Re your draft representations, I think these are framed correctly. However, having seen this sort of thing many times before, I suspect Barnet will refuse these by focussing on the absence of any oncoming vehicles. Therefore I'd be tempted to remove reference to oncoming vehicles and just refer to the exemption with respect to other vehicles turning right, as follows. If they then reply saying you are relying on oncoming vehicles, that might open up an additional defence of failing to consider...
Dear Sir / Madam
Re: AG46648067
I am challenging this PCN dated 14/09/2024 on the following grounds:
As per the TSRGD 2016, the prohibition of entering a yellow junction box doesn`t apply to a person who:
(A) Causes a vehicle to enter the box junction for the purpose of turning right;
And
(B) Stops the vehicle within the box junction for so long as the vehicle is prevented from completing the right turn by another vehicle which is stationary whilst waiting to complete a right turn.
To further quote from the Highway Code and the TFL website:
“You must not enter the box until your exit road or lane is clear. HOWEVER, you may enter the box and wait when you want to turn right, and are only stopped from doing so by ... other vehicles waiting to turn right.
Law TSRGD regs 10(1) & 29(2)”
“You can stop in a yellow box junction when turning right if you are prevented from turning by ... other vehicles waiting to turn right”
The video evidence shows that I entered the box junction for the purpose of turning right, and stopped in the box junction only for so long as I was waiting behind another vehicle which was stationary waiting to complete the same right turn onto Regents Park Road. For this reason, I am requesting that this PCN be cancelled.
I look forward to hearing from you.
Yours faithfully,