The 5-paragraph structure
(1) Opening — your PCN reference, the date of issue, the contravention code. (2) Statement of grounds — which TMA 2004 s.73(1) ground(s) you are relying on. (3) Evidence — photos, signage diagrams, receipts, witness statements. (4) Statutory citation — quote the relevant Act or regulation, not just the section number. (5) Closing — clear, polite request for cancellation and reinstatement of the discount.
Tone matters more than length
Adjudicators read hundreds of representations a week. Yours stands out by being specific, calm, and statute-grounded — not by being long, angry, or emotional. A one-page letter that cites TMA 2004 s.73(1)(c) and attaches three photos beats a three-page letter without legal grounding every time.
What to avoid
Skip apologies (they read as admission). Skip moral arguments ("I was only there for two minutes"). Skip personal hardship as the primary ground unless mitigating circumstances are one of your grounds. Stick to defects on the council's side — signage, evidence, procedure, or exemption.