As usual, (and, BTW, all, repeat, all councils in London do this), they have sent you the usual Fob-Off letter. They do this knowing that most people then cough-up, not wanting to risk the full PCN penalty. As penalties in London are double the rest of the UK, you can understand why. For me, they have failed to consider your representations, but if you take the matter further, to the Notice to Owner stage, it is likely your reps will be considered more fully. The difficulty is that at the NtO stage, the discount option is lost. However most London councils re-offer it at this stage to avoid having to prepare an evidence pack for an adjudication. This is because, for an appellant, if the discount is not re-offered, it is a complete no-brainer to take them to London Tribunals as the penalty remains the same and there are no additional costs.