Hopefully someone will respond to your question.
If they have failed to consider your representation then that's a legal point that can be challenged in accordance with paragraph 1(7) under Schedule 1 of the relevant legislation. Now if you cited all the PCNs in that single representation, then that argument may apply to all the PCNs you cited.
If you submit a representation, make sure the PCN portal cites the correct date for submission, once I submitted a representation on Lambeth’s PCN portal, it cited the correct date, then a few days later it changed the date, it seemed to change the date when I sent a question to Lambeth Parking services. I used this error as another legal point to challenge. Also, calculate the last day for the PCN discount and take a screenshot of portal on that date, then take a screenshot the day after incase there are errors.
With regards to the LA exercising discretion, under Section 87 of the Traffic Management Act, they should give regard to the guidance from the secretary of state, this official guidance explicitly mandates that authorities must not fetter their discretion. Gov.uk states on 28 May 2026:
“They should approach the exercise of discretion objectively and without regard to any financial interest in the penalty or decisions that may have been taken at an earlier stage in proceedings.”
However, I think the failure to consider argument and screenshot errors on the PCN portal (if any occur) may be a valuable strategy of appeal. I had a recent win against Lambeth, they did not contest at tribunal, just on the basis of a PCN portal screenshot error and telephone recordings where they misinformed the appellant of the enforcement process. Though I am unsure if they operate customer service by telephone or email in recent times.
@Incandescent, please correct me if I am mistaken but for moving traffic pcns would a “repeated contravention” be considered if service of the first PCN comes after the other contraventions occurred or is it strictly limited to parking pcns? In terms of a “continuous contravention” could that apply if a driver passed through multiple traffic restrictions in an area in a window of time on the same date. As I recall seeing cases like that on the previous forum (though it does not apply here).