Perhaps...
This is a response of the worst kind, I'd carry on.
Procedural impropriety;
Contravention did not occur.
The contravention grounds in the PCN are given as:
Parked or loading/unloading in a restricted street where waiting and loading/unloading restrictions are in force.
However, in response the NOR states that:
1. According to the CEO's notes this vehicle was issued with a PCN for being parked in a loading bay without loading/unloading.
It also states that:
2. According to the [same CEO's] notes the vehicle was issued with a PCN because the vehicle was parked where a loading ban was in force.
As these comments are mutually exclusive, it is impossible for the recipient to know which, if either, applies. Having said this:
If 1 applies, then this does not relate to the actual grounds in the PCN and therefore is a clear procedural impropriety.
But if 2 applies this similarly does not refer to the grounds of contravention which requires that both waiting and loading restrictions are in place and not simply a location where solely a 'loading ban was in force'.
Having given these incoherent references to the grounds of contravention and contents of the CEO's notes, the NOR then fails to show that the authority has given my detailed representations consideration, instead these are dismissed as follows:
Whilst I appreciate your circumstances, they do not warrant cancellation of the PCN.
In addition to these procedural improprieties, I would also refer the adjudicator to my original representations regarding the CEO's photographic evidence which confirms the absence of compliant lines, including kerb markings, which is reinforced by the CEO's photo of an 'At any time' loading sign whose use is redundant because were the markings clear then no such sign is required for 'double blips' and if the CEO believed that only single blips were in situ then this sign is unauthorised and unenforceable by virtue of not specifying the restricted hours. It is also in a different road.
