The Parking Penalty Enforcement Process.

Soon after I emailed the Council parking department I received an email saying that my appeal was rejected. This came from a "Parking Charge Assistant"
Attached to the Email was a file - C0946897 DOC.docx
Now, as it happens I can read docx files, but not everyone can. They should use pdf files and I have advised them of this.
It said

Thank you for your letter recently received. 

On receipt of a Penalty Charge Notice the driver of the vehicle is given a fourteen day period to either pay the reduced rate of the Charge or make an informal appeal, as you have already done with your initial letter.  The appeal is then considered, taking into account all the available information in relation to the contravention and a decision is made.

In this instance, a non-cancellation letter was sent to you on 16 October 2012 in which you were advised that you were able to pay the reduced charge within 14 days of receiving the correspondence or await the Notice to Owner form and make a second appeal.  The Notice to Owner will be sent after the Parking Office has received confirmation of the registered keeper of the vehicle from the DVLA and will be issued after a twenty-eight day period from the issue of the Penalty Charge Notice.

The Notice to Owner form allows you to make a formal appeal, which is then reviewed by another member of the Parking Office staff.  If the appeal is accepted the Penalty Charge Notice will be cancelled and a letter sent to the keeper of the vehicle.  If the appeal is rejected a Notice of Rejection will be sent.  A Notice of Appeal form will be included with this letter in order for you to make an appeal to the Traffic Penalty Tribunal, who are independent adjudicators.  The adjudicator has the final decision on the case. 

 As such, I have noted your comments but am unable to take them into consideration at this time and have added your letter to the case file.

Yours sincerely

I immediately replied

"There really is no need for any DVLA checks as the facts are not in question

Why waste money on a futile exercise?"

 

Now, quite why they need to send a notice to the owner of the Loan car I have no idea (it's the RULE) since they know that the owner was not using the car as I was.
But investigating this it seems to be required by the The Parking Penalty Enforcement Process.
Here it is, a copy came with each of the two penalty rejections

I suggest that since it involves the DVLA and the prvious owner when there is no reason to it is actually unfit for purpose.
Or maybe Portsmouth Parking department are wrong to rely on it.