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Okay then how's this for a challenge?


Subject: Formal Challenge to PCN [Insert PCN Reference Number]

Dear Sir or Madam,

I am writing to formally challenge PCN [insert PCN number], issued for an alleged Clean Air Zone (CAZ) contravention on [insert date], during my journey from Blackpool to Leeds and back.

I would like to raise the following grounds in my challenge:

1️⃣ Inadequate Signage and Information
While driving, I did not see any CAZ signage that clearly indicated the charge or explained its meaning. As an out-of-town driver, I was unfamiliar with the CAZ symbol, and the signs provided no details on how or where to pay. There was no website address, phone number, or clear payment guidance. Simply stating “pay online” without sufficient details is, in my view, inadequate and unclear.

2️⃣ Lack of Timely Notification Before Penalty Issued
I only became aware of any outstanding charge after receiving the PCN, by which point the payment window for the original charge had already closed. Had I been informed before the penalty stage, I would have promptly paid the original £9 CAZ charge. It feels unreasonable and disproportionate to impose a £120 penalty without ensuring that drivers were properly notified and given a fair opportunity to pay.

3️⃣ Unintentional Entry Due to GPS Navigation
As a driver travelling from BD4 0FE (Bradford) to FY1 6LL (Blackpool), I was following GPS navigation, which gave no warning of CAZ entry or charges. I entered the zone unintentionally and had no intention to avoid payment or evade compliance.

4️⃣ Procedural Invalidity Under Regulations
According to the Road User Charging Schemes (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013, once the CAZ payment window has passed, the council can only issue a penalty charge — it does not have the power to combine or demand the original CAZ charge within the PCN.

This was explicitly confirmed in the Traffic Penalty Tribunal Case IA01249-1803 (June 2018), where Chief Adjudicator Caroline Sheppard ruled:

“There is no power in Regulation 7 for the PCN to require the road user charge to be paid in addition to the penalty charge. Nor is there a power for the charging authority to refuse to allocate a payment made for a crossing to that crossing, and hold it, possibly indefinitely, for future use.”

In this case, the PCN improperly demands payment of both the £120 penalty and the £9 CAZ charge, which exceeds the legal powers set out in the regulations. As such, the PCN is procedurally flawed and unenforceable.

Request for Cancellation
Given the legal and procedural issues outlined above, I respectfully request that this PCN be cancelled. I look forward to your written response.

Thank you for your time and consideration.

Yours faithfully,
[Your Full Name]
[Your Address]
[Your Contact Email/Phone (optional)]
[Date]

https://drive.google.com/file/d/1O49dyoBWhTmxuzyug7n_qwwRPg8pjeK3/view?usp=drive_link

Been working on more of a challenge.

is this any better?

Summary of Challenge Grounds
1️⃣ Unintentional Entry Due to GPS Navigation
As an out-of-town driver travelling from BD4 0FE (Bradford) to FY1 6LL (Blackpool), I followed GPS navigation, which did not alert me to the presence of the CAZ or warn me of any charges on the route. I entered the CAZ unintentionally and had no intention to avoid payment or evade compliance.

2️⃣ Inadequate Signage and Insufficient Payment Information
The CAZ signs I encountered did not provide sufficient clarity for a driver unfamiliar with the area. Specifically:
    • The CAZ symbol was not explained for drivers unaware of its meaning.
    • There were no clear instructions on how, where, or when to pay the charge.
    • No phone number or website was provided, limiting access for drivers without internet or prior knowledge.
As a result, I was unaware that I owed a payment or how to make it.

3️⃣ Lack of Timely Notification Prior to Penalty
I only became aware of the outstanding charge upon receipt of the PCN, by which point the penalty had already been applied. Had I received any form of reminder or notice before the penalty stage, I would have willingly paid the original £9 charge. The sudden escalation to a £120 penalty seems disproportionate, given the circumstances.

4️⃣ Procedural Invalidity Under Regulations
Under the Road User Charging Schemes (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2013, once the CAZ payment window closes, the council has no separate process to recover the unpaid daily charge other than issuing a PCN.
However, for the penalty to be valid, the council must meet key legal requirements, including:
    • Providing adequate advance notice through clear and effective signage.
    • Giving the driver a fair and reasonable opportunity to pay the original charge.
    • Issuing the PCN in full compliance with regulatory procedures.
In my case, these conditions were not met, and as such, I respectfully submit that the PCN is procedurally invalid.

Request
Given these mitigating factors and the outlined legal points, I respectfully request that the PCN be cancelled.
Thank you for your time and consideration. I look forward to your written response.

Signed:
[Your Full Name]
[Your Address]
[Your Email or Phone (optional)]
[Date]