LEZ — Council enforcement contractor acted outside reg 11 arrangements
Reg 11 SSI 2021/177 permits a council to enter into 'arrangements' with another person for the exercise of functions under s.7 of the 2019 Act. Contractor's powers are derivative — cannot exceed council's. Common defects: PCN in contractor's name as 'enforcement authority' (only the local authority can serve a PCN under reg 6(1)); payment demanded to contractor's account; contractor not formally appointed by council resolution; representations decided by contractor without delegation under s.59 LGSA 1973.
Legal basis
SSI 2021/177 reg 11; reg 6(1); LGSA 1973 s.56 / s.59
How to identify this in your case
PCN issuer is private contractor (Marston Holdings, NSL, Civica, Excel) named as 'the authority'; payment to non-council account; FOI shows no delegation resolution.
Sample appeal wording
Dear [COUNCIL], Re: PCN [PCN_NUMBER] Representation under reg 8(1); ground reg 8(4)(a). The PCN names [CONTRACTOR] as issuing authority. Under reg 6(1) only the local authority may serve a PCN; reg 11 permits arrangements but a contractor cannot itself become the local authority. — PCN on [CONTRACTOR]-branded paper; — Payment demanded to [CONTRACTOR]-administered account [REF]; — FOISA 2002 request for council resolution / s.56 LGSA 1973 delegation. [If response: no resolution / does not extend to PCN issue.] PCN was not validly served by the local authority. Please cancel. Yours faithfully, [NAME]
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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- SSI 2021/177 reg 11
- LGSA 1973 s.56