Free Traffic Legal Advice

The key question here is why RingGo applied a discount to a car registered in 2000. As it is the council that have contracted with RingGo for their pay-by-phone facility, it is clearly their responsibility to make sure RingGo is applying the discount correctly.
I suggest you wait for the Notice to Owner and submit representations again, that point out you used RingGo in good faith, and it is not your fault the discount was incorrectly applied.

Thanks @cp8759 .

As a test, I tried buying a few additional parking tickets, to see if it still shows co2 (and to make sure I didn't miss something in the ringgo app to request the discount).



On the 11th, I first bought a ticket for 15 mins. It should have been £1, but came as as free.
The second ticket - purchased within 60 mins of the first expiring - was full price, and didn't show any co2 discount.
The third, purchased the next day, showed the co2 discount again.


This seems in-line with Richmond residents parking discount (https://www.richmond.gov.uk/richmond_card_for_parking)

If you live in the borough and hold a Richmond Card, you can get 30 minutes free parking in our:
..
You can only park for a single session for a period of up to 30 minutes. If you wish to park for longer you must pay for the total duration of your stay, but as a resident you will receive a 10% discount

The current advertised parking fees (gone up since I got the PCN):

• Up to 15 Minutes - £1.00
• 30 Minutes - £1.95
• 45 Minutes - £2.80
• 1 Hour - £3.75

When I try to book in the app, I get these prices:

• [15 mins] FREE
• [30 mins] FREE
• [45 mins] £2.80 - 10% = £2.52 (charge shows as £2.50)
• [60 mins] £3.75 - 10% = £3.375 (charge shows as £3.40)

The same link above also describes the low-emissions discount:

A 50 per cent discount applies on parking charges or parking permits* if you have a Car Tax Band A vehicle

I clearly didn't receive 50% discount.

If I try other cars with low emission number plates, the charge is £1.90 for 1 hour (same for two cars, one with residents permit, one without)


I think that they have just mislabelled the residents discount on the Ringo VAT receipt.

OP, your desire to investigate the why is laudable, but IMO it risks over-complicating matters.

You park; you look at the traffic sign; you contact the service provider prescribed; you enter the details required; you see the tariff demanded; you pay or drive away.

That's it IMO.

How the council's service provider calculates the tariff demanded is NOT your concern, it's the council's.

How the service provider notifies the council and its officers is NOT your concern, it's the council's.

...AND what's been overlooked so far, the wrong grounds have been used!

There is no 'display' requirement with RingGo therefore the contravention cannot be for failiure to display. Code 11 is the correct code, see the CEO Handbook under contravention code 11  https://www.londoncouncils.gov.uk/download/file/fid/4029

No you will nest receive a document called a order for recovery with this you will receive a form allowing you to make a statutory declaration to the effect that you did not receive the NTO the CC will be cancelled and the council will re serve the NTO

Hi @cp8759,
I can see now the fine is back down to £60 on the council website.

Do you have any recommendations on what I should be submitting in the formal representations?

• ringo applied a discount is wholly outside of your control
• Ringo have confirmed in writing that the amount charged was result of error in their systems
• pdf of the ringgo correspondence?
• screenshots of the ringgo app, showing there is no way for me to request a discount?

Do I also submit details of how the amounts align with my entitled residents discount, and co2 discount would actually be much greater, or as @guest179 says, complicate the matter. - I should save this for the adjudicator?


As always, thanks for all your help.

I prepared a word document with all the evidence that I was planning to attached to the formal representation.
How does this look?

Thanks in advance!


Penalty Charge Notice Number RT38689757
Date of issue 25/06/2023 at 13:14
Location of contravention SHEEN RD RICHMOND (CPZ A1)
Vehicle Registration Number V462LGW
Contravention 06P - Parked without clearly displaying a valid pay & display ticket or voucher (pay & display)

1. Parking without displaying a valid pay & display ticket/voucher

While I did not have a “pay & display” ticket, I did have a valid parking permit covering this time, purchased through Richmond’s cashless/ticketless parking provider (“RingGo”).
Contravention 06P should not apply when a ticketless voucher has been purchased.

The Penalty Charge was issued at 1:14 PM.
My parking permit covered a 1-hour period between “1:04 PM - 2:04 PM”

See Appendix A for the Ringgo Invoice, showing the start/end time of the purchased parking ticket.



2. CO2 Discount
In response to my appeal, you have changed the argument from “Parked without clearly displaying a valid pay & display ticket” to having purchased a ticket with a CO2 discount to which I was not entitled.
Application of this discount was wholly out of my control.
I was in no way able to control application of the discount, or aware that you were applying one.
a. The discount was applied automatically by London Borough of Richmond / their parking provider.
b. There is/was no way for me to request/not request the discount when purchasing a ticket through RingGo.
See Appendix B for screenshots from the RingGo App when purchasing a parking ticket. None of the screens include option for
c. There is no indication when purchasing the ticket that a discount was going to be applied.
The only indication of any discount being applied would be the confirmation page showing a total of £3.05 instead of the advertised rate of £3.40. It does not state that this was a CO2 discount.
If I had noticed the discrepancy, my only assumption would be that it was due to the 10% residents discount, to which I am eligible.

3. Resolution from RingGo Customer Care:
I have contacted RingGo directly to inquire about the CO2 discount mentioned in your response to my initial appeal.
In their email response, a representative named Carolyn acknowledged that the inclusion of the wording “CO2 discount of £0.35” on my invoice was an error.
They attributed this error to the age of my car, where unfortunately, the information was not held on the DVLA website and did not automatically populate on their system. Carolyn confirmed that that I have been charged correctly for the parking session.


See Appendix C for the email dated 21 September 2023 from RingGo customer support.
• The “(including CO2 discount of £0.35)” was incorrectly showing on my invoice
• They confirm that I was charged correctly.

4. Residence discount
The discrepancy between advertised parking rate of £3.40 and charged amount of £3.05 would be better explained as a resident’s discount.
Richmond residents should receive a 10% (£0.34) discount on parking rates.

My RingGo account is correctly registered with my residents status, as I am able to book tickets up to 30 minutes without charge, as shown in the screenshot below:
<screenshot of RingGo payment confirmation for £0.00, for a 15 min ticket>


In this case, the RingGo invoice gets marked as ‘dispensation’:
<screenshot of invoice showing £0.00, description is Dispensation: Sheen Road, Richmond Town (A1) (5431)>



Appendix A - Ringo Invoice Screenshot of the RinnGo Invoice, showing the ticket was valid at time PCN was issued.
Appendix B - Screenshots of each page in the RingGo app no options to request a CO2 discount
Appendix C - Email response from RingGo customer support stating I was charged correctly.

I think I would be strongly tempted to raise an official complaint with Richmond on this case. Not sending a letter of acceptance for 7 months is quite disgraceful as is the way they handled your representations.  RingGo are their PbP service provider and they could have easily checked with them why your car had a CO2 reduction shown.

It's the Royal Mail Horizon syndrome, which seems widespread throughout all our public bodies.