this was my challange letter
To: Parking & Enforcement Representations Department
London Borough of Hillingdon
16/8/2026]
CHALLENGE AGAINST FIXED PENALTY NOTICE (FPN)
FPN Reference Number: LH102092574
Vehicle Registration Mark (VRM): SL19VHE
Date of Alleged Offence: 03/08/2026
Location: Harmondsworth Lane (at the roundabout junction)
Dear Sir / Madam,
I am writing to formally challenge the issuance of the above-referenced Fixed Penalty Notice (FPN), which alleges a breach of a Public Spaces Protection Order (PSPO) on Harmondsworth Lane. I request that this FPN be cancelled immediately due to fundamental statutory non-compliance, physically defective infrastructure, active misdirection, and an inadequate signage layout which completely invalidates any lawful enforcement.
My challenge is based on the following strict technical and legal grounds:
1. Fundamental Failure to Declare a Criminal Order (Breach of Regulation 2)
The signage deployed by the council on Harmondsworth Lane fails the strict statutory test set out under Regulation 2(1)(a) of The Anti-social Behaviour, Crime and Policing Act 2014 (Publication of Public Spaces Protection Orders) Regulations 2014. The regulations mandate that physical notices must explicitly state "the fact that a public spaces protection order has been made." [1]
The physical signs present on Harmondsworth Lane completely omit any reference to a "PSPO", an "Order", or its statutory criminal framework, stating only "No PHV, Taxi and Chauffeur Waiting". A PSPO carries criminal penalties, yet by masking a specialized criminal order as a standard civil traffic restriction, the council has failed to publicise the legal nature and "effect" of the restriction. A motorist cannot be penalized under a hidden order where the word "PSPO" is entirely absent from the physical signage face.
2. Physically Defective and Twisted Signage (No Legal Notice on Entry)
At the immediate busy roundabout junction where entry is made onto Harmondsworth Lane, the primary restrictive sign face was physically twisted on its lamppost fixture. It was turned completely away from the line of sight of entering traffic, making it exclusively visible to vehicles that were already leaving the lane.
I have attached clear, date-and-time-stamped photographic evidence verifying that the sign was structurally rotated away from the junction approach. The Enforcement Officer’s claim that I "should have seen it" is factually and legally incorrect. Under established UK road traffic precedent, a motorist cannot be held strictly liable for an infraction if the physical infrastructure fails to provide an unambiguous, readable warning upon entry. Navigating a busy roundabout requires a driver's full visual attention on immediate hazards and traffic to the right; it is entirely unreasonable to expect a motorist to read a twisted sign facing the opposite direction.
3. Inadequate Positioning (Unilateral Layout and Lack of Repeaters over 1.1 Miles)
The comprehensive thoroughfare network spanning Sipson Lane through to Harmondsworth Lane is an extensive corridor measuring approximately 1.1 miles. The council has failed in its statutory duty under Section 72 of the 2014 Act to ensure notices are positioned "sufficient to draw the attention of any member of the public using that place" due to two structural design failures:
• No Valid Repeater Network: There is a total absence of continuous, compliant repeater signage across this 1.1-mile stretch. A driver cannot reasonably be expected to maintain awareness of a localized restriction over a mile long without regular reminders.
• Single-Sided Repeater Signage: The few signage plates present are situated exclusively on one side of the road. On a busy thoroughfare near Heathrow Airport, unilateral signage is easily obscured by preceding or oncoming traffic, airport delivery vehicles, and local buses, rendering them entirely invisible to motorists.
For enforcement of a criminal order to be lawful, signage must be transparent, statutory, and uniformly prominent. The combination of masking the PSPO identity, a physically twisted entry sign, displaying conflicting text at the entry point, a lack of consistent repeaters over a 1.1-mile road, and single-sided placement means the council has failed its statutory obligations.
If the council refuses to cancel this ticket, I formally request that you provide:
1. The official Signage Placement Plan and maintenance log for this specific PSPO zone.
2. The legal justification for omitting the statutory phrase "PSPO" from the physical signage face.
I look forward to your swift confirmation that this FPN has been cancelled.
Yours faithfully,
this is thee reply
Thank you for your challenge in relation to the above Fixed Penalty Notice (FPN).
Further to your enquiry concerning the FPN that was issued to you on the 03/08/2026 the matter has
been reviewed with due care and consideration and it is believed that the FPN was issued correctly.
As of 1 February 2025, the London Borough of Hillingdon implemented a Public Spaces Protection Order
(PSPO) prohibiting taxis, private hire vehicles, and chauffeur-driven vehicles from waiting in residential
streets in the wards of Pinkwell, West Drayton, and Heathrow Villages, unless actively collecting or
dropping off passengers in those streets or if the driver resides there. This measure was introduced
following a public consultation that highlighted significant support for reducing nuisances such as littering,
noise, and parking issues caused by waiting vehicles.
Even in areas where parking signs are present, the PSPO’s restrictions take precedence for taxis and
private hire vehicles. The order specifically prohibits waiting in the designated areas to address the
concerns raised by residents.
The council undertook extensive public consultations and disseminated information about the PSPO prior
to its enforcement date. As a professional driver operating in the area, it is important to stay informed
about local regulations affecting your operations.
The council has ensured that appropriate signage is in place to inform drivers of the restrictions. While we
strive to maintain clear and visible signs, the absence or perceived inadequacy of signage does not
exempt drivers from adhering to the PSPO.
Please see the link attached pspo-2025-appendix-1-pspo-phv-and-taxi-order
Furthermore, it is not a legal requirement for signage to explicitly state that the restriction is imposed
under a PSPO.
More information can be found on the Hillingdon Council website.
The FPN issued to you serves as an administrative alternative to prosecution for minor offences. There
are no formal grounds for appeal if you're issued with an FPN. The legislation that governs fixed penalty
notices means that a person who receives an FPN can challenge it in court if they believe the penalty
should not have been issued to them. By paying the fine, you discharge your liability without the need for
court proceedings.
Please follow the below link to make payment,