I received a joke of a response to my informal representation, below, followed by my notice to owner a bit after. Any advice on anything in particular to include in formal representations?
Thank you for your informal representation regarding the above Penalty Charge Notice (PCN).
Transport for London (TfL) acknowledge the comments raised within your representation stating that as seen in the image
provided, the vehicle was parked in a marked parking bay, similar to the other vehicles parked along this stretch. Although,
the painted lines are very faded. Furthermore given this, you believe there was no contravention.
We issued the PCN because your vehicle was observed parked with one or more wheels on or over a footpath or any part
of a road other than a carriageway on the date and time of contravention at the above location. The Highway Code item 244
states that a vehicle "MUST NOT park partially or wholly on the pavement in London, and should not do so elsewhere
unless signs permit it. Parking on the pavement can obstruct and seriously inconvenience pedestrians, people in
wheelchairs or with visual impairments and people with prams or pushchairs". Parking on the pavement or verge is
therefore potentially dangerous to pedestrians, and could potentially cause damage to pipes and cables housed under the
paving stones. In the few locations where parking on the pavement is allowed, it is clearly indicated by signs and road
markings. There is no signage or road marking in place at the above location indicating that parking in this manner is
permitted.
It is the legal responsibility of every road user and business operator to identify all the traffic laws that must be complied
with, and to then comply. The relief of congestion and the improvement of traffic flows are of strategic importance to
London. The red routes are by definition roads that are particularly sensitive to the disruptive effect of illegal stopping. As
the Highway Authority with the responsibility for the performance of the red route network, TfL places a very high priority on
achieving full compliance with the restrictions and expects every road user to plan and operate their road use fully within the
law at all times.
The Civil Enforcement Officer (CEO) in this case is considered by Transport for London (TfL) as a credible witness. The
Officer is employed by the Metropolitan Police Service (MPS) as a CEO and was acting on behalf of TfL in enforcing the red
route regulations.
We have considered your informal representation. However we do not consider you have established grounds or suitable
reasons for the Penalty Charge to be cancelled.