Hi all,
I’d really appreciate some views on whether this is worth fighting further or whether I’m likely to lose the discount for nothing.
This is a Wrexham CBC WPPP PCN in Wales, issued on the windscreen in an off-street car park.
Basic details:
Council: Wrexham CBC (processed by WPPP)
Contravention code: 85
Allegation: “Parked in a permit bay without clearly displaying a valid permit”
Location stated on PCN: Wrexham Technology Park Centre Car Park
Date/time: 23/04/2026 at 10:25
Full penalty: £70
Discounted amount: £35
I made an informal challenge and they’ve rejected it.
My main concern from the start was the PCN wording itself. The front of the PCN appears to refer to the Traffic Management Act 2004 / 2013 Wales regulations, but it also seems to include wording referring to the old Road Traffic Act 1991 / designation order setup. That made me wonder whether it’s a hybrid / non-compliant PCN.
Also, the PCN says the penalty charge is payable within 28 days beginning with the date the PCN was served. My understanding was that for a regulation 9 PCN in Wales, the wording should be 28 days beginning with the date of the alleged contravention, not the date of service. The council’s rejection actually doubled down on this and said the wording is correct because it uses the “date served” wording.
In the rejection letter they say:
the area was signed on entry as “WCBC Permits and WCBC Visitor Permits Only No Pay and Display”
there were two signs on entry to the permit area
there is a relevant TRO and they refer to WX054 map page 23
photos are only secondary evidence and the CEO notes / handheld record are primary evidence
They also sent CEO photos. From what they’ve sent:
there is a photo of an entry sign
there are photos of the car in the bay
there are some photos through the windows / windscreen
the CEO notes say words along the lines of all windows checked / driver not seen / no permit displayed
One awkward point for me is that one of their close-up photos seems to show some sort of ticket or permit-looking item in the vehicle, but it doesn’t look like a WCBC permit for that location, so I’m not sure that helps me much.
At this point I’m trying to work out whether my best argument is now purely technical rather than factual.
The points I think might still be arguable are:
PCN wording defect – wrong 28-day wording for a reg 9 Wales PCN.
Hybrid statutory basis – PCN appears to mix current TMA 2004 Wales regime with old RTA 1991 / designation wording.
Possibly failure to properly consider, because the rejection doesn’t really engage with the statutory wording point beyond saying “the wording is correct”.
What seems weaker now:
general signage argument
“no TRO” type argument
general “contravention did not occur” argument, because they’ve now produced photos and notes
So my questions are:
Do the PCN wording / hybrid wording points look strong enough to take this to formal representations / TPT?
Is the “28 days from service” point for a Wales windscreen PCN a proper winner, or is there case law / adjudicator practice against it?
Does the old RTA 1991 / designation order wording matter in practice if the council says it was issued under TMA 2004?
Does the rejection letter itself help me by showing they may have applied the wrong statutory wording test?
If this were yours, would you pay the £35 or carry on?
If needed, I can post up:
both sides of the PCN
the informal challenge
the rejection letter
the CEO photos
the TRO page they relied on
All personal details / reg / PCN number will be redacted before posting.
Thanks in advance.
