Ok, so you shouldn't have any problem getting this PCN cancelled, (hopefully !!). The relevant information on the sticker should be quoted, plus include a photo of the sticker.
Opinions on this draft?
Re: Penalty Charge Notice GX36837978
Vehicle Registration: WP19 NLD
I make these representations on the ground that the alleged contravention did not occur.
At the time of the alleged contravention, I was working as a
Transport for London licensed Private Hire Vehicle (PHV) driver, undertaking a genuine pre-booked Uber journey. I had accepted a booking to collect a passenger at this location at approximately
07:35 on 7 June 2026. A copy of the Uber trip details is enclosed in support of these representations.
The vehicle concerned is a
TfL-licensed Private Hire Vehicle, and I was the licensed private hire driver operating it at the time. The vehicle displays the official
TfL PHV licence discs/stickers that were issued and affixed as part of the TfL licensing and inspection process. These are fitted to the inside of the front and rear windows, as required by TfL. However, due to the stickers being mounted behind the glass and the vehicle having tinted rear windows, they may not be readily visible from a remotely positioned CCTV enforcement camera. To avoid any doubt, I enclose copies of the vehicle's PHV licence, my TfL Private Hire Driver Licence, and photographs showing the official TfL licence stickers displayed on the vehicle.
The CCTV evidence shows my vehicle stopped for only around
34 seconds, with the brake lights illuminated throughout. This is entirely consistent with a driver stopping briefly for the purpose of collecting a passenger. The vehicle was not parked, unattended or left for any prolonged period.
The location is a marked white bay with a sign stating
"Red Route – 2 mins – Pick up or Set down only." The sole purpose of my stop was to collect my pre-booked passenger, which is exactly the activity the bay is intended to facilitate.
Furthermore, the road markings at this location do not adequately convey the restriction. There are
no visible double red lines within the white bay where my vehicle stopped. A reasonable motorist would understand a marked white bay, together with a sign expressly permitting stopping for passenger pick-up or set-down, to be a permitted stopping place. If TfL intends to impose additional restrictions within that bay, those restrictions must be clearly indicated by the prescribed road markings.
The courts have confirmed that traffic restrictions must be adequately conveyed to motorists. In
Herron v Sunderland City Council [2011] UKSC 2, the Supreme Court held that road signs and markings must substantially comply with the statutory requirements so that a reasonably diligent motorist is properly informed of the restriction. In this case, the absence of visible double red lines within the bay means the restriction was not adequately communicated.
The CCTV evidence also fails to demonstrate that any contravention occurred. The still images merely show a vehicle stopped for approximately 34 seconds within a designated pick-up/set-down bay. They do not establish that the stop exceeded the permitted period, that the vehicle was parked, or that it was being used for any purpose other than collecting a passenger in connection with a pre-booked private hire journey.
In light of the evidence provided, namely:
- the Uber booking confirming a genuine pre-booked passenger collection;
- confirmation that the vehicle and driver were both licensed by Transport for London as a Private Hire Vehicle and Private Hire Driver;
- the very short duration of the stop;
- the vehicle being positioned within the designated pick-up/set-down bay;
- the absence of visible double red route markings within the bay; and
- the failure of the evidence to establish that the restriction was adequately conveyed or that any applicable exemption did not apply,
I respectfully request that Transport for London cancel this Penalty Charge Notice.
Should TfL decide not to cancel the notice, please provide:
- A copy of the full CCTV recording relied upon, rather than still photographs.
- A copy of the relevant Traffic Management Order governing this bay.
- Confirmation of the exemption(s) considered during your assessment.
- An explanation of why the evidence of a genuine pre-booked passenger collection by a licensed TfL Private Hire Vehicle has been rejected.
I trust that, upon reviewing the enclosed evidence, you will conclude that no contravention occurred and that this Penalty Charge Notice should be cancelled.
