Private contractor wrongly acted as the council

Only the council itself can issue a Low Emission Zone penalty notice — it cannot hand that power to a private contractor. If the penalty notice names a private company as though it were the enforcement authority, or demands payment into a private company's account, the notice may be invalid. A contractor can only do what the council has formally authorised it to do, and even then it cannot make final decisions on your challenge unless the council has properly delegated that right.

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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Private contractor wrongly acted as the council

Legal basis

How to identify this in your case

Sample appeal wording

Beat It writes this argument automatically

Sources

Related appeal grounds

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