Thank you Mr Chips and super helpful. I use chatgpt to draft an appeal letter:
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Dear Sir/Madam,
I make these formal representations against Penalty Charge Notice (PCN) number EF99174738, issued on 13/08/2025, concerning vehicle registration PJ60VYC.
Grounds of Representation – Procedural Impropriety
This PCN has not been issued in accordance with the requirements of the London Local Authorities and Transport for London Act 2003 (“the Act”).
Section 4(

(a)(viii) of the Act requires that a penalty charge notice must state that the person on whom the notice is served may be entitled to make representations under paragraph 1 of Schedule 1 to the Act.
Paragraph 1(3) of Schedule 1 provides:
“The enforcing authority may disregard any such representations which are received by them after the end of the period of 28 days beginning with the date on which the penalty charge notice in question was served.”
However, this PCN instead states:
“We may disregard any representations received after the period of 28 days beginning with the date of the notice of this Penalty Charge Notice.”
This is a material misstatement of the law. The “date of the notice” is not the same as the “date of service.” The law deems service to occur two working days after posting if sent by first-class post. The PCN therefore unlawfully shortens the statutory representation period by at least two days.
1. Prejudice and Confusion
This defect is not trivial. It materially prejudices my legal rights by misinforming me of the correct time limit for making representations. A motorist relying on the PCN wording could wrongly believe they are out of time when, in law, they are not. The PCN therefore fails in its purpose of properly conveying statutory rights.
2. Mandatory Requirement
The requirements of section 4(

are mandatory, not optional. Case law such as Camden LBC v The Parking Adjudicator & BHS [2011] EWHC 295 (Admin) confirms that statutory wording must be followed precisely. A PCN that misstates mandatory information is invalid and cannot be enforced.
3. Inconsistency of Information
The PCN refers to deadlines being calculated from the date of service for payment, but from the date of the notice for representations. This inconsistency is confusing, contradictory, and contrary to the requirement that a PCN must be clear, accurate, and consistent in setting out the recipient’s rights.
4. Enfield’s Statutory Duty
As the enforcing authority, the London Borough of Enfield has a statutory duty to issue PCNs that comply with the Act. A PCN that misstates statutory rights is null and void ab initio, and cannot lawfully be pursued.
Conclusion
For the above reasons, the PCN is invalid due to procedural impropriety. I respectfully request that it be cancelled forthwith. Should you nevertheless reject these representations, I will appeal to the independent adjudicator at London Tribunals, where I will rely on the statutory wording and case law cited above.
Yours faithfully,
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PCN is issued under LLA 2003.
https://www.legislation.gov.uk/ukla/2003/3/contents/enacted
Section 4(8 )(a)(viii) states:
A penalty charge notice under this section must state that the person on whom the notice is served may be entitled to make representations under paragraph 1 of Schedule 1 to this Act.
Within paragraph 1 of Schedule 1, it states "The enforcing authority may disregard any such representations which are received by them after the end of the period of 28 days beginning with the date on which the penalty charge notice in question was served."
Your PCN does not state this - it states the similar but critically different "We may disregard any representations received after the period of 28 days beginning with the date of the notice of this Penalty Charge Notice."
Date of service is taken to be two business days after posting (first class) so that law gives you additional time to make representations than is set out in the PCN.
As it is a requirement of the LLA 2003 that Enfield MUST state that you may be entitled to make representations under the terms set out in paragraph 1 of Schedule 1 of the Act, and Enfield have not correctly done this, then I can't see how the PCN can stand as it includes information that is different and contrary to the wording that must be included.