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So, not too much effort needed at this stage! 

Is there any benefit or advantage delaying the initial reps until the last minute or should the driver just go ahead with it now?

Initial representation submitted together with the drivers contemporaneous photos evidencing road markings obscured by snow and a pdf map showing the route taken to the location which, if inspected, will show no signs indicating that the area was a controlled zone for parking.

This is the final submission:

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I am challenging this PCN with representations on the following grounds:

1. Road markings at the location where the vehicle was stopped were obscured by snow so there was no indication of a bay and therefore the driver would not be expected to look for any signs. The photographs provided by the CEO do not show any road markings and additional photographs taken by the driver upon discovering the PCN also show that any road markings were obscured by snow.

2. There are no signs indicating that this was a controlled zone for parking along the route taken from the A49 along Freckleton Street to the location of the alleged contravention on Swinley Lane. After returning to the vehicle and seeing the PCN, the driver had to walk 25m behind the vehicle to see any sign indicating any parking restrictions. The driver never passed this sign when manoeuvring the vehicle in to the location from the junction with Freckleton Street and Swinley Lane. There are no photographs from the CEO showing the vehicle and any sign in the same frame because it was impossible to do so.

3. A procedural impropriety by using the incorrect contravention Code [12] "Parked in a residents’ or shared use parking place or zone without a valid virtual permit or clearly displaying a valid physical permit or voucher or pay and display ticket issued for that place where required, or without payment of the parking charge” should not have been used for the following reason: It should be contravention code [16]: "Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid physical permit where required" . Contravention code [16] is the correct code, not code [12].

4. An additional procedural impropriety is that the PCN cites the wrong period for payment. The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022, Schedule 2 paragraph 2(d) states: "that the penalty charge must be paid within the period of 28 days beginning with the date on which the alleged 'contravention' occurred,". The PCN actually states: "28 days from the date of 'service'", which is wrong and which introduces the potential for prejudice.

Based the above points, I believe that the PCN has been issued incorrectly and should be cancelled.

Additional evidence includes photographs taken by the driver upon discovery of the PCN showing any road markings obscured by snow. Also, no evidence of any signs within 25m of the vehicle. (evidence_1.jpg, evidence_2.jpg, evidence_3.jpg and evidence_4.jpg)

The following link to a Google Street View of the entrance to Freckleton Street evidencing no signs indicating a "Controlled Parking Zone": https://maps.app.goo.gl/JLocXJ1hE9cN15gZ6

A Google map indicating the route taken from the junction of the A49 and Freckleton Street to the location of the alleged parking contravention. (map_1.pdf)

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I'll keep you updated on progress. Thanks for the assistance.

There is no time limit for responding to informal reps (yours), although they have a common law duty to act fairly and expeditiously. There is a limit of 56 days to respond to formal representations against a Notice to Owner. ALso there is a limit of 6 months to actually issue an NtO, but they would have some serious explaining to do if it was over 3 months.

Have you checked the status of the PCN on their website ?

I presume the name and address on the V5 Registration Certificated is correct, up-to-date, and the same now as it was on the alleged contravention date ?

Some councils can be very tardy in dealing with representations, we see this a lot.

Very well done. We don't often see councils accept informal representations.