This is procedural. All that you are doing is registering an appeal. It's stage 1 of a 4-part process:
You register;
The tribunal notify the council who decide whether to contest your appeal and if so they would notify the tribunal and upload their evidence, a hard copy of which would be posted to you as well as being available to you online;
You add to your appeal based upon further points which arise from the council's evidence;
The hearing takes place.
Many, many appeals are won on procedural as opposed to substantive grounds so we've moved on from the events of the day to procedure which the forum posters know inside out.
While you're waiting for stage 2....
Is your surname and address the same as the registered keeper's? How did you submit these 'reps'? Sorry if this sounds intrusive but procedurally the authority SHOULD NOT have issued a NOR because they had not received reps from the person to whom the NTO was addressed:
Notice to owner
20.—(1) Where—
(a)a penalty charge notice has been given with respect to a vehicle under regulation 9, and
(b)the period of 28 days specified in the penalty charge notice as the period within which the penalty charge is to be paid has expired without that charge being paid,
the enforcement authority concerned may serve a notice (a “notice to owner”) on the person who appears to it to have been the owner of the vehicle when the alleged contravention occurred.
Duties of an enforcement authority to which representations are made under regulation 5
6.—(1) This regulation applies where an enforcement authority receives representations from a recipient under regulation 5.
The council had NO power to consider the 'representations' submitted by you and to issue a NOR. My question above are designed to see what possible excuse the council might have in the eyes of the adjudicator for such a gross procedural impropriety.
There are other faux pas in the 'NOR', but one step at a time.
