What did you finally submit?
I sent the following..
I make representations against this PCN on the ground that the contravention did not occur.
The prohibition in law applies only where a vehicle is parked on the carriageway more than 50cm from its edge. The CEO’s photographs and the current traffic order (see attached) show that my vehicle was not on the carriageway but on the paved hard-standing (footway) beyond it, the edge of the carriageway being clearly defined by the raised setts/kerbstones. On that basis, the statutory conditions for this contravention were not met.
In the alternative, even if the authority were to assert that the paved area is part of the carriageway, the vehicle was stationary for less than two minutes solely for unloading purposes. Loading and unloading is a recognised statutory exemption, and the stop was both brief and necessary.
For these reasons, the contravention alleged did not occur and the PCN should be cancelled.
And attached this image..
[ Guests cannot view attachments ]