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Submitted.

Attempt 3.
I've picked up on Sec of State guidelines for TMA 2004 in a similar case - exercising discretion.
I guess an Adjudicator will say they only look at law not guidelines, but these reps are to Redbridge.

Redbridge Representations PCN AF14295221

I submit this representation for PCN AF14295221 on the grounds that the alleged contravention did not occur and that the Penalty charge exceeded the amount applicable in the circumstances of the case.

On 12th May 2026 at 14:16 I parked in Grove Park. I opened the Ringo App and out of the three nearby codes suggested it did not include 6081220 as displayed on the nearest  plate. I therefore had to manually type the code. I started a free, 1 hour parking session at 14:16.

I returned to my vehicle at approx. 14:35 to find a PCN on my windscreen. It had been issued 3 minutes after I had booked the parking session.
 
When I checked the current Ringo session I discovered I had booked the wrong Redbridge location, code 6081228, instead of 6081220. The last digit being different and adjacent on an iPhone keypad.

The contravention code on the PCN is 11u - Parked without payment of the parking charge. I assert that the contravention did not occur because there is zero payment due for the first hour of parking.  I paid zero.
 
The Secretary of State guidelines for the Traffic Management Act 2004 clearly states that:
“An authority has a discretionary power to cancel a PCN at any point throughout the CPE process. It can do this even when an undoubted contravention has occurred if the authority deems it to be appropriate in the circumstances of the case. Under general principles of public law, authorities have a duty to act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably and with due regard to the public interest. “

“Enforcement authorities have a duty not to fetter their discretion, so should ensure that PCNs, NtOs, leaflets and any other advice they give do not mislead the public about what they may consider in the way of representations. They should approach the exercise of discretion objectively and without regard to any financial interest in the penalty or decisions that may have been taken at an earlier stage in proceedings.

Authorities should formulate (with advice from their legal department) and then publish their policies on the exercise of discretion. They should apply these policies flexibly and judge each case on its merits. An enforcement authority should be ready to depart from its policies if the particular circumstances of the case warrant it.”

The penalty charge has clearly exceeded the amount applicable. A £110 penalty cannot be relevant for a minor location code error for an hour free parking.
 
The back office staff at Redbridge have not exercised their discretion at the informal stage. The Secretary of State guidelines have been ignored. They have clearly not acted faired and proportionately, with due regard to the public interest and appear more focused on raising revenue through a disproportionate financial penalty.

Addiitionally, the phone app is not user friendly and susceptible to user errors, especially for older people. The geolocation for location code 6081220 (Wanstead High Street) is inconsistent and does not show as a nearby location in Grove Park, a turning off Wanstead High Street. The lack of geolocation assistance means the entry of s 7 digit code on a small phone screen.

There are London Tribunal cases that support my assertion that a zero fee is not a payment and RingGo’s inaccuracies are unfair.
 
In London Tribunal Case 2250307301 the adjudicator allowed an appeal because you cannot fail to make a payment if it is free.

London Tribunal Case 2250307301 – the adjudicator allowed an appeal against Redbridge, saying "It seems to me that a PCN cannot be issued for a failure to “pay” for something which is free, and for which, by definition, no payment is required. The Appeal is allowed on this ground and it is unnecessary to examine the other issued raised by the Appellant."

For the reasons stated above I believe that this PCN should be cancelled.

Second attempt. Bit more concise and businesslike.

That third case above doesn't help. Geolocation gave the appellant the wrong code. The Adjudicator specifically says it's not the same as a manual keying error.

Redbridge Representations
PCN AF14295221
I submit this representation for PCN AF14295221 on the grounds that the alleged contravention did not occur and that the Penalty charge exceeded the amount applicable in the circumstances of the case.

On 12th May 2026 at 14:16 I parked in Grove Park. I opened the Ringo App and out of the three nearby codes suggested it did not include 6081220 as displayed on the nearest  plate. I therefore had to manually type the code. I started a free, 1 hour parking session at 14:16.
I returned to my vehicle at approx. 14:35 to find a PCN on my windscreen.
It had been issued 3 minutes after I had booked the parking session.
 
When I checked the current Ringo session I discovered I had booked a location in Ilford, code 6081228, instead of 6081220. The last digit being different.
The contravention code on the PCN is 11u - Parked without payment of the parking charge. I assert that the contravention did not occur because there is no payment due for the first hour of parking.  I have booked a session and accidently made a last digit error in the location code. This was also a free hour. No payment was required.

The penalty charge has clearly exceeded the amount applicable. A £110 penalty cannot be relevant for a minor location code error for an hour free parking. The phone app is not user friendly and susceptible to user errors, especially for older people.
The geolocation for location code 6081220 (Wanstead High Street) is inconsistent and does not show as a nearby location in Grove Park, a turning off Wanstead High Street. The lack of geolocation assistance means the entry of a 7 digit code on a small phone screen.

There are London Tribunal cases that support my assertion that a zero fee is not a payment and RingGo’s inaccuracies are unfair.
 
In London Tribunal Case 2250307301 the adjudicator allowed an appeal because you cannot fail to make a payment if it is free.

London Tribunal Case 2250307301 – the adjudicator allowed an appeal against Redbridge, saying "It seems to me that a PCN cannot be issued for a failure to “pay” for something which is free, and for which, by definition, no payment is required. The Appeal is allowed on this ground and it is unnecessary to examine the other issued raised by the Appellant."

For the reasons stated above I believe that this PCN should be cancelled.

I submit this representation for PCN AF14295221 on the grounds that the alleged contravention did not occur and that the Penalty charge exceeded the amount applicable in the circumstances of the case.

On the date in question, I did park in Grove Park. I opened the Ringo App and out of the three nearby codes suggested it did not include 6081220 as displayed on the nearest  plate. I therefore had to manually type the code. I started a free, 1 hour parking session at 14:16.

I returned to my vehicle at approx. 14:35 and was shocked to find a PCN on my windscreen. It had been issued 3 minutes after I had booked the session.
 
When I checked the current Ringo session I discovered I had somehow booked a location in Ilford, code 6081228, instead of 6081220. The last digit is different.

The contravention code on the PCN is 11u - Parked without payment of the parking charge. I assert that the contravention did not occur because there is no payment due for the first hour of parking. I have not denied Redbridge of a parking fee. I have booked a session and accidently made a last digit error in the location code. If Redbridge consider £0.00 as a payment then they still received one, albeit in a different location.

The penalty charge has clearly exceeded the amount applicable. A £110 penalty cannot be relevant for a minor location code error for an hour free parking. The phone app is not user friendly and susceptible to user errors, especially for older people. I am 68 years old, a Redbridge resident for over 30 years and often have issues with fat fingers and reading a small screen.

The geolocation for location code 6081220 Wanstead High Street is inconsistent and does not show as a nearby location in Grove Park, a turning off Wanstead High Street. The lack of geolocation assistance means the entry of s 7 digit code on a small phone screen. I would suggest Redbridge ensure that all codes are different by a minimum of 2 characters.

There are London Tribunal cases that support my assertion that a zero fee is not a payment and RingGo’s inaccuracies are unfair.
For the reason stated above and in the interest of fairness and common sense I ask that this PCN is cancelled.

Appreciate the observations but I didn't think faded lines held much sway these days.

The nearest entry roads have CPZ entry signs on GSV.

Seems like a high risk appeal to meq
 
Hard to convince an adjudicator that he didn't see the SYL and kerb blips which should trigger a look at the signs.

'You should know there is a loading restriction and  there is a sign on the nearest post'

Yes, that's what I thought. I'll get him to pay up.

I'll tell him about the kerb markings too. Surprising how many people don't know what they mean.

Another one for my family friend 

Not convinced this has much hope. He was doing a delivery but the markings (though faded) and the sign seem OK to me. Location details look garbled but it is Lloyd Road next to the CoOp. A few days left for the discount.



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