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Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: ticketed_off on March 31, 2024, 05:29:31 pm

Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on October 15, 2024, 12:14:02 am
I hate to bump an old thread, but just to clear up any speculation (there was some previously whether the authority may still choose to send a Charge Notice) and to provide closure to this thread/contribute to the hivemind for anyone searching for the exact same contravention in future, no further correspondence was received from Newham Council after my representations, so I assume the PCN was fully cancelled.

As ever, thanks to the wizards (primarily to the legendary CP!!) and also perhaps, an interesting example of the use of informal reps to cancel a manifestly wrong PCN (vs taking it as a given they will fail).
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on June 12, 2024, 09:56:52 pm
@ticketed_off here are:

The Newham (Waiting and Loading Restriction) (Amendment No. 111) Order 2017 (https://drive.google.com/file/d/1SFzh2xdiefyOEhVYiLKxVlxiQODQExFf/view)
The Newham (Royal Docks East) (Parking Places) (No. 1) Order 2017 (https://drive.google.com/file/d/1wOJUr7GPVW5oHtCPu4HiGfmZCdhSCFL8/view)
The Newham (Royal Docks East) (Disabled Resident Parking Places) (No. 1) Order 2017 (https://drive.google.com/file/d/1GCl2bozlmZzrJafN7qbLJwBEZdC3aAsW/view)
The Newham (Parking Places) (Car Clubs) (No. 1, 2007) (Amendment No. 12) Order 2017 (https://drive.google.com/file/d/1MM8QQagTFBbwyjWQifiouKkfRO8t_VI-/view)
The Newham (Free Parking Places) (Disabled Persons) (No. 1, 2011) (Amendment No. 38) Order 2017 (https://drive.google.com/file/d/1x4fy8g6qhvzPYV7TwUfseIfMa1Dj7Qvb/view)
The Newham (Parking Places) (Any Controlled Parking Zone Permit) (No. 1, 2016) (Amendment No. 7) Order 2017 (https://drive.google.com/file/d/1l_z1Q7JC2ju6FI3qdtwJzKYsv38pXKMm/view)
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on May 31, 2024, 10:47:21 pm
Fingers crossed! Absent any letter I'm not sure yet if it's set to 0.00 as it's on hold, or has just been cancelled. I wouldn't have thought they'd set it to £0 during informal reps in case someone had a change of heart and wanted to pay?
No, if someone pays while a challenge is outstanding they throw the challenge in the bin and laugh all the way to the bank.

If you can post or send any response to the orders you requested if you get one that'd be much appreciated - not least for my own interest!
Sure thing.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on May 28, 2024, 01:30:46 pm
(https://i.imgur.com/46QxQtU.png)
Result, they must have realised the traffic order doesn't exist!

Fingers crossed! Absent any letter I'm not sure yet if it's set to 0.00 as it's on hold, or has just been cancelled. I wouldn't have thought they'd set it to £0 during informal reps in case someone had a change of heart and wanted to pay?

As ever will update you all when I hear more. Thanks so much for all the help so far.

If you can post or send any response to the orders you requested if you get one that'd be much appreciated - not least for my own interest!
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on May 27, 2024, 11:48:40 pm
(https://i.imgur.com/46QxQtU.png)
Result, they must have realised the traffic order doesn't exist!
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: Incandescent on May 27, 2024, 05:40:51 pm
The 56 days is a limit for a council to respond to formal reps against a postal PCN, or a Notice to Owner, both issued under the Traffic Management Act 2004. A postal PCN is essentially also an NtO, because it is sent to the name and address on the V5 for the vehicle.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on May 27, 2024, 02:54:54 pm
Today is, by my count, the 56th day since I submitted these informal reps. I have not yet received anything except the confirmation e-mail (which promised a response within 56 days), or anything in the post. The confirmation email stated the below which implied a 56 day turnaround even in the case of informal reps:

Quote
Thank you for your representation, which has been allocated to the above Penalty Charge Notice. The case is now on hold until a response is sent to you either by email (if an email address has been provided) or by post.

Where a PCN is issued under the Traffic Management Act (TMA) 2004, the council will respond to your challenge within 56 days of the date it was received.

If you challenge your penalty charge notice within 14 days from the date of service of the notice, known as an informal challenge, where the notice was placed on the vehicle or handed to the driver. Then it will then be held at the reduced rate and a further 14 days will be given, from the date of our correspondence, to pay at the reduced rate if your challenge is not accepted.

Any PCNs issued by a camera, such as bus lanes, no entry restrictions, motor vehicle restriction zones, pedestrian zones in pursuant to the Road Traffic Regulations Act 1984 (as amended), London Local Authorities 1996 and Transport for London Act 2003 will be responded to as soon as possible. There is no corresponding provision within the Acts relating to bus lane and moving traffic contraventions which require that an Enforcement Authority must respond within a statutory time limit.

As today is a Public Holiday I am not expecting to receive anything (although not entirely ruling it out).

I am trying to decide whether they have just decided to accept the reps and not engage with me any further, or whether I should expect to hear something out of time (as I understand the 56 days isnt a hard limit?). Would it be possible they have done the former or would they always send a letter of rejection, even to informal reps?

Edit: I have reviewed the PCN online and it shows the below under 'View PCN':

(https://i.imgur.com/46QxQtU.png)
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on May 15, 2024, 12:35:35 am
I'll get hold of the orders mentioned in that gazette announcement.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on May 08, 2024, 02:53:22 pm
From some research (thanks CP for info on how to search the Gazette) it seems they at least gave notice that they had made an order on 15 May 2017 - https://www.thegazette.co.uk/notice/2785273 that would seem to cover the area in question, but I am unable to find the full text of the order anywhere online. Still no reply to my reps.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on May 03, 2024, 09:00:09 pm
Thanks gents, so to be clear, there is presumably no legal basis by which vehicles can be issued with a PCN or removed from this road purely for being in contravention of the purported control?? Is there any alternative legal mechanism they could claim to be exercising this power under?
If the traffic order doesn't exist then it doesn't exist. In the past where councils have rejected representations despite the lack of a traffic order being raised in the formal representations, the tribunal has held this to be wholly unreasonable and has made a costs order against the council.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on May 02, 2024, 11:49:20 pm
Thanks gents, so to be clear, there is presumably no legal basis by which vehicles can be issued with a PCN or removed from this road purely for being in contravention of the purported control?? Is there any alternative legal mechanism they could claim to be exercising this power under?
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: Incandescent on April 30, 2024, 09:13:34 pm
You couldn't make it up, really !

Actually, knowing how bovinely stupid councils are, you can !!!
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on April 30, 2024, 06:09:54 pm
It gets better:

(https://i.imgur.com/9ieewyZ.png)

(https://i.imgur.com/hN50pVA.png)
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on April 01, 2024, 08:16:12 pm
Glad you see my logic - I'll send later tonight or tomorrow.

I've just revisited the site in passing and although light was too dim to get a photograph (and not sure if that is relevant) absolutely no bay markings were visible, at all (far deteriorated from GSV). At most the odd fleck of white.

I'll update when I hear anything back. Thanks so much again.

Representations submitted - response due by 27 May 2024.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on April 01, 2024, 05:05:55 pm
What you say makes a lot of sense and the other consideration is that if the council are confronted with the argument and simply prove obtuse, you might be able to get a costs order against them.

Send the modified draft and let's see what comes back. Don't forget to screenshot the confirmation page.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on April 01, 2024, 04:39:24 pm
Well, I don't have any intention of paying at any stage from what I have seen of their case so far!

One point before I send:

The fact they will probably not read my informal representations aside, on reflection I'd be more comfortable being a little more direct that my argument is rooted in the lack of the required road markings, vs leaving that for them to figure out. If this goes to Tribunal and I win, I don't just want to leave it at that - I'd like to lobby Councillors on Newham's gung-ho attitude to parking enforcement in the neighbourhood. I think that is more effective if I showed I engaged positively and tried to shut the matter down early (vs just put them to proof) and this was ignored. As a matter of personal style I also think this makes me look more reasonable in front of an Adjudicator and vice versa, Newham less so.

There is also part of me that would rather the PCN went away (even if a Tribunal victory would be enjoyable, I'd obviously prefer to avoid the case progressing any further if possible) and it seems that unless they are genuinely not reading any of the informal representations that there is still some slightly increased chance (even if this is still highly unlikely) that the below might lead someone to see sense.

What about:

Quote
Dear London Borough of Newham,

Having viewed the photos taken by the civil enforcement officer I do not believe that you can evidence a contravention, as there are no road markings shown indicating parking controls on the point the vehicle is stopped. It would appear the PCN must have been issued in error. I trust you will arrange for its prompt cancellation.

Yours faithfully

Ultimately though, defeating the PCN is obviously more important to me than the ability to complain about Newham's policies through local politics or seeming like a 'reasonable guy'. Would my latest proposed representation be likely to reduce my chances/options at Adjudication? If so I'll go with what's you proposed cp8759.

Thanks again for the advice to me and so many others on this forum which is highly appreciated.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on April 01, 2024, 01:28:31 pm
I hope you have no intention of ultimately paying at any stage!

Yes you might as well get the representations sent off now.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on April 01, 2024, 01:20:27 pm
Thanks, fair enough!  :)

I presume there is no point in waiting any longer to send informal reps if I have no intention of ultimately paying at this stage?

I'm likely to move house within the next 6 months so I'd rather any NtO came sooner rather than later.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on April 01, 2024, 01:15:39 pm
You're making the mistake of thinking that someone from the council with at least an average IQ is going to sit down and give your representations proper consideration, that is not the case. Virtually all informal representations result in a fob-off letter and your representations will likely only be skim-read, if read at all.

I would also avoid making any self-incriminating statements or admissions, here's what I would suggest:

Dear London Borough of Newham,

Having viewed the photos taken by the civil enforcement officer I cannot see any prima-facie evidence of any contravention, so it would appear the PCN must have been issued in error. I trust you will arrange for its prompt cancellation.

Yours faithfully

Of course they'll reject, but we want to put the burden on them of spelling out why they think a penalty is payable.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on April 01, 2024, 12:58:36 pm
Thanks both for your responses. How's the below - edits are to prevent this being indexed on Google but the full details remain in the images. The sections in lime green are optional and don't add to making the key point (as well as open up an angle of CEO incompetence/malpractice) so I don't know if that would be helpful or a hindrance in terms of maximising the chances of an early disposal?

Grateful for any thoughts.

Quote
Dear Sir/Madam,

I write with reference to PCN**** issued to my vehicle ****** on Albert Road on 31 March, 2023. I wish to make representations regarding this PCN, which are set out below.

I parked in the location specified because I had been of the understanding that Easter Sunday is a Public Holiday, and that therefore, permit and shared use bays within Controlled Parking Zones are not enforced. I now understand this not to be the case. Regardless, my first representation is the fact that enforcement continues on Easter Sunday is not clear from your website, which does not make clear what is defined as a Bank holiday and Public holiday (GOV.UK only lists Bank Holidays - your additional reference to un-referenced Public Holidays therefore creates ambiguity). Given this was a genuine mistake, I would like you to consider cancelling the PCN as a gesture of goodwill and mutual understanding.

Having looked into this matter in more detail, I wish to make a second representation, which is that in the event, I do not believe that Newham Council is able to properly enforce the purported parking controls at the specific location in question. From review of your CEO's evidence, there is no visible white bay marking where the vehicle is parked, and the impression could therefore be given that a controlled parking bay does not exist at that location. Given the absence of the required markings, I do not consider that Residents Parking controls should have been subject to enforcement at this location. This inadequate marking must have been clear to your CEO who proceeded to issue the PCN regardless. I consider the PCN is not enforceable and therefore your CEO could not, if they were acting properly, have had reasonable cause to believe a PCN was payable given the clearly defective road markings.

I would ask that my representations are reviewed and that the PCN is cancelled as it was issued as a result of genuine error on my part, and ultimately, it also does not seem to be legally enforceable.

I have no experience of these tribunals but am a seasoned letter-writer/complainer (including against said Council previously!) so am happy to pursue this one if there is a good prospect of success - all of this advice is much appreciated. I am not sure (and am unable to gather from reading other threads) whether it is likely to help or hinder if I volunteer that I thought controls did not apply on that day (which is why I parked) or whether I should say less and more narrowly build the argument on the lines not being properly in place.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: cp8759 on April 01, 2024, 02:40:22 am
I agree with Incandescent, there is no prima-facie evidence of a contravention:

(https://i.imgur.com/q33MhpT.jpeg)

(https://i.imgur.com/3VLbdmF.jpeg)

(https://i.imgur.com/x860lRA.jpeg)

(https://i.imgur.com/1RCMvrW.jpeg)

(https://i.imgur.com/adSjy14.jpeg)

(https://i.imgur.com/8iS8NHq.jpeg)

(https://i.imgur.com/agm8eba.jpeg)

As long as the case is argued properly it's hard to see how you could possibly lose this.

Draft up an informal representation and post it on here for review please, in the meantime I'll get hold of the traffic order.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: Incandescent on April 01, 2024, 12:41:49 am
This is an absolutely disgraceful PCN; the bay markings are totally absent ! If you had parked at the other end, after the "Scarab" truck in your GSV view, why would you think you need to go and see a bay restriction sign when there is no bay !!  There is, if a motorist parks in a marked bay, a duty on him to establish what restrictions there might be for that bay, and hence go and look for the sign. But here there is no marked bay.  Of course there were markings there in 2019
https://maps.app.goo.gl/bmHXjxq8Q33BxgPc9
but they've all disappeared now.

I would say this has to be a clear win at London Tribunals.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on March 31, 2024, 06:54:02 pm
Thanks - yes it's odd, and counter-intuitive.

This page https://www.newham.gov.uk/parking-permits/parking-newham/7# sets out Newham's approach to parking on "Public and Bank Holidays". In many (most?) London Boroughs Resident only Parking is suspended during Bank Holidays. I had, foolishly, assumed Easter Sunday would count, but it doesn't.

Newham don't define what they mean by Public and Bank Holiday but https://www.gov.uk/bank-holidays doesn't show Easter. The hours of the bay are 8.00am - 6.30pm Mon-Sun so I was relying on the fact that Easter was a Bank/Public holiday to park.

The legalities aside, I think the fact that they were presumably about to tow my vehicle for this matter (as opposed to teaching me a £65 lesson on what does and doesn't count as a Bank Holiday) given there was plenty of parking elsewhere and I was not causing an obstruction is grotesque, but probably a matter for me to complain to local councillors about, and not really one for reps. I suppose it may help them look unreasonable at Tribunal.

My 'cigarette packet argument' is that this was a genuine error on my part compounded by the fact that the lack of bay markings (I believe they may be extremely, extremely faded) makes it questionable whether this matter should have been enforced anyway. But I am unclear whether at law the white bay markings are required for a Controlled Parking Zone, and have found some conflicting advice on this and the old forum.
Title: Re: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ManxTom on March 31, 2024, 06:48:37 pm
You might not consider this very helpful, but I would presume that the restriction was 24/7, 365 days a year unless the signage specifically indicated otherwise.

I'm also surprised that you say the council treat Good Friday and Easter Monday as "Bank Holidays" but not Easter Sunday.  I'm surprised because all my local supermarkets are open on Friday and on Monday, but not on Sunday.

Is this a thing in Newham?  (Or in London generally.  I don't live in London...)
Title: Newham 12 - Parked in shared usage bay without valid permit, Albert Road North Woolwich
Post by: ticketed_off on March 31, 2024, 05:29:31 pm
Good afternoon, and Happy Easter from me and in particular, Newham Council >:(  :( .

I had been under the impression that Newham Council did not enforce resident parking restrictions on Easter Sunday as this was a Public Holiday. I have learned a lesson, via PCN, that Easter Sunday itself (unlike the Friday and Monday) is not a PH.

I am not sure whether there may be any route to 'appeal' here, or not. I returned to my vehicle parked in a shared usage Resident CPZ/PaybyPhone bay at 11:45AM to find the PCN. As I sat reading it, I was passed by a slightly disappointed looking towtruck driver who slowed down as he passed my vehicle and had presumably been sent to remove my vehicle.

If Newham were a more reasonable borough on parking then I would consider an informal representation on the grounds of genuine error (and pointing to my track record of paying for permit parking in this area when required) but given their hardline stance on vehicle removals (they routinely remove vehicles within 30m of a contravention), I am not sure if there is any point.

I previously had my vehicle removed in the same CPZ when a CEO keyed in my number wrongly (I had a valid visitor's permit). I caused a fair amount of fuss about this at the time and received a settlement, so if there is any element of human discretion applied I am not clear whether that might count against me now there was a bona fide case.

My only other immediate thought is that there is no 'bay' marking for the CPZ but I am unsure if this is legally required?

Thanks very much in advance for any suggestions.

Please see below the PCN:

(https://i.imgur.com/vEaKNx0.jpeg)

The images taken by the CEO are here:

https://imgur.com/a/Vf7QUKk

The location is here:

https://maps.app.goo.gl/u5FYbGsxCMWwDFfm8