I've had a look and it is not compliant with Regulation 3 (1)(c) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022
Information about right to make representations or appeal to be included in regulation 9 penalty charge notices and enforcement notices
3.—(1) A regulation 9 penalty charge notice must include the following information—
(a)that a person on whom a notice to owner is served may, in accordance with these Regulations, make representations to the enforcement authority against the penalty charge and, if those representations are rejected, appeal to an adjudicator;
(b)that if, before a notice to owner is served, representations against the penalty charge are received at such address as may be specified in the notice for the purpose those representations will be considered by the enforcement authority;
(c)that if a notice to owner is served despite the representations mentioned in sub-paragraph (b), representations against the penalty charge must be made to the enforcement authority in the form and manner and at the time specified in the notice to owner.
Of course this may not win an adjudication at the TPT, as adjudicator seem to have fallen in love with the words "substantial compliance", but for me, it is important to warn a PCN recipient that even if he submits represenations against a PCN, he must respond to the NtO despite having already submitted representations. This PCN does not make that clear.
I have to say I'm surprised to see this error, because it's been around in these and previous regulations for over 20 years. Why can't councils just copy and past the clause into the PCN ?
