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I've changed my mind. London Councils say for code 16:

Suffix ‘s’ only for use where bay is completely non-resident. In shared use bays where residents’ permits are valid, codes 12 and 19 should be used as appropriate.

It is a signed bay in a PPA though.

The PPA is not really relevant as it's a signed bay but I'm assuming both the PPA and signed bays permit resident parking. The sign just days Permit holders D.

It's an informal challenge at this stage.

I would add to the first point:

I remind you of the Department of Transport's Statutory guidance for local authorities in England on civil enforcement of parking contraventions, which state you "have a duty to act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably and with due regard to the public interest".

? It is NOT the wrong code just because it uses 's'. Your argument should accept that the 's' is correct, not claim it isn't.

I would also relegate the fact that you paid to a footnote because your actual argument is that even if you could prove you paid this is not a defence against the alleged contravention anyway!

OP, I would reword.

The contravention did not occur.

The evidence in this case is the PCN citing the grounds of '****' and giving code 16s. As the authority know, the suffix 's' is prescribed for use only for shared use bays. Indeed, the authority's own photos show a traffic sign which allows parking between the stated hours by either permit holders or on payment of the required tariff i.e. a shared use bay.

Given that parking is therefore permitted on display of a permit OR on payment of the tariff, then it cannot be the case that the contravention of '***' could apply in any circumstances to any motorist.

So:
The PCN acknowledges that the parking place was shared use by using the code suffix 's';
The authority's evidence shows a shared use traffic sign;

Therefore the authority cannot rationally assert that while its own evidence acknowledges the shared use nature of the parking place a contravention could have been committed based upon ONLY the fact that a permit was not displayed which means that the ONLY defence open to me in this regard would be to prove that I displayed the necessary permit.

Had the PCN used the correct grounds for this type of bay, that it to say 'failing to ******', then I would have made representations on the grounds that I actually paid and provided proof. But I do not need to deal with this as this is not the alleged contravention.

The contravention grounds and the CEO's actions cannot withstand scrutiny and therefore the PCN must be cancelled.

But you must draft as suits you.

@H C Andersen, Please see reworded draft using yours as a template, while it was difficult to reword as i struggled to word it any other way) draft, as you'd covered it as best possible.

Contravention did not occur -

The ground used in the PCN is 'Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid permit' alongside a contravention code '16s'.

Redbridge LA is aware suffix 's' is prescribed for use only for shared use bays, in this instance the LA photo evidence show a signage stating that you have to be a permit holder OR can park upon payment of the tariff i.e. a shared use bay.

Given that parking is therefore permitted on either one these two conditions, with one clearly being 'payment upon tarrif. then it cannot be the case that the contravention of 'Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid permit' could apply in any circumstances to any motorist - This would only be applicable in the case of a permit only bay.

Therefore this PCN cannot be valid and I request this is cancelled immediatly.

In addition to the above a valid ticket was purchased for the full duration of my stay.... etc (I've dropped this down as advised unless you further advise to leave it out in its entirity for this informal rep)

If this will suffice for now, I can send this to get it in tonight before the deadline, which then gives time to focus on formal appeal once they've rejected it.

A permit only bay is.....a permit only bay!

This isn't.

End of....but give them the longer version!

Submitted - Await their rejection - A miracile if they accept, but their track record says other wise

Hi All,

Have received the NTO finally, will look to fill in the adjudicator appeal process, any pointers on if I should be adding anythign different or additional or just state 'refer to previous appeal points'