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       #Post#: 57772--------------------------------------------------
       Re: Surrey County Council - 27 Parked in a special enforcement
       area adjacent to a footway cycletrack or verge lowered 
   DIR By: Lycans
       Date: February 12, 2025, 3:50 am
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       Hi all,
       Many thanks for all your input. I've drafted a letter
       challenging the procedural process of the ticket:
       "I am writing to formally challenge Penalty Charge Notice
       RR02573792 issued to my vehicle PK59 RHA. I wish to contest this
       charge on the grounds of procedural impropriety by the
       enforcement authority.
       Grounds for Representation
       The Notice to Owner (NTO) states that the date of service of the
       PCN is 5th February 2025. However, the Civil Enforcement Officer
       (CEO) placed the PCN on my vehicle on 1st January 2025. This
       significant discrepancy suggests an administrative error and
       raises concerns about the validity of the enforcement process.
       Under Regulation 19 of The Civil Enforcement of Parking
       Contraventions (England) General Regulations 2007, a Notice to
       Owner must be served no later than 28 days after the PCN was
       issued. Given that the PCN was placed on my vehicle on 1st
       January 2025, the deadline for issuing an NTO should have been
       by 29th January 2025. However, the NTO I received was dated 3rd
       February 2025, suggesting a failure to comply with statutory
       timeframes.
       Furthermore, the council’s claim that the service date of the
       PCN is 5th February 2025 is factually incorrect, as I was issued
       the PCN on 1st January 2025. This misrepresentation could result
       in an unfair extension of enforcement deadlines, putting me at a
       disadvantage in responding to the charge.
       Request for Cancellation
       Due to this procedural impropriety and the inconsistency in the
       dates provided by the council, I kindly request that this
       Penalty Charge Notice be cancelled with immediate effect.
       I would appreciate written confirmation that the charge has been
       revoked. Should my representation be rejected, I request a full
       explanation addressing the discrepancy in dates and confirmation
       of my right to appeal to the independent adjudicator at the
       Traffic Penalty Tribunal."
       #Post#: 57774--------------------------------------------------
       Re: Surrey County Council - 27 Parked in a special enforcement
       area adjacent to a footway cycletrack or verge lowered 
   DIR By: stamfordman
       Date: February 12, 2025, 4:19 am
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       They get 6 months to serve an NTO from the time the PCN was
       served so you can lose that bit.
       #Post#: 57851--------------------------------------------------
       Re: Surrey County Council - 27 Parked in a special enforcement
       area adjacent to a footway cycletrack or verge lowered 
   DIR By: H C Andersen
       Date: February 12, 2025, 12:29 pm
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       You need to start again pl.
       The applicable regs are 2022 vintage, not 2007.
  HTML https://www.legislation.gov.uk/uksi/2022/71/regulation/20/made
  HTML https://www.legislation.gov.uk/uksi/2022/576/regulation/5
       Procedural impropriety on the part of the authority (not on
       behalf of as stated in the grounds.....which rather suggests
       that they've not updated these since taking the service back
       in-house)
       The Grounds of Representation are not those mandated by the
       Appeals regulations as follows:
       (g)the order which is alleged to have been contravened in
       relation to the vehicle concerned, except where it is an order
       to which Part 6 of Schedule 9 to the RTRA 1984 applies, is
       invalid;
       Is irrelevant. The restriction is a statutory prohibition, not
       one imposed under an order. And even if it was, these aren't
       grounds anyway because Part VI of Schedule 9 to the RTRA
       prescribes the only means by which an order could be challenged
       and this is to the High Court within 6 weeks of it being made.
       The Civil Enforcement Officer was not prevented from serving the
       Penalty Charge Notice;
       Is similarly incorrect as regards grounds which are available to
       you. These apply only if the PCN was served by post.
       If full payment has not been received or you have not made
       representations to the council within the time allowed the
       penalty charge will increase by 50% thereby increasing the
       amount outstanding to £105 and a Charge Certificate will be
       served on you.
       Rubbish. Increasing the penalty and serving a CC are permissive
       powers there's no WILL serve, this fetters their discretion,
       it's MAY serve.
       #Post#: 57919--------------------------------------------------
       Re: Surrey County Council - 27 Parked in a special enforcement
       area adjacent to a footway cycletrack or verge lowered 
   DIR By: Lycans
       Date: February 13, 2025, 4:14 am
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       Thank you all once again for your time and input  :)
       I never received the PCN via post, nor did I see it on the
       vehicle. The first time I was made aware of this is when I
       received the NTO.
       I'll leave in the bit regarding the service of the pcn being the
       incorrect date, and perhaps use this as a way to try and get the
       original discounted fee. I'll take responsibility for my mistake
       in parking on a lowered verge, I'd just like to pay the original
       fee instead as that method was never awarded to me.
       I'd be grateful if anyone could help me draft up a
       representation to them.
       Thank you.
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