As your only alternative is to pay then you may as well appeal.
NOR deemed served 12 Jan - pl forget about 13th - therefore you must register no later than 8 Feb.
I think your only grounds are Procedural Impropriety:
1. I have been consistent throughout the enforcement process in my belief that cars have parked in exactly the same location as here for a long period but without being issued with PCNs and that by extension I had a legitimate expectation that such parking was not penalised. Indeed I have parked there before without issue. I accept that on normal roads parking by a dropped footway should be enforced. However, I submit that there is no way in which this area could be considered as a 'normal' road. GSV shows the unorthodox method apparently adopted by the council to stop up this road which gives the whole area the appearance of a dump and not a road. Had the authority responded robustly and evidentially to this assertion in my informal representations then I would have accepted my mistake, paid and moved on. But they did not.
All they have said at both the informal and formal stages is that they have reviewed the PCN and concluded that it was issued correctly. I submit that this fundamentally misunderstands their duty which is not simply to decide whether the PCN was issued correctly, which can only turn on what was known to the CEO at the time, but to consider my representations.
I respectfully suggest that they have not met this duty.
2. At the time, I believed that although the authority's response to my informal representations was defective, I would receive proper and more detailed condsideration at the formal stage. Unfortunately, I did not, neither was the discount re-offered. I therefore felt compelled to appeal and look in further detail at the NOR. In this respect, I submit that the NOR fails to state that an appeal may be submitted and registered by the adjudicator later than the 28-day period stated provided that reasons for lateness are included. The NOR gives a single deadline of 'no later than' which, given the reportedly chaotic state of postal services in some areas, could have a significant effect upon an owner. As this requirement is specified in the 2022 regulations, I submit that it doesn't lie with the authority to choose those parts it will include in NORs and those that it will not. I would add that this defect is compounded by their use of revoked regulatory provisions regarding 'Service' i.e. 2007 Regulations.
Just some thoughts.
