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       #Post#: 28025--------------------------------------------------
       Request clarity on procedure to take (Out of time appeal - NTO
       sent to previous address due to DVLA delays) - Southwark
   DIR By: FaeLLe
       Date: June 30, 2024, 10:54 am
       ---------------------------------------------------------
       Dear all,
       Apologies for the large post, but I am in a desperate situation
       and requesting support.
       Any support would be appreciated as I am now without a job and
       struggling to make ends meet. All PCNs involve the Southwark
       Council.
       Please let me know if any additional information is required.I
       hope to gain clarity on how to handle the situation.
       Subsequently, I could get further advice on how to appeal as
       needed.
       Relevant documents are linked to below
       Relevant TMO for the parking PCNs
  HTML https://drive.google.com/file/d/1h-C50pd9J55tvTq5pE3_XJ059tWAi_j6/view?usp=sharing
       Notice for parking restriction
  HTML https://drive.google.com/file/d/1qHEn96fnh9j9qnSCAilTfWEKuT4aLZKE/view?usp=sharing
       Evidence for the existence of a valid virtual visitor permit
       (PCN still issued)
  HTML https://drive.google.com/drive/folders/1mNBSfwbjcOWY_XOK2sFAxzKIqmGkBn5o?usp=sharing
       Email sent to council after the existence of PCN (known after a
       SAR)
  HTML https://drive.google.com/file/d/1crRZ2xtC_Sz_76-wfaSojBAUi5oo94Mf/view?usp=sharing
       Final correspondence sent by the council
  HTML https://drive.google.com/drive/folders/1nb3GjFtlkkx7z1fBACn9E788d77kOx10?usp=sharing
       NTO and Charge certificates received through SAR
  HTML https://drive.google.com/drive/folders/1nqPX5As2VKUp9AEXsQ8AEpIAewYCDWaV?usp=sharing
  HTML https://i.imgur.com/3GESLHW.png
       8 PCN's in total
       - 5 PCNs the council has restored discounted payment for but
       will not accept representations despite not receiving PCN or
       NTO(2 of these days had valid permits).
       - 3 PCNs no discount offered again(1 in OfR stage at TEC and 2
       at pre - debt stage)
       For the 3 PCNs to which the council has not responded
       - For 1 PCN, I have evidence of a valid parking permit for the
       vehicle on the date.Receipts downloaded from the council
       website(link at the top of the post) can show the existence of
       valid permits.
       - For the other 2 PCNs, the TMO and parking space allocation do
       not match.
       ADVICE SOUGHT
       What should I do next, please ?
       
       - 5 PCNs where the Council has refused to consider the
       circumstances? Should it be out of time to appeal to the
       adjudicator since it is in the predebt stage?
       - For the 2 PCN in Full Stage rate, should I wait for NTO to
       appeal?
       - For 1 PCN(at TEC), should I wait for TEC's response?
       For all parking PCNs, I believe I have reasonable grounds for
       appeal.
       For the moving traffic contravention, I believe there is a
       technical issue with the yellow box, and I am waiting for a
       request to obtain copies of the relevant orders and camera
       details
       Historical Context
       I was made homeless and unable to access the property where I
       live due to several reasons.
       A friend helped me find a location to store my car at the NORTH
       PECKHAM ESTATE in Southwark.
       The parking location was in a permit parking area, but every
       day, the car was assigned a 'Virtual Estate Visitor Parking
       Permit' and parked at various places where a space was
       available.On 07 May 2024, the vehicle was assigned a resident
       estate parking permit(valid till 07 May 2025).
       This is an area where a lot of antisocial activity happens, and
       tampering with PCNs on cars is quite common. I have had two
       tyres vandalised in NP estate too.
       Context - How I became aware of the PCN
       On 23 May 2024, a neighbour was talking to me about my car and,
       in passing, mentioned how expensive it must have been to deal
       with all the parking tickets I was getting.
       Since I had never seen any PCN on the vehicle, I raised a GDPR /
       SAR request with South Council on the same day.
       On 31 May 2024, following a Subject Access Request, as listed
       below, Southwark Council returned to me with seven parking
       PCNs(code 85) and 1 moving traffic PCN(code 31j).
       None of Southwark Council's correspondence was received as it
       was sent to my previous address (more on below).
       Context - Why the PCN was not dealt with on time
       Since I was a domestic abuse victim and I am being protected,
       the DVLA has put in place special procedures for me to perform
       transactions on my vehicle.
       The DVLA requires me to work with a specially designated
       caseworker to perform transactions such as changing the address
       on my V5C.
       I have been corresponding with DVLA since December 2023 and was
       trying to obtain the form I need to use. Evidence shows delays
       occurred, andDVLA only effectively updated my address on 30
       APRIL 2024.
       Current situation - Southwark Council refuses to comment on
       evidence but insists procedure was followed
       On 19 June 2024, I made representations to the council(email
       attached), stating that the PCN was never received.
       On 28 June 2024(5 AM), South Parking sent me several emails that
       it was too late to appeal, and the NTO gave me 28 days to
       appeal.
       They added that my comments and evidence were seen but insisted
       that the PCN was valid and that legal procedure was followed.
       Questionable content was added(not sure if the wording/procedure
       followed by Southwark Council is correct): However, as a
       goodwill gesture, we will reoffer you the chance to pay at the
       amount of £65.00 for a further 7 days from the date of this
       letter. Failure to make payment will allow the case to revert to
       its original charge of £195.00.
       The last correspondence sent to me has offered to restore the
       original payment of £65 for 7 days, after which it will go back
       to the original charge or £195.
       I enclose copies of the final correspondence sent by email with
       the previous address still on it above.
       #Post#: 28084--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: ivanleo
       Date: June 30, 2024, 4:48 pm
       ---------------------------------------------------------
       [member=2106]FaeLLe[/member] your situation is potentially
       critical but can be salvaged as long as you follow our advice.
       JK09920129: This is at the pre-debt registration stage. To get
       this reset you must follow the instructions here:
  HTML https://www.ftla.uk/announcements/charge-certificates-london-local-authorities-and-tfl-act-2003-london-local-autho/<br
       />(do not contact the council, ignore everything the council
       says
       and just follow the guide).
       JK11077172, JK11097817, JK12943100, JK12954865: These are at the
       pre-debt registration stage. To get these reset you must follow
       the instructions here (this is not the same as the guide above):
  HTML https://www.ftla.uk/announcements/charge-certificate-cases-under-the-traffic-management-act-2004-no-original-pcn/<br
       />(do not contact the council, ignore everything the council
       says
       and just follow the guide).
       JK10970350: This will require an out-of-time statutory
       declaration using forms TE9 and TE7, this will require careful
       drafting and may well necessitate a review before a county court
       judge. It would be helpful at this stage to know whether you
       qualify for remission of fees, see the guidance here on this:
  HTML https://www.gov.uk/get-help-with-court-fees
       There is no guide for OOT cases because they require detailed
       case-specific submissions, unlike the other PCNs above where you
       can make an in-time submissions, an OOT application is not a
       tick-box exercise.
       JK13079860 and JK13201148: There are no documents I can see for
       these PCNs, how do you know about their existence? In any event
       the council website suggests you're still in time to make
       representations. I don't know what the deadline is as I don't
       know when the notices to owner were issued, but if you think you
       have an argument I would recommend you make representations
       immediately on
  HTML https://pcnevidence.southwarkparking.co.uk/pcnonline/index.php<br
       />and don't forget to add your new address (explain in the
       representation that you've moved house) and take a screenshot of
       the confirmation page once the representation has been
       submitted. If you don't know when the 28 day deadline is, just
       make a representation tonight. If you know when the 28 day
       deadline is and you know as a fact that you have a few days
       left, then post a draft on here first.
       Summary:
       Please read the guides I have linked and confirm whether the
       steps you need to follow are clear to get those five PCNs reset
       (note that there are two different guides, one for the parking
       PCNs and another for the moving traffic one).
       For the one where an OOT application to TEC is needed,please
       confirm whether you qualify for remission of fees. We will have
       to help you draft an out-of-time application to TEC.
       For JK13079860 and JK13201148, confirm how you know about the
       PCNS and whether you know when the 28 day deadline is. If it's
       imminent (within the next 3 / 4 days) just submit
       representations yourself as best you can. If you have at least a
       week or more, post a draft representation on here first.
       #Post#: 28102--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: FaeLLe
       Date: June 30, 2024, 6:17 pm
       ---------------------------------------------------------
       Thanks again for your help cp8759. It is very kind of you to
       support.
       I have marked up below the next steps as I understand it below
       each comment you have made.
       I appreciate your help in reviewing.
       --- Quote from: cp8759 link ---
       >
       > JK09920129: This is at the pre-debt registration stage. To get
       this reset you must follow the instructions here:
  HTML https://www.ftla.uk/announcements/charge-certificates-london-local-authorities-and-tfl-act-2003-london-local-autho/<br
       />(do not contact the council, ignore everything the council
       says
       and just follow the guide).
       >
       --- End Quote ---
       I will check with TEC to see if the debt has been registered. If
       yes, representations should be made using Form PE3 (which needs
       to be witnessed by a commissioner of oath).
       Southwark Council seems to have mentioned 14 days for the 50
       percent discount. This appears to be procedurally incorrect as I
       understand the discount for early payment must be within 21 days
       if a CCTV operation issued the PCN:
  HTML https://www.londoncouncils.gov.uk/services/parking-services/parking-and-traffic-charges-london<br
       />
       Anyway, I can seek guidance later once the TEC formality is
       complete.
       --- Quote from: cp8759 link ---
       >
       > JK11077172, JK11097817, JK12943100, JK12954865: These are at
       the pre-debt registration stage. To get these reset you must
       follow the instructions here (this is not the same as the guide
       above):
  HTML https://www.ftla.uk/announcements/charge-certificate-cases-under-the-traffic-management-act-2004-no-original-pcn/<br
       />(do not contact the council, ignore everything the council
       says
       and just follow the guide).
       >
       --- End Quote ---
       I will check with TEC to see if the debt has been registered. If
       yes, representations should be made using Form TE9 (parking
       PCN).
       --- Quote from: cp8759 link ---
       >
       > JK10970350: This will require an out-of-time statutory
       declaration using forms TE9 and TE7, this will require careful
       drafting and may well necessitate a review before a county court
       judge. It would be helpful at this stage to know whether you
       qualify for remission of fees, see the guidance here on this:
  HTML https://www.gov.uk/get-help-with-court-fees
       > There is no guide for OOT cases because they require detailed
       case-specific submissions, unlike the other PCNs above where you
       can make an in-time submissions, an OOT application is not a
       tick-box exercise.
       >
       --- End Quote ---
       TE9 and TE7 were submitted to TEC and an acknowledgement was
       received:
  HTML https://drive.google.com/file/d/1rpOTbVpR5mBXg1vD9y2lY63NJ-Nc-VuU/view?usp=sharing
       I have used the Ex106 form before and could be eligible for a
       fee waiver. This is only applicable if we need to seek a review
       of the TEC administrator's decision by a District Judge, am I
       right?
       For now should I hang tight and wait for TEC outcome?
       --- Quote from: cp8759 link ---
       >
       > JK13079860 and JK13201148: There are no documents I can see
       for these PCNs, how do you know about their existence? In any
       event the council website suggests you're still in time to make
       representations. I don't know what the deadline is as I don't
       know when the notices to owner were issued, but if you think you
       have an argument I would recommend you make representations
       immediately on
  HTML https://pcnevidence.southwarkparking.co.uk/pcnonline/index.php<br
       />and don't forget to add your new address (explain in the
       representation that you've moved house) and take a screenshot of
       the confirmation page once the representation has been
       submitted. If you don't know when the 28 day deadline is, just
       make a representation tonight. If you know when the 28 day
       deadline is and you know as a fact that you have a few days
       left, then post a draft on here first.
       >
       --- End Quote ---
       The following files were sent to me by Southwark Council through
       the SAR.
       JK13201148 (13 Mar 2024 - alleged contravention date):
  HTML https://drive.google.com/file/d/1bNkPWAI2q0cUqqi0pg2O5_qJJ_jkFjfn/view?usp=sharing
       JK13079860 (09 Apr 2024 - alleged contravention date):
  HTML https://drive.google.com/file/d/1hX-UvkWMDKCJVmr0n3dX1vuXmv9mcfRL/view?usp=sharing
       Both these PCNs show up as 'Next Stage' NTO.
       Perhaps the NTO has not been issued for these two yet. Is that
       why it's not shared in the SAR?
       --- Quote from: cp8759 link ---
       >
       > For the one where an OOT application to TEC is needed, please
       confirm whether you qualify for remission of fees. We will have
       to help you draft an out-of-time application to TEC.
       >
       --- End Quote ---
       Most appreciated. As above, do I wait for TEC to respond to my
       TE9 and TE7?
       --- Quote from: cp8759 link ---
       >
       > For JK13079860 and JK13201148, confirm how you know about the
       PCNS and whether you know when the 28 day deadline is. If it's
       imminent (within the next 3 / 4 days) just submit
       representations yourself as best you can. If you have at least a
       week or more, post a draft representation on here first.
       >
       --- End Quote ---
       As above, since 28 days have passed, should I just wait for the
       NTO? The relevant dates were in March and April 2024.
       Thanks again for all the guidance and help!
       #Post#: 28117--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: ivanleo
       Date: July 1, 2024, 3:12 am
       ---------------------------------------------------------
       JK09920129: 14 days is the correct period because this PCN comes
       under the London Local Authorities and Transport for London Act
       2003, which provides for a 14 day discount period. The period of
       21 days only applies to PCNs issued under the Traffic Management
       Act 2004.
       Yes you need to use form PE3 once the debt is registered.
       --- Quote from: FaeLLe link ---
       >
       > [quote author=cp8759 link=topic=2383.msg28084#msg28084
       date=1719784117]
       > JK11077172, JK11097817, JK12943100, JK12954865: These are at
       the pre-debt registration stage. To get these reset you must
       follow the instructions here (this is not the same as the guide
       above):
  HTML https://www.ftla.uk/announcements/charge-certificate-cases-under-the-traffic-management-act-2004-no-original-pcn/<br
       />(do not contact the council, ignore everything the council
       says
       and just follow the guide).
       >
       --- End Quote ---
       I will check with TEC to see if the debt has been registered. If
       yes, representations should be made using Form TE9 (parking
       PCN).
       [/quote]
       Correct.
       --- Quote from: FaeLLe link ---
       >
       > [quote author=cp8759 link=topic=2383.msg28084#msg28084
       date=1719784117]
       > JK10970350: This will require an out-of-time statutory
       declaration using forms TE9 and TE7, this will require careful
       drafting and may well necessitate a review before a county court
       judge. It would be helpful at this stage to know whether you
       qualify for remission of fees, see the guidance here on this:
  HTML https://www.gov.uk/get-help-with-court-fees
       > There is no guide for OOT cases because they require detailed
       case-specific submissions, unlike the other PCNs above where you
       can make an in-time submissions, an OOT application is not a
       tick-box exercise.
       >
       --- End Quote ---
       TE9 and TE7 were submitted to TEC and an acknowledgement was
       received:
  HTML https://drive.google.com/file/d/1rpOTbVpR5mBXg1vD9y2lY63NJ-Nc-VuU/view?usp=sharing
       I have used the Ex106 form before and could be eligible for a
       fee waiver. This is only applicable if we need to seek a review
       of the TEC administrator's decision by a District Judge, am I
       right?
       For now should I hang tight and wait for TEC outcome?
       [/quote]
       Just wait for the TEC outcome for now.
       JK13079860 and JK13201148: You might as well submit a
       representation now, it can't hurt. Post a draft on here in the
       first instance. Make sure to give your current address.
       #Post#: 35482--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: FaeLLe
       Date: September 3, 2024, 9:38 am
       ---------------------------------------------------------
       Hello all and [member=1]cp8759[/member]
       I have been following up diligently on the PCN, and the latest
       status is as below.
       Updated obtained through phone on 03-Sep-2024.
       Regarding JK10970350, I believe I now need to make an N244
       application (I am eligible for Help with Fees so I can get an
       HWF number).
       Could you please help me with the content for the N244
       application since they have rejected the grounds specified in my
       TE9? Redacted versions of forms submitted to TEC are below:
  HTML https://drive.google.com/file/d/1rpOTbVpR5mBXg1vD9y2lY63NJ-Nc-VuU/
       Could I repurpose the content we prepare for the N244 as the
       content for making applications to TEC for JK09920129,
       JK11097817, JK12943100 and JK12954865 (valid visitor permit
       exists). I have only a few more days/weeks for this.
       JK12943100: There was a valid visitor permit so PCN should be
       invalid. Should a separate N244 application be made for this PCN
       sharing this evidence (it was not included previously).
       JK13079860, JK13201148: Should I wait for the TEC debt
       registration or make further representations to the council with
       evidence of a valid visitor permit (this was not shared
       previously)?
       Since the vehicle had a valid visitor permit (linked in the
       table below) the PCN is really invalid.
       JK13381731: I have only received a rejection, and the council
       has not sent me a charge certificate (that I am aware of).
       JK1357373A (new PCN)
  HTML https://drive.google.com/file/d/1b2rUjhhG5uLXN2Q9pEAwx6mKUSsovA0m/:<br
       />Should I make late representations for this? Could you please
       help review the representations I previously made
  HTML https://drive.google.com/file/d/1Ea0Kb-zdnwU3mZVOcY9au2JYb_Pa9BOy/<br
       />and rejection provided by council
  HTML https://drive.google.com/file/d/14lNS9fn7QnCimYsUUIsqUr6XC4VUzY5I/<br
       />for JK1338173
  HTML https://drive.google.com/file/d/12KVsf9z3StYlg2_UoB-q7IH4rOB-Pqmu/<br
       />since it is the same scenario as this PCN.
       [table][tr][td][/td]
       [td]PCN NUMBER[/td]
       [td]STATUS[/td]
       [/tr]
       [tr][td]JK10970350[/td]
       [td]TEC rejected appeal.
       TEC informed me that Southwark Council rejected the appeal so
       the TEC officer reviewed their decision and rejected my appeal.
       [/td]
       [/tr]
       [tr][td]JK11077172[/td]
       [td]15 AUGUST 2024 - Debt registered with TEC
       19-Jun 2024: Southwark Parking provided notice by email that the
       PCN was not received and the registered keeper no longer lives
       at the previous address.
       02-Jul-2024: Email sent to Southwark parking requesting that the
       charge certificate be cancelled, new address obtained from DVLA
       and PCN be sent out.
       08-Aug-2024: GDPR request to rectify address was provided to
       Southwark council but the new address was ignored when debt was
       registered with TEC.[/td]
       [/tr]
       [tr][td]JK11097817[/td]
       [td]15 AUGUST 2024 - Debt registered with TEC
       Same as above
       20-Sep-2024 (4PM): Deadline to appeal to TEC.[/td]
       [/tr]
       [tr][td]JK09920129[/td]
       [td]15 AUGUST 2024 - Debt registered with TEC
       Same as above.
       20-Sep-2024 (4PM): Deadline to appeal to TEC.[/td]
       [/tr]
       [tr][td]JK12943100
       [/td]
       [td]13 AUGUST 2024 - Debt registered with TEC
       Same as above.
       18-Sep-2024 (4PM): Deadline to appeal to TEC.[/td]
       [/tr]
       [tr][td]JK12954865[/td]
       [td]13 AUGUST 2024 - Debt registered with TEC
       Same as above.
       Valid visitor permit exists:
  HTML https://drive.google.com/file/d/1a_OQkBRK59cqWLk7GIePcPQX-318X6GS/view?usp=sharing
       18-Sep-2024 (4PM): Deadline to appeal to TEC.[/td]
       [/tr]
       [tr][td]JK13079860[/td]
       [td]No debt registered with TEC.
       Council rejected representations.
       19-Jun 2024: Southwark Parking provided notice by email that the
       PCN was not received and the registered keeper no longer lives
       at the previous address.
       15 Jul 2024: Informal representation rejected -
  HTML https://drive.google.com/file/d/1Li8ycDXk1ZZBVMcVAfu3JGVgdQBXYAWL/
       08-Aug-2024: GDPR request to rectify address was provided to
       Southwark council but the new address was ignored when debt was
       registered with TEC.
       Vehicle had a valid visitor parking permit issued to them
       (states it was valid for the entire day):
  HTML https://drive.google.com/file/d/1IL5K6GmdIvQhGU-3bBew1dRZfF3X5BgO/
       Receipt downloaded from Southwark Parking website.[/td]
       [/tr]
       [tr][td]JK13201148
  HTML https://drive.google.com/file/d/1HvKKP0yk8AT0RILpry0jvmKNqlLyXynN/[/td]
       [td]No debt registered with TEC as of 03-Sep-2024.
       Council rejected representations.
       Vehicle had a valid visitor parking permit issued to them
       (states it was valid for the entire day):
  HTML https://drive.google.com/file/d/1bC7l746CvkxCAuDUE-_MYYgwLyMhSF15/
       Receipt downloaded from Southwark Parking website.
       19-Jun 2024: Southwark Parking provided notice by email that the
       PCN was not received and the registered keeper no longer lives
       at the previous address.
       02 Aug 2024: Informal representation rejected -
  HTML https://drive.google.com/file/d/1ylSZ2j1Q-Nu0RdVOQPXASAMlwn3Pz00U/
       08-Aug-2024: GDPR request to rectify address was provided to
       Southwark council.[/td]
       [/tr]
       [tr][td]JK13381731
       [NEW PCN revealed through SAR - same location]
  HTML https://drive.google.com/file/d/12KVsf9z3StYlg2_UoB-q7IH4rOB-Pqmu/
       Vehicle was parked in the permit parking zone using a valid
       permit.
       Council issued PCN stating that the bay was a disabled bay and
       no Traffic Order was required since the bay is compliant with
       TSRGD 2016.[/td]
       [td]No debt registered with TEC as of 03-Sep-2024.
       Council rejected representations.
       Vehicle had a valid parking permit to park in the zone.
       Registered keeper got a copy of the effective traffic order from
       Southwark parking team and Southwark traffic.
       Traffic order was used to check permitted locations to park -
       bay was not shown as disabled bay.
       19-Jun 2024: Southwark Parking provided notice by email that the
       PCN was not received and the registered keeper no longer lives
       at the previous address.
       18 Jun 2024: Informal representation made through website -
  HTML https://drive.google.com/file/d/1Ea0Kb-zdnwU3mZVOcY9au2JYb_Pa9BOy/
       16 Jul 2024: Informal representation rejected -
  HTML https://drive.google.com/file/d/14lNS9fn7QnCimYsUUIsqUr6XC4VUzY5I/<br
       />
       08-Aug-2024: GDPR request to rectify address was provided to
       Southwark council.[/td]
       [/tr]
       [tr][td]JK13581731
       Same as JK13581731 - PCN was just handed over to me by the
       driver.[/td]
       [td]No representations made - kindly advice.[/td]
       [/tr]
       [/table]
       #Post#: 35487--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: FaeLLe
       Date: September 3, 2024, 10:08 am
       ---------------------------------------------------------
       Additionally, on 02 July 2024, I wrote to Southwark Council
       stating the procedure from London Councils and asking them to
       cancel the charge certificate and reissue the PCN (quoted
       below).
       Southwark Parking has indicated that they can 'consider' but are
       not 'obligated to do so'.
       This indicates that Southwark Parking considers following
       guidance from the tribunal as optional. Full reply below.
       Is there any way to use this in our representations to the
       District Judge or the Tribunal for an out-of-time appeal (for
       those in the Charge Certificate stage)?
       P.S. Southwark Parking mentions some information was redacted,
       but only confidential information (such as the secure
       correspondence code with DVLA) etc. was redacted. My name, email
       address and full contact details of DVLA agents was provided to
       the council.
       My email to Southwark Parking (02 July 2024), well before these
       were registered with TEC as debt.
       --- Quote ---
       >
       > We notice that the seven PCNs below are in the Charge
       Certificate stage. Per paragraph 116 of London Councils' Code of
       Practice for Parking Enforcement, Southwark Parking is requested
       to cancel the Charge Certificate, re-check the address with
       DVLA, and serve another NtO.
       >
       > If this request is denied kindly confirm the reasons for
       deviance from London Councils code of practice formally in
       writing.
       > Evidence of delays incurred by DVLA to change the address  on
       V5C, due to which the NtO was not received, is attached to this
       email.
       >
       > Quoting the Code of Practice on Civil Enforcement from London
       Councils
  HTML https://archive.londoncouncils.gov.uk/services/parking-services/parking-and-traffic/parking-information-professionals/code-practice-civil,
       > If an owner contacts an authority and says that the Charge
       Certificate is the first notice received, the authority should
       consider allowing the owner to make payment of the full PCN
       charge (without the Charge Certificate increase) or make a
       challenge. When this is received, the Charge Certificate and
       preceding NtO should be cancelled. If the challenge is not
       accepted, the owner’s address should be checked and another NtO
       served (if within the time allowed) in order to give the owner
       the opportunity to make representations. If the authority
       chooses not to allow either of these options, for example, where
       an owner frequently makes this claim, they should explain the
       procedure for making a Witness Statement at the next stage of
       the process.
       >
       --- End Quote ---
       Southwark council responded individually in seven different
       emails with the below text:
       --- Quote ---
       >
       > Thank you for correspondence received in connection with the
       Penalty Charge Notice (PCN) JK12954865.
       > We have noted your comments. However, you did not provide us
       with an address to re-issue the notices and as a gesture of
       goodwill we reoffered you another opportunity to pay the
       discounted amount.
       > London Councils website states and as you have quoted ' the
       authority should consider' it does not state that we
       areobligated to do so.
       > The evidence you provided us had the necessary information
       redacted and therefore had no bearing on your case.
       > As it is the registered keepers responsibility to ensure that
       their details are correct and up to date with the DVLA, the
       legislation does not permit us to go back to the DVLA for an
       updated address.
       > We would like to inform you again that, the discount amount of
       £65.00 is still payable until 22/07/2024. Failure to make
       > payment will allow the case to revert back to its original
       charge of £195.00 and the PCN will continue on its path of
       > enforcement.
       >
       --- End Quote ---
       #Post#: 35658--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: ivanleo
       Date: September 4, 2024, 2:24 pm
       ---------------------------------------------------------
       [member=2106]FaeLLe[/member] for JK10970350 I will send you an
       email, this can't be dealt with efficiently on the forum.
       JK11077172: You need to go back to the guide here
  HTML https://www.ftla.uk/announcements/charge-certificate-cases-under-the-traffic-management-act-2004-no-original-pcn/<br
       />and follows the instructions from "As soon as the debt has
       been
       registered, use form TE9..." onwards.
       You are at very serious risk of missing the statutory deadline,
       you should file form TE9 as soon as possible.
       JK11097817: same as JK11077172 above.
       JK09920129: You need to use this other guide (not the same as
       JK11077172!)
  HTML https://www.ftla.uk/announcements/charge-certificates-london-local-authorities-and-tfl-act-2003-london-local-autho/<br
       />from "As soon as the debt has been registered, use form
       PE3..."
       JK12943100: I have no idea why you're mentioning N244s or HWFs,
       this is the same as JK11077172 above. Do not include anything
       about valid visitor permits or anything of the sort, just follow
       the guide and file form TE9 as instructed.
       JK12954865: same as JK11077172 above. Do not include anything
       about valid visitor permits or anything of the sort, just follow
       the guide and file form TE9 as instructed.
       JK13079860: You've said both "No debt registered with TEC" and
       "new address was ignored when debt was registered with TEC",
       which is it? If this has not yet gone to TEC, we don't know if a
       notice to owner has been issued, but make a speculative
       representation to the council anyway, this way if they've issued
       one in the past 28 days you'll get a notice of rejection and
       will be able to appeal to the tribunal (and if an NTO was issued
       more than 28 days ago and your representations are disregarded
       you can still go via the TEC route). Take a screenshot of the
       confirmation page once the representation has been submitted.
       JK13201148: Same as JK13079860 above.
       JK13381731: make a speculative representation to the council,
       this way if they've issued one in the past 28 days you'll get a
       notice of rejection and will be able to appeal to the tribunal
       (and if an NTO was issued more than 28 days ago and your
       representations are disregarded you can still go via the TEC
       route). Take a screenshot of the confirmation page once the
       representation has been submitted.
       JK13581731: Cannot find on the council website, is there a typo
       in the PCN number or is this a different vehicle reg?
       When I say make a speculative representation, include the
       following text in the representation:
       [indent]
       I am making this formal representation because the council might
       have issued a notice to owner within the past 28 days, in which
       case I ask that this be considered as my formal representation.
       I have not actually received the notice to owner, but that does
       not prevent you from considering this formal representation if a
       notice to owner has been issued.
       [/indent]
       As for this:
       --- Quote from: FaeLLe link ---
       >
       > Additionally, on 02 July 2024, I wrote to Southwark Council
       stating the procedure from London Councils and asking them to
       cancel the charge certificate and reissue the PCN (quoted
       below).
       >
       > Southwark Parking has indicated that they can 'consider' but
       are not 'obligated to do so'.
       > This indicates that Southwark Parking considers following
       guidance from the tribunal as optional. Full reply below.
       >
       --- End Quote ---
       This actually indicates that you have not read my instructions
       above which say "do not contact the council, ignore everything
       the council says and just follow the guide". Please do not
       contact the council for any PCN where I have said not to.
       Sorry if this comes across as a bit harsh, but there is an awful
       lot going on in this thread and I do not have time to explain
       the ins and outs of why you need to follow the steps I have
       indicated, you're just going to have to trust that I know what
       I'm doing.
       Also you don't need to PM me, if you tag me when you reply I
       will deal with it within 24 hours, usually far quicker than
       that. That being said if you need any clarification please feel
       free to ask, I'm more than happy to assist if anything is
       unclear.
       #Post#: 52680--------------------------------------------------
       Re: Request clarity on procedure to take (Out of time appeal -
       NTO sent to previous address due to DVLA delays) - Southw
   DIR By: ivanleo
       Date: January 9, 2025, 1:24 pm
       ---------------------------------------------------------
       Outcome for one
  HTML https://drive.google.com/file/d/1pfwKyNtkqTd0Nxr1d5tmTOilmpcyFnN6/view,<br
       />many more to go.
       *****************************************************
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