@Johnathorn I think we can come up with something, here's a draft representation:
Dear London Borough of Waltham Forest,
In the first instance I challenge liability on the grounds of procedural impropriety. The penalty charge notice is required to state the grounds on which the authority believes the penalty is payable, and this includes adequate particulars of where the alleged contravention is said to have taken place. Lea Bridge Road is circa 3.2 miles long and as far as I can establish there are approximately 30 bus stops along its length, the penalty charge notice served in this instance gives no indication of where the relevant bus stop might be either by giving its identifier, or by reference to any nearby landmarks or junctions.
As such it is not possible for me to return to the location to investigate the adequacy of the signage, the road layout or any other relevant matters, I refer you to the decision of adjudicator Jack Walsh in Sofiane Kherbachi v London Borough of Redbridge (2230412198, 18 November 2023) and adjudicator Anita Reece in Nayeem Haque v London Borough of Redbridge (224017240A, 20 May 2024).
While I appreciate first instance decisions are not binding, I cannot see any reason why the tribunal would reach a different conclusion on this occasion.
Yours faithfully,
In the meantime I'll make some enquiries about the camera make and model, there is also a novel argument about the signage which I could try, more on this later.
Send the representation online and keep a screenshot of the confirmation page.
