I was the representative in that case. I will draft something in a minute or so. I cannot access the documents via dropbox; but....
Dear Council
I make this formal representation against PCN :
The contravention did not occur as:
1. You have failed to carry out your responsibilities under LATOR to maintain the signage and curb the growth of the vegetation which renders the advanced signage invisible.
2. Similarly,the plate on the left hand right hand sign is covered by foliage.
In light of the above, please take the eminently sensible course of action and cancel the said PCN.
Yours faithfully
Reg. keeper
Address
******
I would not cite the case v WF as it is not relevant at this stage.
Isn't the obscured entry sign on the right-hand side ?
Sorry you are correct. I have fixed it.
*****
Re the WF case won on Wednesday, this was part of the submissions to the Tribunal:
TSM Chapter One
1.3.2. In order to achieve safe and efficient operation of a highway network, it is essential that all signing provided is necessary, clear and unambiguous, and gives its message to road users at the appropriate time. The message must be quickly and easily understood at the point it is needed; neither too soon that the information might be forgotten, nor too late for the safe performance of any necessary manoeuvre.
TSM Chapter Three
1.8.6. There are likely to be some situations where two signs will still be preferable, such as on the side road at junctions, and where obstruction of a sign by other vehicles is possible. Drivers should not be placed in the situation where they might not see the sign before starting to turn at a road junction.