LEZ — Hire vehicle: hirer is liable, not registered keeper or rental company
Reg 5(4) SSI 2021/177 transfers LEZ liability from the registered keeper (a vehicle hire firm) to 'the person hiring the relevant vehicle' where (a) the registered keeper at time of contravention was a vehicle hire firm, and (b) the vehicle was hired under a 'hiring agreement' (defined: fixed-period hire, particulars meeting s.66 Road Traffic Offenders Act 1988, not hire-purchase). PCNs issued to a rental company for non-compliant hire vehicles are unenforceable against the rental company; council must serve the hirer. Conversely, if the agreement does NOT contain s.66 RTOA particulars or is for an indefinite period, transfer fails and rental company remains liable.
Legal basis
SSI 2021/177 reg 5(4); RTOA 1988 s.66; CCA 1974 s.189(1)
How to identify this in your case
PCN issued to you as hirer; or to your business as registered keeper but vehicle was on hire on detection date.
Sample appeal wording
Dear [COUNCIL] LEZ Team, Re: PCN [PCN_NUMBER] Representation under reg 8(1); ground [(c) keeper but liable is hirer / (d) hirer but agreement defective]. [If keeper:] On [DETECTION_DATE] the vehicle was on hire to [HIRER_NAME], [ADDRESS] under hiring agreement [REF] dated [DATE] (enclosed). The agreement contains the s.66 RTOA 1988 particulars, the hire is for a fixed period, and it is not a hire-purchase agreement within s.189(1) CCA 1974. Under reg 5(4) the penalty is payable by [HIRER_NAME]. [If hirer:] The hire agreement does not contain the s.66 RTOA particulars [or is a hire-purchase agreement / does not specify a fixed period]. Reg 5(4) does not apply. Please cancel and (if applicable) re-serve the correct person. Yours faithfully, [NAME]
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
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- SSI 2021/177 reg 5
- RTOA 1988 s.66