I'd take a very different approach in this case:
Dear London Borough of Waltham Forest,
I contend that my vehicle was not parked on land that is part of a highway or other road dedicated to public use. There are what appear to be private parkings bays marked on the footpath, which suggest this land has been reserved by the landowner for the parking of vehicles. This being the case, the land cannot be an adopted part of the highway, nor is there any evidence that members of the public may pass and re-pass as of right, let alone is there any evidence that they actually do so.
On the contrary, there is a sign adjacent to the parking bay that says "Artplinths | No Parking", this suggests that the occupiers of this land have reserved the use of this land for their own private use.
The Google Street View images for this location show that on every occasion over the past 10 years when images of this location have been captured, this land has been occupied by a combination of road-going motor vehicles, off-road vehicles such as fork-lift trucks, trolleys, building materials, pallets of goods, debris, commercial waste, private bins, logs, barriers, and on one occasion there was even a wardrobe.
If this land were part of the highway or some other road to which the public have an unimpeded right of access, this could not be happening: a pavement licence would not allow a business to deposit all manner of objects in such a manner on the highway as they see fit, and if this were unauthorised use of highway land it is inconceivable that the council would not have taken enforcement action many years ago to stop what would be an ongoing and unlawful obstruction of the highway. The fact that the occupiers of this land have felt entitled to draw their own private parking bays suggests very much that the reason for all this is that the land in question is not part of the highway at all, a view supported by the High Court decision in Pereira, R (On the Application Of) v Environment And Traffic Adjudicators [2020] EWHC 811 (Admin).
I would suggest the true boundary between the road and the land reserved for private use is shown by the red line in the attached image, which would be consistent with the boundary between the private land at 51 to 64 Argall Avenue which is also shown to be routinely filled with all manner of property inconsistent with that land forming part of the road.
If I am wrong about the above and the footway parking bay has been installed by the council, please would you supply a copy of the resolution duly made under section 15(4) of the Greater London Council (General Powers) Act 1974.
Yours faithfully,
Obviously the council won't understand any of this, but it's laying the foundations for the tribunal appeal.
