I'm not going to comment without seeing the rejection letter and invoice except to say there is a formal notice to owner stage next before tribunal where they often reconsider.
The text of the three letters received from the council, in order from oldest to most recent, are as follows:
1. This first response followed the initial appeal, in which I described the situation, included specific times relating to the sequence of events in the breakdown, and included several photos showing the car being loaded and secured onto a recovery vehicle, visibly at the location of the PCN's issue.
"Thank you for contacting us about the above Penalty Charge Notice (PCN).
The PCN was issued because the vehicle was parked in a residents’ parking place or zone without a valid virtual permit or clearly displaying a valid physical permit or voucher or pay and display ticket issued for that place where required, or without payment of the parking charge.
Having reviewed your correspondence and the evidence available to myself, whilst I appreciate that the vehicle may have broken down, please be advised, we would require documentation in support of your appeal, before we make an informed decision. This should take the form of a breakdown report, or towing invoice, containing the date, time and location of the breakdown or recovery. It may also be an invoice from a garage who completed the works that were required or an invoice for the part, parts or labour that was required.
Please note, providing this evidence will assist in a decision being made but it should be noted that this does not guarantee the PCN will be cancelled. Failure to provide the evidence, could result in the PCN being upheld."
2. This second response followed me uploading the invoice from the recovery agent as requested - the response is correct in pointing out that there is not a VAT registration or address, although there is an email address for the recovery agent.
"Thank you for contacting us about the above Penalty Charge Notice (PCN).
The PCN was issued because the vehicle was parked in a residents’ parking place or zone without a valid virtual permit or clearly displaying a valid physical permit or voucher or pay and display ticket issued for that place where required, or without payment of the parking charge.
Having reviewed your correspondence and the evidence available, whilst I appreciate the invoice you have provided, please note that we are unable to accept this. Please be advised, as the documentation does not contain a company VAT number or a company address, I am unable to ascertain the validity of the invoice, therefore we would be looking at upholding this PCN.
Leaving a vehicle unattended for a period of time without a valid permit to park effectively renders the vehicle parked in contravention and a Civil Enforcement Officer (CEO) may issue a PCN.
It remains the driver's responsibility to ensure that the vehicle is parked legally at all times.
With that being said, we would have to inform you, the circumstances described do not warrant the cancellation of the PCN, and your appeal has been rejected at this stage.
Please see the below images as taken by the CEO whilst issuing the PCN:
[ the same photos as originally included with the PCN are repeated in the body of the letter, showing the car in the bay from front and back, and the bay's 'Resident permit holders only' sign ]"
3. This third letter came after I responded and questioned why the VAT registration of the recovery agent was of relevance to demonstrating whether or not I had broken down:
"Thank you for contacting us about the above Penalty Charge Notice (PCN).
The PCN was issued because the vehicle was parked in a residents’ parking place or zone without a valid virtual permit or clearly displaying a valid physical permit or voucher or pay and display ticket issued for that place where required, or without payment of the parking charge.
Having reviewed your most recent correspondence and the evidence available to myself, whilst I appreciate you may be disappointed with our decision, please be advised, should you wish to contest the matter further, I would have to advise to please await the Notice to Owner to arrive via post. Please do not respond to this correspondence as it will only delay the appeals process.
The Notice to Owner will establish liability for the PCN and the grounds under which representations may be made. If representations are made at this stage and they are rejected, there will be the right of appeal to an independent Environment and Traffic Adjudicator. We have now let the case off hold to allow it to progress to the next stage.
Further correspondence may not be responded to."
The invoice is as the council describes - it does not have an address or a VAT registration number. It has the company name, an email address, an invoice number, and in the description of the service provided, it states my vehicle reg number, the location it was recovered from (road and postcode), and the location it was recovered to (road and postcode), the date, the price, and that it was paid.
The photos I attached to the initial appeal showed (i) the car loaded onto the recovery truck, taken from in front of the recovery truck facing backwards, with the bays in which the PCN offence occurred clearly visible in the background; (ii) the car loaded onto the truck, with the photo taken from the opposite angle, with my car's reg plate clearly visible; (iii) the car parked up outside the garage having been recovered to there; (iv) the car up on a ramp at the garage.
For what it's worth, I'm not sure (iii) or (iv) are particularly convincing evidence on their own - since I don't have an invoice from the garage (since no work was actually carried out), these could, I guess, have been taken at any time in the past. So I don't think they come into play going forward, realistically - it wouldn't be worth labouring that. In any case, we're not trying to prove that my car got fixed here, we're trying to prove that it was broken down in the first place, hence why I couldn't move it from the bay and got a PCN.
