I would mention the de minimis intrusion into the bus lane. If you get to London Tribunals, one always fires all one's ammunition.
How’s this for a draft (thank you AI!), please let me know what you guys think!
To Whom It May Concern,
I am writing to formally appeal against Penalty Charge Notice [PCN NUMBER], issued in respect of vehicle [REGISTRATION], for the alleged contravention of ‘being in a bus lane’ on Cambridge Heath Road on [DATE].
I respectfully submit this appeal on the following grounds:
1. DE MINIMIS
Having reviewed the council’s own enforcement video, it is evident that my vehicle was present within the bus lane for no more than approximately 7–10 metres, and at no point fully within it. Upon realising I had inadvertently drifted into the bus lane, I moved back into the traffic lane as promptly as was safely practicable, having first checked for vehicles to my right.
The intrusion was momentary, minor, and immediately self-corrected. I submit that such a brief and negligible incursion should properly be regarded as de minimis, and that issuing a full Penalty Charge Notice in these circumstances is disproportionate and unreasonable.
2. INADEQUATE SIGNAGE / INSUFFICIENT EVIDENCE OF CONTRAVENTION
I further draw the council’s attention to the fact that the enforcement video submitted in support of this PCN does not clearly show a sign to diagram 959 in a manner sufficient to establish that the contravention occurred. The standard of proof required to sustain a Penalty Charge Notice has therefore not been met.
For the above reasons, I respectfully request that this Penalty Charge Notice be cancelled in full.
Yours faithfully,