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leahpatterson5
Hi I have had a look around the forum and I cant find a topic with a similar situation to my own. I was wondering whether somebody can direct me to one if they know of it or hopefully help me with my query please?

I received a Notice to Owner on 3rd August 2011 stating that I have failed to pay a PCN relating to a Bus Lane contravention on Rice Lane (Liverpool). The NTO stated the contravention was on 17th May 2011 and that I have failed to pay within 14 days so the charge is now £90.

I did not receive any PCN or any evidence of contravening Bus Lane laws.

I called Liverpool City Council and spoke to a gentleman who told me to make a complaint in writing.
I wrote and sent a letter the following day (4th August) and stated that i did not receive the original PCN, I didnt receive any evidence of the contravention and I asked for information they hold about me under the freedom of information and data protection acts.

56 days passed and i did not receive a response so i sent a further letter on 28th September to escalate my complaint and requested a reply within 10 working days whcih seems to be reasonable enough time to respond. I had no response after the 10th working day.

I then wrote to My MP on the 11th working day as i felt this was the only way i was able to get a response to my letters.
My MPs assistant emailed LCC and requested a response to my complaint. The response he got was that the council would re-issue the original PCN and I have to pay. There was no reference to my complaint or the information I requested under the freedom of info and data protection acts.

My questions are;

a) The offence was supposedly commited on 17th May but i was not served with a PCN. The NTO was served on 3rd August, which is over 11 weeks later, does this void the original PCN?
b) After the hassle they have put me through and the time taken are they able to reset the charge?
c) I read somewhere on another forum a while back that after 56 days of no response the council has failed to enforce the charge and it is therefore their fault they have failed to implement it and it is to be cancelled. Is this the case?

Thank you for your help and advice in the matter. Please, if I have missed a similar post to this then if you could direct me to it i would be grateful.
Leah
Enceladus
That document you received on the 3rd August. Please have another look. Is it something called a "Charge Certificate"?
Neil B
QUOTE (leahpatterson5 @ Fri, 21 Oct 2011 - 14:10) *
Hi I have had a look around the forum and I cant find a topic with a similar situation to my own. I was wondering whether somebody can direct me to one if they know of it or hopefully help me with my query please?

I received a Notice to Owner on 3rd August 2011 stating that I have failed to pay a PCN relating to a Bus Lane contravention on Rice Lane (Liverpool). The NTO stated the contravention was on 17th May 2011 and that I have failed to pay within 14 days so the charge is now £90. No, as 'E' said, that's a Charge Cert and probably clearly says so.

I did not receive any PCN or any evidence of contravening Bus Lane laws.

I called Liverpool City Council and spoke to a gentleman who told me to make a complaint in writing.
I wrote and sent a letter the following day (4th August) and stated that i did not receive the original PCN, I didnt receive any evidence of the contravention and I asked for information they hold about me under the freedom of information and data protection acts.

56 days passed and i did not receive a response so i sent a further letter on 28th September to escalate my complaint and requested a reply within 10 working days whcih seems to be reasonable enough time to respond. I had no response after the 10th working day.
There was a process to follow and complaints. foi, dpa, etc. are not it - although you weren't to know that at the time. The next doc in the process 'Order for Recovery' would have explained.

I then wrote to My MP on the 11th working day as i felt this was the only way i was able to get a response to my letters.
My MPs assistant emailed LCC and requested a response to my complaint. The response he got was that the council would re-issue the original PCN and I have to pay. There was no reference to my complaint or the information I requested under the freedom of info and data protection acts.

My questions are;

a) The offence was supposedly commited on 17th May but i was not served with a PCN. The NTO was served on 3rd August, which is over 11 weeks later, does this void the original PCN? No.
b) After the hassle they have put me through and the time taken are they able to reset the charge? Yes, and have been co-operative in doing so, saving you the trouble of dealing with the OfR.
c) I read somewhere on another forum a while back that after 56 days of no response the council has failed to enforce the charge and it is therefore their fault they have failed to implement it and it is to be cancelled. Is this the case? Not for bus lanes no.

Thank you for your help and advice in the matter. Please, if I have missed a similar post to this then if you could direct me to it i would be grateful.
Leah


Have they actually re-issued the PCN then??? We need to see it if so.

All LCC Bus Lane PCNs are beatable anyway but for none of the reasons you are looking at.
leahpatterson5
Hi guys, thanks for the info. My mistake, it is actually the charge certificate as you said not an NTO. Sorry, im reading to much and getting things confused.
Im waiting on the reissued PCN and will upload it as soon as i get it. I was just trying to gather as much info as possible in preparation. Should be today when i get home or tomorrow.
In terms of FoI and data protection, i only really asked for that for personal reference in case there were any other issues they have about me. Or if they have anything else that could help my cause.
once i get the PCN ill compare it against one already on site, if im struggling would you mind taking a look and giving me some pointers?
Thanks for helping me out so far
Leah
Enceladus
Do you have anything in writing that confirms that LCC propose to re-issue the PCN? Or might the above be a phone call or what? By that I mean do you have possession of such in writing, not some member of the MP's office?

I am trying to definitively establish where the case is at. IE. there is no possibility that we are in fact at the warrant stage?

If the Council reissue the PCN then you are perfectly entitled to challenge it and ultimately request adjudication. You do not have to pay it unless you lose, which I doubt will happen.
Enceladus
In a case like yours, where you have a Charge Certificate but did not receive the original postal PCN, then I would normally advise that you wait for the subsequent Order for Recovery from Northampton County Court and complete the statutory declaration which comes with it.

I would not be surprised, at all, if your case did progress to the OfR stage, no matter what your MP has been told.
And be aware that OfRs seem to have some mysterious propensity to get lost in the post. (The Council is responsible for posting them not Northampton Court.)
And the first the victim knows is when the bailiff arrives and clamps the car.

Hence my earlier questions. And keep a close eye on this.

Neil B
Could try the payments page idea I just posted in Davemarsbar thread?
Neil B
QUOTE (Neil B @ Sun, 23 Oct 2011 - 13:55) *
Could try the payments page idea I just posted in Davemarsbar thread?


Don't bother, that idea doesn't work.
Glacier2
Wait for the OFR.

When people depart from this procedure they end up with bailiffs. Stop engaging with the council.
leahpatterson5
Hi Guys, finally managed to get the letter from the council. It was sent recorded delivery and nobody was able to sign so I have had to get it from the post office this morning.

I have scanned and sorted the docs they have sent me and attached them.

I think there may be discrepencies on the PCN that has been re-issued as the dates in November are more than 14 and 28 days apart.

The PCN is dated 18/10/11 and assuming I received it 20/10/11 14 days (inc 20th) would be up on 2nd November. They state the 4th November.
The 28 days would therefore be up on 16th November, they have stated 22nd November.
Am I reading this incorrect? I am quite naive when it comes to legal issues such as this.
(The same kind of thing is true for the one they say they posted on 06/06/11 but i was never in receipt of)

The info I requested under FoI is also attached and shows dates upon which documents were issued/received etc. hopefully this may be of some use.

Its worth saying that although the photo has scanned poorly, it is my car. The date/time log on the two photos is 17/05/2011 17:39:35 and 17/05/2011 17:39:36.

Sorry to be a pain, you have probably seen this many times over. I appreciate any help or advice you can give me.

Thanks
Leah
Glacier2
Our advice of waiting for the OFR stands still. Until you have that you need to put that over active pen of yours away.
Enceladus
There is a possibility that your original PCN has been served late. In order for the Council to enforce they would have to prove that;
they requested the RK (Registered Keeper) details within the 14 days from the DVLA, 30th May in this case.
and
the DVLA failed to provide the RK info before the end of the 28 days, 13th June in this case.
Otherwise they are simply not entitled to serve the PCN.

In this case they claim in the letter to have posted the PCN on the 6th June. RK requests and the response are done via an EDI system. The response would be next day at worst where there are no change of address complications. So why was the PCN delayed until the 6th June if the request mas made in time?

You did not receive this PCN. You can only deal with the PCN you did receive and the details stated on it. This says it was posted on the 18th October. As I see it LCC was not entitled to serve a PCN this late unless they had requested the RK details by the 30th June and the DVLA had not responded till after the 14th July.

So when you make representations against this PCN make sure you ask for the dates of and copies of the requests and responses to the DVLA. And a copy of the computer access record for this PCN.
http://www.legislation.gov.uk/uksi/2005/27...ulation-8-made)

QUOTE
8.—(1) Where an approved local authority have reason to believe that a penalty charge is payable under Part 2 with respect to a vehicle, they may, in accordance with paragraphs (2) and (5) below, serve a notice (“penalty charge notice”) on the person appearing to them to be the owner of the vehicle or on the person appearing to them to be the person liable to pay the charge.

(2) Subject to paragraph (3), a penalty charge notice shall be served before the end of the period of 28 days beginning with the detection date.

(3) Where—

(a)within 14 days of the detection date an approved local authority have made a request to the Secretary of State for the supply of relevant particulars; and

(b)those particulars have not been supplied before the date after which the authority would not be entitled to serve a penalty charge notice by virtue of paragraph (2),

the authority shall continue to be entitled to serve a penalty charge notice for a further period of six months beginning with the date mentioned in sub-paragraph (b).
Neil B
QUOTE (leahpatterson5 @ Mon, 24 Oct 2011 - 10:35) *
I think there may be discrepencies on the PCN that has been re-issued as the dates in November are more than 14 and 28 days apart.

The PCN is dated 18/10/11 and assuming I received it 20/10/11 14 days (inc 20th) would be up on 2nd November. They state the 4th November.
The 28 days would therefore be up on 16th November, they have stated 22nd November.
Am I reading this incorrect? I am quite naive when it comes to legal issues such as this.


You've obviously done as suggested and had a read around. Not naive at all - you achieved 100% understanding straight away, a very good sign for the fight ahead, and your calculations are correct.
Enceladus
For the record, the (copy of) 6th June PCN also has date errors.
06/06/11 = Posted (allegedly).
08/06/11 = PCN deemed served.
21/06/11 = Last day topay at discount. PCN says 23/06/11.
05/07/11 = Lat day to pay or challenge. PCN says 11/07/11.

Have a read of this post, if you have not done already. You will likely have to use and modify the J.Edgar letter to suit.
And I suggest you send the DVLA letter.
leahpatterson5
Thanks Enceladus. Judging by the report they sent along with the copies of the PCNs they have been a few days outside of the 14days.

One more question if you wouldnt mind, do I have to tick any of the boxes on the back of the PCN and return it or should i just write a short letter something along the lines of the following;

I wish to make representations against this charge on the following grounds;

I believe that LCC has failed to follow legislation and the Registered Keeper information was requested outside the 14 days allowed for LCC to enforce the fine.

In order to have the full facts available to me I will require a copy of all requests and responses to and from the DVLA in relation to LV51145420. I will also require a copy of the computer access form for this PCN.


I wouldnt want to get this far and mess it up by ticking the wrong box

(Thanks also to Neil B - I just tried to get the info so as not to repeat others and waste everyones time)

Must have been typing at the same time, ill check out the J.Edgar letter. Thanks
Enceladus
Please don't do anything for the moment. I missed the fact that there were more computer log pages posted earlier.
leahpatterson5
ok no probs, i havent written/sent anything so ill check back a little later on. Thanks
Enceladus
QUOTE (Enceladus @ Mon, 24 Oct 2011 - 13:01) *
Please don't do anything for the moment. I missed the fact that there were more computer log pages posted earlier.

Be aware that I have corrected the dates in my post #12 above.

Hmmm!
The computer log shows that a request for details was submitted on the 26th May. This would be in time.
And shows a repeat request on the 3rd June. This would be out of time.
The response was received and processed the same day.
(And then the PCN was apparently lost in the post.)

So I wonder when the DVLA think they had the request?
Just because LCC's system says a request was made does not mean it went through to the DVLA and was correctly formatted. Seems to me possible that LCC had some computer issue at the end of May and that is not your problem.

Did you change address around this time? And were the car details up to date with the DVLA? I Assume no and yes. So I suggest that you challenge both the original and replacement PCNs as being null and void as the RK details were not requested with the time-frames laid down in the regulations. And let LCC prove otherwise.
and
In respect of the second and current PCN, it has been served outside the rules as the DVLA clearly did respond within the 28 days, whatever about the date of the request. And their own record says so.

You have PCN so you must pay or challenge.
Might be best to post up a draft of what you intend to say.

Glacier2
Hang on. I thought the OP was at the CC stage and was waiting on a OFR?
Neil B
QUOTE (Glacier2 @ Mon, 24 Oct 2011 - 14:00) *
Hang on. I thought the OP was at the CC stage and was waiting on a OFR?


We were, --- but she LCC agreed to re-issue without issuing OfR. We were waiting to see if they kept their word -- and they did.

So we just have the PCN now.

QUOTE (Enceladus @ Mon, 24 Oct 2011 - 13:54) *
Just because LCC's system says a request was made does not mean it went through to the DVLA and was correctly formatted. Seems to me possible that LCC had some computer issue at the end of May and that is not your problem.


--- and every other day of the year!

bama
check with the DVLA re dates of all requests and dates of matching responses (within the relevant period)

Do that in writing.

council IT is appalling IMO (why should it be different than the rest of the council's 'efforts')
leahpatterson5
Hi,
Sorry, I just want to be sure before I go in to it that im fighting on the right lines.

I understand from Enceladus' post that the second PCN is out of time for sure, so is the original cancelled and the second one a replacement (thus cancelling the first)? Or is the second one simply acting as a copy of the first PCN?

I understand that I should make representations against both because in some sly way im sure they will try to enforce the first if they can, if its more likely to be in time.

So is it a simple case of using the template from J.Edger and changing the dates?
Do I have to do two seperate letters for each PCN even though the second is a replacement?
In terms of them accessing the DVLA registered keeper info, is it worth mentioning this as well as the inaccurate dates on the PCNs?

____________________________________________________________________


Using J.Edgars template I have underlined the dates to make it a little easier to read, so if I were to word a letter;

I wish to make representations against PCN LV******** on the following grounds;

1) That the penalty charge exceeded the amount applicable in the circumstances of the case.

The PCN issued by Liverpool City Council (LCC) fails to comply with, The Bus Lane Contraventions (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2005, regulation 8(5) and specifically with regulations, 8(5)(e), 8(5)(g) and 8(5)(k) as it fails to correctly and with certainty, inform the recipient of the lawful periods for payment, for making representations and for enforcement via Charge Certificate. The relevant regulations are quoted below:

"(5) A penalty charge notice must state—(a) the registration mark of the vehicle involved in the alleged contravention;
(b) the detection date and the time at which the alleged contravention occurred;
© the reasons why the authority believe that a penalty charge is payable;
(d) the amount of the penalty charge;
(e) that the penalty charge must be paid before the end of the 28 day period;
(f) that if the penalty charge is paid before the end of the period of 14 days beginning with the date of service of the notice, the penalty charge will be reduced by one half;
(g) that representations may be made, on any of the statutory grounds of appeal, to the authority against the imposition of the penalty charge but that representations made outside the 28 day period may be disregarded;
(h) what are the statutory grounds of appeal;
(i) the postal address to which representations are to be sent;
(j) any electronic mail address or FAX number to which representations may be sent as an alternative to the postal address;
(k) that if at the end of the 28 day period—
(i) no representations have been made; and
(ii) the penalty charge has not been paid,
the authority may increase the penalty charge by a half and take steps to enforce payment of the charge as so increased;"

The 28 day period is defined within the regulations in regulation 7 and is defined as follows:

"7.
In this Part—
"the detection date", in relation to a contravention, means the date on which, according to a record produced by an approved device, the contravention occurred;
"the recipient", in relation to a penalty charge notice, means the person on whom the penalty charge notice is served; and
"the 28 day period", in relation to a penalty charge notice, means the period of 28 days beginning with the date of service of the notice."

The penalty charge notice issued by LCC fails to comply with the above mentioned regulations in that rather than specifying the 28 day periods as prescribed in law it provides in all instances a date of 11 July 2011, this date is calculated from a presumed date of service that LCC cannot know at the time of issue and posting.

Although the regulations do make provision from presumption of service in regulation 2(5) as quoted below:

" (5) References to the service of a document include service by post and, in determining for the purposes of these Regulations the date on which a notice or other document is served by post, it shall be presumed that service of a notice sent by first class post was effected on the person to whom it was addressed on the second working day after the day on which it was posted."

This definition is clearly defined as a presumed date of service and not a statement of fact. Actual service of a document sent by post is effected at the time at which the letter would be delivered in the ordinary course of post. "

This is confirmed in s.7 of the Interpretation Act 1978 as quoted below:

"7
References to service by post.
Where an Act authorises or requires any document to be served by post (whether the expression “serve” or the expression “give” or “send” or any other expression is used) then, unless the contrary intention appears, the service is deemed to be effected by properly addressing, pre-paying and posting a letter containing the document and, unless the contrary is proved, to have been effected at the time at which the letter would be delivered in the ordinary course of post."

I therefore contend that the failure of the PCN issued to comply with the stated regulations under which it is issued renders it unlawful and an unenforceable nullity in law.

2) That the penalty charge exceeded the amount applicable in the circumstances of the case.

The PCN issued by Liverpool City Council (LCC) fails to comply with, The Bus Lane Contraventions (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2005, regulation 8(5) and specifically with regulation, 8(5)(f), as it fails to correctly and with certainty, inform the recipient of the lawful period for payment of the penalty charge at the discounted rate.

(5) A penalty charge notice must state—

(f) that if the penalty charge is paid before the end of the period of 14 days beginning with the date of service of
the notice, the penalty charge will be reduced by one half;

The penalty charge notice issued by LCC fails to comply with the above mentioned regulation in that rather than specifying the 14 day period as prescribed in law it provides a date of 23 June 2011, this date is calculated from a presumed date of service that LCC cannot know at the time of issue/posting for the reasons as stated in point 1) above.

However even if the the date is calculated by the methodology used by LCC based on the date of service being the second working day after the date of issue/posting, the date provided is incorrect and unlawfully reduces the period of time prescribed in law for payment at the discounted rate by a period of 4 (four) days.

Date of posting of the PCN is Monday 06/06/2011, therefore the calculated date of service is Wednesday 08/06/2011. This makes the end of the 14 day discount period as Tuesday 21/06/2011 and not Thursday 23/06/2011 as stated on the PCN by LCC.

With respect to both points 1) and 2) of these representations LCC have failed in their statutory duty to ensure that the PCN they have issued to me is compliant with the legislation under which it is issued, I contend that the PCN is so fatally flawed that it is a nullity in law and any attempt on the part of LCC to pursue this matter further would be ultra vires. This has been confirmed in the High Court as referenced below:

The need for certainty in the payment periods has been establish in the High Court and I refer to the binding ruling of Jackson J in R v The Parking Adjudicator (ex p Barnet) , who at paragraph 39 states:

"There are good policy reasons why PCNs should comply with the statuary requirements. These documents are issued in large numbers. They often change hands. A PCN may for example, be issued to a driver on one date and handed to the owner on a later date. When a PCN reaches the owner, he or she may wish to pay the discounted charge. There must always be certainty about the date when the notice was issued and the dates when the various periods for payment will expire."

Jackson J, further goes on to state with respect to statutory compliance, in R v The Parking Adjudicator (ex p Barnet), paragraph 41:

"Mr Lewis submits that even if there was non-compliance in this respect, nevertheless no prejudice was caused, PCNs should not be regarded as invalid. I do not accept this submission. Prejudice is irrelevant and does not need to be established. The 1991 Act creates a scheme for the civil enforcement of parking control. Under this scheme, motorists become liable to pay financial penalties when certain specified statutory conditions are met. If the statutory conditions are not met, then the financial liability does not arise."

In the event that the enforcement authority wish to argue that this ground is inappropriate in this case I would like to refer them to PATAS key case, Elaine Patricia Lavall -v- London Borough of Hammersmith and Fulham Case No: 2040135996. Where the adjudicator, Martin Wood found in paragraph 8 as quoted below:

"8) As to the argument that the circumstances do not fall within one of the statutory grounds for contesting liability in paragraph 2(4) of Schedule 6 to the 1991 Act, they seem to me to fall within ground (f): that the penalty charge exceeded the amount applicable in the circumstances of the case. If the PCN was not valid, the penalty payable would be nil and therefore would exceed the penalty claimed by the local authority. In any event, in R v Parking Adjudicator Ex p. Bexley [1998] RTR 128, the Court expressly rejected the argument that challenges on collateral matters of law could only be brought by way of judicial review and held that parking adjudicators have the power to consider issues of collateral challenge. The arguments put forward in this case have in truth already been considered by the Court in Bexley and rejected. I would also note Wandsworth LBC v Winder [1985] 1 AC 461 in which the House of Lords held that a defendant in civil proceedings brought by a public authority could raise a public law issue in his defence."

In light of the above and the fact that, local authorities are statutory creatures and can do nothing except that which is expressly or impliedly authorised by statute - Lord Templeman in Hazell v. Hammersmith and Fulham London Borough Council [1992] 2 A.C. 1. I require the enforcement authority to cancel this alleged "penalty charge notice" forthwith.

In the event that these representations are rejected I will require the enforcement authority to fully explain in their Notice of Rejection how their "PCN" complies with the above mentioned regulations. I will have no hesitation in taking this matter to adjudication, where I will be making a request for costs on the grounds that the enforcement authority have acted frivolously, vexatiously and wholly unreasonably in not accepting valid representations at the earliest opportunity. I will also be respectfully requesting the that adjudicator is minded to make recommendations in his adjudication with respect to all previous and pending PCNs that LCC have unlawfully issued under The Bus Lane Contraventions (Penalty Charges, Adjudication and Enforcement) (England) Regulations 2005



________________________________________________________________

Should I include the request as follows or is this not necessary at this point?
as a further note I believe that LCC has failed to follow legislation and the Registered Keeper information was requested outside the 14 days allowed for LCC to enforce the fine.

In order to have the full facts available to me I will require a copy of all requests and responses to and from the DVLA in relation to LV51145420. I will also require a copy of the computer access form for this PCN


________________________________________________________________

In terms of the Re-Issued PCN is it a case of simply copying the above text and inserting the corrected paragraph to suit my dates as follows:

"7.
In this Part—
"the detection date", in relation to a contravention, means the date on which, according to a record produced by an approved device, the contravention occurred;
"the recipient", in relation to a penalty charge notice, means the person on whom the penalty charge notice is served; and
"the 28 day period", in relation to a penalty charge notice, means the period of 28 days beginning with the date of service of the notice."

The penalty charge notice issued by LCC fails to comply with the above mentioned regulations in that rather than specifying the 28 day periods as prescribed in law it provides in all instances a date of 22 November 2011, this date is calculated from a presumed date of service that LCC cannot know at the time of issue and posting.



AND...


The penalty charge notice issued by LCC fails to comply with the above mentioned regulation in that rather than specifying the 14 day period as prescribed in law it provides a date of 04 November 2011, this date is calculated from a presumed date of service that LCC cannot know at the time of issue/posting for the reasons as stated in point 1) above.

However even if the the date is calculated by the methodology used by LCC based on the date of service being the second working day after the date of issue/posting, the date provided is incorrect and unlawfully reduces the period of time prescribed in law for payment at the discounted rate by a period of 4 (four) days.

Date of posting of the PCN is Tuesday 18/10/2011, therefore the calculated date of service is Thursday 20/10/20011. This makes the end of the 14 day discount period as Wednesday 02/11/2011 and not Friday 04/11/2011as stated on the PCN by LCC.




Sorry for such a long winded post.
Neil B
I've just realised you've done the same as another appellant.

reps inaccurate - too old referring to a PCN from 2010 -- and it says --- '14 day period unlawfully reduced' - which isn't true -- nor is the 'four days' mentioned.

If you c&p you must pay attention to detail and adapt properly to ALL of the issues that do or don't apply.
Neil B
My post #16 in this thread also eliminates a lot of superfluous stuff from Regs.

http://forums.pepipoo.com/index.php?showto...t=0&start=0

JPSP
Leah - you've quoted your PCN number in the draft response (post#22) - you might want to delete it !!
Enceladus
We have not seen an update for a while so I guess that we are still awaiting a response from Liverpool City Council?
When exactly did you submit your representations and by what means?

If you have not done so, I suggest you send the template letter below to the DVLA.
Other folks who have done so have had interesting results which in the main prove that LCC has been sending out PCNs illegally. So please post up the DVLA response when you get it.

QUOTE (Enceladus @ Fri, 28 Oct 2011 - 03:48) *
Here is the template for the DVLA letter mentioned above.
Just add your name and address and the other required details. (VRN = the registration mark of your vehicle.) Just stick to the text provided, the purpose of the letter is find out when the Council / Enforcement authority asked the DVLA for the RK (Registered Keeper) details and when the DVLA responded.
NB "nn/xxxx/nnnn" means the date of the contravention, not the date of the PCN
Don't forget to sign the letter.

QUOTE
Vehicles Fee Paying Enquiry Section
DVLA
Swansea
SA99 1AJ

Month Day, yyyy
Release of Information,
Fee Paying Enquiries Section,
DVLA,
Swansea
SA99 1AJ.
Dear Sir/Madam,

This letter is not requesting personal information and so is not a Subject Access Request under the Data Protection legislation therefore I believe no fees are involved.

As your records will show I am the Registered Keeper of vehicle index XXXXX.

I require you to send me the dates and times of queries against my VRN XXXXX issued by yyyyy council since nn/xxxx/nnnn. I also require the dates and times of the matching responses that you provided to yyyyy council.

Yours,
etc


The template was provided by member Bama and the original source is to be found here.

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