Council Clean Air Zone Notice Uses Wrong Legal Wording
Clean air zone, low emission zone, and ultra-low emission zone penalty notices from councils or Transport for London are public-authority fines. They are governed by a completely different set of rules from private car park tickets. If your notice uses language about 'keeper liability' that belongs only in private car park enforcement, that points to a procedural error that may give you grounds to challenge.
Legal basis
Protection of Freedoms Act 2012 Schedule 4 (private land only); Transport Act 2000; Greater London LEZ Charging Order
How to identify this in your case
Council/TfL paperwork uses POFA-style keeper-liability wording or threats based on Schedule 4.
Sample appeal wording
To: [Authority] CAZ/ULEZ/LEZ Team Re: PCN [PCN_NUMBER] Your communications reference the Protection of Freedoms Act 2012 Schedule 4 framework. POFA Schedule 4 applies only to private-land parking and CANNOT be the basis for a public-authority CAZ/ULEZ/LEZ charge. The correct statutory basis for your enforcement is the [Transport Act 2000 / Transport (Scotland) Act 2019 / Greater London LEZ Charging Order]. The procedural confusion in your correspondence raises serious questions about whether the PCN was lawfully issued. I require clarification of statutory basis or cancellation. Yours faithfully, [Keeper Name]
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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- POFA 2012 Sch 4
- Transport Act 2000
- Greater London LEZ Charging Order
Related appeal grounds
- Aberdeen LEZ: Special Vehicle Local Exemption
- Advisory bay has no legal force behind it
- Airport Land Isn't "Relevant Land" — They Can't Pin the Driver's Charge on You as Keeper
- Appeal to an Independent Tribunal
- Bath Clean Air Zone discount not applied to your charge
- Birmingham CAZ — NHS Worker / Hospital Visitor Exemption