This is my planned response (a little help from AI):
Westminster Parking Services
PO Box 351
Sheffield S98 1TU
6 July 2026
FORMAL REPRESENTATIONS AGAINST PENALTY CHARGE NOTICE WE6712817A
Vehicle registration: SH16KRX
Contravention: Code 31J — entering and stopping in a box junction when prohibited
Location: Piccadilly – Dover Street – Arlington Street
Date/time: 28 June 2026, 11:05
Dear Sir or Madam,
I am the registered keeper and driver of the above vehicle. I make formal representations against this PCN on the ground that the alleged contravention did not occur. In the alternative, I invite the Council to cancel the PCN in the exercise of its discretion.
1. The contravention did not occur – obstructed sightlines and Council’s own works made compliance impossible
1.1 I was turning left from Arlington Street onto Piccadilly (westbound). Full-height construction hoarding on the western corner (associated with the Ritz Hotel refurbishment) runs flush to the kerb and completely obstructs any view west along Piccadilly from the Give Way line. The westbound exit only becomes visible once a driver has committed to the turn and is already on or over the box markings, which begin immediately at the junction mouth.
1.2 The video evidence supplied does not show my vehicle crossing the white Give Way line, nor the state of the exit at the critical moment of commitment. This is a fundamental evidential gap.
1.3 At the material time, the nearside westbound lane of Piccadilly immediately west of the junction was closed due to the same works. This forced left-turning traffic into a wider line and merged two lanes into one at the exit, compressing the queue. The Council licensed the hoarding and permitted the lane closure; it therefore created the very conditions that prevented a proper assessment of the exit. I attach photographs taken on 4 July 2026 (Exhibit 1) and reports confirming the works and lane closure were in place well before and after 28 June 2026 (Exhibits 2 and 3). The Council is asked to disclose the relevant street works permits and traffic management plans for this location on the date in question.
2. The CCTV evidence does not prove the contravention
2.1 Under TSRGD 2016 Schedule 9 Part 7 para 11, the prohibition only applies where a driver causes their vehicle to enter the box so that it has to stop due to the presence of stationary vehicles.
2.2 The supplied CCTV runs from 11:05:15 to 11:05:39. The approach to, and crossing of, the Give Way line is not shown.
2.3 Key timeline from the footage:
At approximately 11:05:19 I entered the yellow box, with traffic (including vehicles ahead and a van in the right lane) still moving.
At 11:05:21 the car immediately ahead of me stopped suddenly (now clear of the box).
I was forced to stop mid-turn within the box and remained stationary until the end of the clip.
This shows I entered when the exit appeared to be flowing and was only forced to stop by the unexpected action of a single vehicle ahead, not by a pre-existing stationary queue. The footage is consistent with a driver exercising reasonable care who was caught by a sudden stop after commitment.
2.4 I request disclosure of the full unedited footage (minimum 60 seconds before and after the served clip) and all other evidence relied upon.
3. Discretion should be exercised in any event
3.1 The junction was heavily congested in all directions due to the Council’s own lane closure and works. A second vehicle (light van) was also trapped on the markings. My vehicle caused no additional obstruction and cleared the junction as soon as traffic permitted.
3.2 The Council has been aware since at least May 2026 that this closure was causing systematic difficulties and PCN issuance for left turns out of Arlington Street (see Exhibits 2 and 3). Enforcing the box in these circumstances does not advance the purpose of the markings.
Conclusion
The contravention did not occur because of the physical impossibility of assessing the exit (due to the Council’s hoarding and lane closure) and because the evidence shows I entered with moving traffic ahead and was only stopped by an unexpected single-vehicle stop. In any event, the PCN should be cancelled on discretionary grounds.
If these representations are rejected, please issue a Notice of Rejection with appeal rights to the Environment and Traffic Adjudicators, disclose the full footage, and confirm the discounted rate will be held for 14 days from the date of the Notice of Rejection.
Yours faithfully,
Schedule of Exhibits
Exhibit 1 — Photographs: the Ritz Hotel works hoarding on the western side of Arlington Street; the driver's-eye view from the Arlington Street approach showing the obstructed western sightline; and temporary lane-closure signage displayed at the junction (photographed 4 July 2026; permanent features only — traffic conditions on that date differed)
Exhibit 2 — Social media post dated 10 May 2026 reporting heavy enforcement of left turns out of Arlington Street and the effect of the closed lane
Exhibit 3 — Taxi-Point trade press article reporting the same
London taxi drivers are being warned over increased enforcement at the box junction connecting Piccadilly and Arlington Street in Westminster, following reports of a rise in penalty charge notices ...
