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IMO, the problem with this approach is that, although correct in law, it does not provide any reasoning.

The starting point is that the authority's employee, the CEO, has already issued a PCN in circumstances where the law does not allow.

But they did.

So, simply saying 'it's not correct' is unlikely to win the day at the NTO stage.

I suggest you provide reasons. These might cause them to think, challenge received wisdom and give proper consideration, but if not then at least you have a template for an appeal.

Thank you all for your input. I have prepared a draft for the formal representations to the NtO

RE: Penalty Charge Notice : LE31987878

I refer to the above PCN.

I made informal representation for this PCN stating that the Blue Badge with the clock was correctly displayed.

However, you rejected that via your letter dated 10th Jan 2025 with the following:
"You were issued a PCN for parking on the pavement beside a double yellow line...."

and further down in the letter it also states the following:
"The PCN was issued as you vehicle was parked on the pavement"

I am still of the opinion that the alleged contravention did not occur and base my challenge on the following legislation:
The Local Authorities' Traffic Orders (Exemptions for Disabled Persons) (England) Regulations 2000, reg 8

(2) An order to which this regulation applies shall include an exemption from the prohibition in accordance with whichever of paragraphs (3) and (4) is appropriate in favour of any vehicle displaying a disabled person’s badge in the relevant position.

Based on the above, the blue badge exemption applies to all areas controlled by yellow lines provided there is no loading restriction in place.
Which in this case you have confirmed in your letter dated 10th Jan 2025.

In as far as your statement "The PCN was issued as you vehicle was parked on the pavement" is concerned than the contravention code 01 is wrong.
The contravention code for parking on the pavement is 62. Having a blue badge however entitles me to park partially on the footpath as there was no suitable parking available at that time.

I hope the above would suffice in cancelling the PCN and I await confirmation of the same.


Thank you


Any suggestions on my draft

@ stamfordman

What I’m trying to say is that in their reply letter they have confirmed there there were no loading restrictions on the DYL

But you may be right needs a bit of tiding up or rephrasing.

I'll have a look at this tomorrow.

Thank You @stamfordman for your re-draft.

I have a quick question

The NtO is dated 12th Feb 2025 and I get 28 days to either pay or challenge so before 12th March.

Should I wait till around the 9th or 10th and then challenge or should I send it now?
Just trying to see if it makes a difference.