the notice of rejection”) must—
(a)state that a charge certificate may be served under paragraph 5 below unless before the end of the period of 28 days beginning with the date of service of the notice of rejection—
(i)the penalty charge is paid; or
(ii)the person on whom the notice is served appeals to a traffic adjudicator against the penalty charge; and
(b)describe in general terms the form and manner in which such an appeal must be made,
and may contain such other information as the enforcing authority consider appropriate.
Misstated twice and owner's right to apply to adjudicator to register an appeal beyond the regulatory period has been omitted in its entirety.
And misstated their power to serve a Charge Certificate.