Careful consideration? - not apparent.
The paragraph starting 'A PCN was issued' - is irrelevant.
The first six lines of the next paragraph are also irrelevant.
The bold type or emphasis would not be necessary if the irrelevant material wasn't there. This is just lazy cut and paste.
The argument put forward was not 'mitigation' but a head on challenge to the lawfulness of any PCN after the first one.
An 'appropriate response' has not been sent as the question of 'continuous contravention' has not been mentioned or possibly even thought about.
If Brent Council send the same non-reply at the next stage, the Notices to Owner, against which identical challenges will be made, it will be off to the tribunal which has previously considered this argument presented by Mr Mustard and agreed with him and here is one such decision (not a precedent but likely to be persuasive)
Yours frugally
Mr Mustard



