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Absolutely, which is why the TMA excluded on-street obstruction because the exercise of subjective opinion requires training and is best left with the police. But they did introduce the '50 cm' contravention to help councils deal with this form of parking(double parking), particularly near sports grounds.

Fine, but that's the whole point, surely ? The car is not parked in a car park but on-street.

They are in a muddle.

They note the point about terms but then say you should know what they are without anything telling you what they are.

They note the area is wide but it's still obstruction...

They say it's off road but parking rules that apply to a road apply here as per the Highway Code - this is bonkers.

See what others say but I think I'd take it to the tribunal.

Just bumping this if anyone else has anything to add

What will be a more suitable grounds to appeal on?

The contravention did not occur.

Or

The traffic order allegedly contravened is invalid.

While the informal and formal reps argued that no contravention had occured, if I understand correctly, then the latter can be argued for as well as the contravention was for an off-street restriction yet I was parked in an on-street permit zone, therefore rendering it invalid.

Unless I am conflating 'traffic orders' with 'contraventions' that the council can use as the grounds for issuing a PCN.

Have you seen the Traffic Order?

post your intended appeal before you send it.

As I said you don't have to construct an appeal now - you can just register the appeal, and the date could be months away.

I think one of the grounds is procedural impropriety - they are trying to enforce an off-street contravention where no terms are posted while referencing on-street obstruction, and the only sign is an on-street permit sign.

Okay...

I registered the appeal, in the section where you can write your appeal, I just put a marker so as to update it later, but it seems to accept that as the final word. I was under the assumption I can edit this later as per your message, but it seems like I can't, unless I am missing something...