Free Traffic Legal Advice

Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: JackFB on July 31, 2023, 02:42:48 pm

Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on September 13, 2024, 12:51:52 pm
Just to say there has been a
NOTICE OF ACCEPTANCE OF REPRESENTATIONS - thank you for all your amazing advice and counsel...

DETAILS

PCN Number: BH10240956

The representations you made about the penalty charge issued on the 11/03/2023 at 16:29
have been considered and accepted by Brighton & Hove City Council.
1. The details of your PCN / Notice to Owner:
Contravention:
01 Parked in a restricted street
during prescribed hours
2. Our reasons for accepting your representations:
The PCN was issued because the vehicle was parked in a restricted street during prescribed
hours
Please see the photographs taken by the Civil Enforcement Officer at the time the PCN was
issued:
Due to technical problems Brighton & Hove City Council has failed to respond to your
challenge within the time frame set down in the Traffic Management Act 2004.
Owing to this delay, I can confirm that the PCN has been cancelled and the case is now
closed.

Yours sincerely,
A Johnston
Parking Services Officer
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: cp8759 on June 26, 2024, 11:06:01 pm
I think I will appeal on the grounds of the delay.
@JackFB no you won't, you'll make a representation to the council. You can only make an appeal to the tribunal, and that can only happen once a notice of rejection has been issued.

If you are sure you ticked box 2 on the TE9 you sent to the court, then this is really easy:

Dear Brighton & Hove City Council,

I challenge the penalty charge on the grounds that service of the enforcement notice dated 19 June 2024 is invalid and a procedural impropriety. I filed a witness statement on the ground that I made representations against the previous enforcement notice and had not received a notice of rejection, in these circumstances the council is required to refer the matter to the Traffic Penalty Tribunal.

It follows that service of a further enforcement notice was not authorised or required by the regulations, and is therefore ultra-vires and a procedural impropriety.

Furthermore, there has been an inordinate delay of over nine months between the dates of issue of the charge certificate and the order for recovery, such that the council should not be permitted to recover the debtin any event.

For the above reasons please would you now cancel the penalty charge.

Yours faithfully,

Make sure to submit this online and keep a screenshot of the confirmation page. Once submitted keep an eye on the council portal and let us know as soon as a notice of rejection has been issued.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 26, 2024, 03:38:30 pm
This is the form I re-sent yes. Thank you for highlighting it in the thread.

The following post says tick the relevant box and get it sent. I assumed it was the relevant box. If not how do I show the council didn't send an NtO?

Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Enceladus on June 26, 2024, 10:32:45 am
Are you suggesting that we can't rely on the copy of the TE9 Witness Statement form that's in your reply #5 on: May 07, 2024, 04:37:38 pm above? 5th post on page 1 of this topic. The form shows that the no response to representations box has been ticked.

So is it the form that you re-sent to the TEC or not?
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 25, 2024, 12:03:56 pm
I think I will appeal on the grounds of the delay.

None of the boxes gave me an option that showed the lack of NtO or the delay. I would have expected an 'other' section which i could describe the situation/grievance as it would go to protocol, surely?

I can't remember the box I ticked, but I after it came back after I said the above I believe it would have been the one that said:
I made representations about the penalty charge to
the Charging Authority concerned, within 28 days
of the service of the Penalty Charge Notice, but did
not receive a rejection notice.



Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: cp8759 on June 23, 2024, 05:38:23 pm
There is certainly a procedural mess here but the case history shows this:

(https://i.imgur.com/Lr6yEVa.png)

It would certainly be helpful to know for sure which box was ticket on the TE9 form, but a representation can be made in any event on the grounds of undue delay, as there is simply no justification for a nine month gap between the charge certificate and the order for recovery.

@JackFB please confirm which box you ticked on form TE9.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: H C Andersen on June 22, 2024, 06:57:49 pm
OP, would you pl confirm which grounds you ticked in your final WS. The council's record shows:

The case progression record says "18/06/2024 13:15   Revoking Order Received, Box 1: No NTO Received"
and
18/06/2024 13:20   WS Box 1 letter
19/06/2024 07:16   NTO/Enforcement Notice Issued


Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Enceladus on June 22, 2024, 04:13:52 pm
You have received a Notice to Owner so you will have to respond to it.
That said, I would say the new NTO is unlawful.

The Council have no power to serve a new NTO unless the existing NTO has been deemed cancelled due to the acceptance of a Witness Statement under regulation 23(2)(a) "that the person making it did not receive the notice to owner in question;"

You didn't submit any Witness Statement to that effect. And you did receive the original Notice to Owner. Your Witness Statement was submitted under ground 23(2)(b) "that he made representations to the enforcement authority under regulation 4 of the Representations and Appeals Regulations but did not receive from that authority a notice of rejection in accordance with regulation 6 of those Regulations;"

In such a case the NTO is not cancelled. The regulations provide under 23(7) "Where a witness statement has been served under paragraph (2)(b), (c) or (d), the enforcement authority shall refer the case to the adjudicator who may give such directions as he considers appropriate and the parties shall comply with those directions."

The Council appear to have misread your Witness Statement form and incorrectly assumed they should re-issue the NTO. They haven't referred the matter to the Adjudicator for direction as they were supposed to do.

Can anybody confirm whether or not there is a time limit for the Council to refer to the Adjudicator? The TEC order is dated the 13th of May so nearly six weeks ago.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 22, 2024, 02:25:21 pm
So the NTO has arrived. Here is the link to the dropbox
https://www.dropbox.com/scl/fo/wpswr1x04gvknn0kzgg5i/ANI3lZ9C_Lc6Yq-9_YuXeYo?rlkey=h3ipouyjcf4ym4vtfujvf2lz1&st=6j4my5gk&dl=0

Thanks for your attention.

kind regards
Jonny
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: H C Andersen on June 21, 2024, 04:11:52 pm
Here's a record of the events from the council:
Date
Description
19/06/2024 07:16   NTO/Enforcement Notice Issued

So OP, it's on its way. When received pl come back.

At present, the, shall we say, interesting sequence of events and claims that preceded TEC's revocation are not the issue. OP, you have to make new reps which, if based upon previous argument, I think we could assume would be rejected and would then result in an appeal, unless you chose to pay, at which point and because the same PCN is involved the historical events could possibly surface.

IMO, the previous events are now in the 'pending' tray!
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 21, 2024, 12:29:07 pm
Thank you for noticing that.

The link to the letter they sent is in the previous post here it is again: https://www.dropbox.com/scl/fo/wpswr1x04gvknn0kzgg5i/ANI3lZ9C_Lc6Yq-9_YuXeYo?rlkey=9tx21hc26pxqk1m85feith0zd&st=eps7199r&dl=0

- nowhere on it does it say NtO so hopefully I'm safe to assume it isn't. The NtO is yet to arrive.

Kind regards
JackFB

Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Enceladus on June 20, 2024, 03:25:55 pm
The Witness Statement you posted earlier shows that you ticked the box for "I made representations about the penalty charge to the enforcing authority concerned within 28 days of the service of the Notice to Owner, but did not receive a rejection notice".

The case progression record says "18/06/2024 13:15   Revoking Order Received, Box 1: No NTO Received"
and
18/06/2024 13:20   WS Box 1 letter
19/06/2024 07:16   NTO/Enforcement Notice Issued


So on the 18th they sent you a (likely a standard) letter. On the 19th they reissued and presumably posted a new NTO.

Somewhere between the TEC and the Council there's been a mix-up

Please post up the letter and the NTO when you get them.

Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 20, 2024, 02:33:48 pm

Here's a copy of the statement as I thought this was what I was supposed to reply with. I point out the fact I didn't receive a Charge Certificate. I was unclear about the process and whether I was supposed to get one. I tried to phone BH Parking Services but it's a stonewall of convoluted telephone machines.

I couldn't get through to BH Parking Services. There does seem a long time between processes here.

Anyway: here is the statement:

To: Traffic Enforcements Centre
County Court Business Centre
St Katherine’s House
21-27 St Katherine’s Street
Northampton
NN1 2LH 

24th April 2024

Witness Statement in response to Order for Recovery

Regarding Penalty Charge Notice (PCN) BH10240956

Date: 11/03/2023
Time: 16:29
Registration: EN52FMG

I am writing this witness statement in response to the order for recovery of an unpaid penalty charge issued to me. Upon receiving the order, I reviewed the PCN history at the provided website link (https://brighton-hove.tarantoportal.com/PCNs/PCN/KeyEvents) and was surprised to find that a Charge Certificate was issued on 18/07/2023 at 07:21, as I have no record of receiving this certificate either via email or by post.

I must clarify that currently I am suffering from Chronic Fatigue Syndrome (CFS) and experience episodes of brain fog, which affects my memory and cognitive functions - this can be verified with Dr Burgess at Pavilion Surgery,2-3 Old Steine, Kemptown, Brighton and Hove, Brighton BN1 1EJ. One of the reasons I am challenging this is because this PCN seems inordinately harsh and since losing my job, I am having trouble with money.

Despite my condition, I diligently searched through my emails, including deleted items and spam folders, but found no trace of the Charge Certificate for the aforementioned date.

I was told at the Notice of Rejection on June 6 2023 that ‘If, after 28 days, you take no action, we may send you a Charge Certificate increasing the £70.00 charge by 50%. You will then have 14 days to pay this increased charge. If after 14 days this charge has not been paid, we may apply to the County Court to recover the money, plus court costs, from you.’

I reiterate that I received no such Charge Certificate so was unaware this process was activated. I had I done I would have taken steps to address the matter.

Additionally, I find it concerning that there is a nine-month gap between the issuance of the Charge Certificate, which I did not receive, and the unexpected Order for Recovery. I seek clarification if such a lengthy delay is standard procedure.

As Form TE3 advised I phoned the Brighton Parking dept and was met with a series of automated messages saying that they weren’t legally permitted to share information about my own PCN and appeal.

I kindly request guidance on the necessary steps to address this matter further.

Additional supporting points that may be relevant, please ignore if they have already been dealt with:

I also provided valid grounds for why my vehicle was parked on Church Street at the time of the PCN issuance, if permitted I politely ask for them to be taken under consideration.

Firstly, I stated that I was loading leads for the Toads games at a nearby pub. Despite the Civil Enforcement Officer's assertion of not witnessing this activity, I reiterate that the absence of evidence does not negate the occurrence of the event. I provided contact details of the pub and the individual I was assisting to support my claim.

Secondly, I questioned the allowance of 40 minutes for loading and unloading activities. While Brighton Parking indicated that there is no provision for a specific time-frame, I argue that the nature of the items being unloaded, namely Toads tables, which are heavy and cumbersome, and the lack of immediate parking availability directly outside the pub, should be considered.

Thirdly, I inquired about the possibility of photographic evidence of my vehicle at the location after the specified times. While I understand that there is no legal requirement for Civil Enforcement Officers to take photographs, I believe such evidence could substantiate my claims. Although the CEO said there is no legal duty to do so, it stands to reason that had the vehicle not been there, this would have been observed.

Fourthly, I stated that I didn't register the sign because I assumed, like most of the UK, parking on yellow lines is permitted at the weekend. It is well known wardens usually give a grace period of ten minutes for parking.

Fifthly, I noted that the PCN was open and wet when I arrived at the car and asked if a ticket in this state is valid or if it may have been tampered with. This calls into question the propriety of its issue.

Sixthly, I raised the issue of receiving the response as a PDF in my junk mail. I assumed that the correct issue is when I receive the response, not when it's created in an office, as we have no record of its arrival.

Lastly, I asked about responding with evidence and the lack of a deadline date provided in the PDF. I believe this is a fair question given my unawareness of any wrongdoing and the expectation of being able to discuss any issues with a warden.

In conclusion, I respectfully request a review of the circumstances surrounding the issuance of PCN BH10240956. I am willing to provide any additional evidence or information required to support my case and seek a fair resolution to this matter.

Yours sincerely,
None of that has any place on a TE9.
If attached it will be ignored or worse. you may get rejected again.

Complete the form ticking just the relevant box and get it sent to tec@justice.gov.uk

Come back here to confirm you've received an acknowledgement e-mail.

here
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Neil B on June 20, 2024, 02:30:36 pm
they say they will send an a new NtO -
Where have they said that?
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 20, 2024, 02:28:37 pm
The witness statement was sent first time without the boxes ticked.
I made a note to the CC that one of the processes was missing but not one that was on the form, asking for their advice.
They sent it back.
I shared this on here and was advised to tick the appropriate box and sent it back.



Here's a record of the events from the council:
Date
Description
19/06/2024 07:16   NTO/Enforcement Notice Issued
18/06/2024 13:20   WS Box 1 letter
18/06/2024 13:15   Off hold no compensate
18/06/2024 13:15   Revoking Order Received, Box 1: No NTO Received
29/05/2024 13:28   On Hold : WARRANT REGISTRATION REJECTED
19/04/2024 07:30   Notice of Debt Registration Issued
14/03/2024 17:12   Off hold no compensate
04/12/2023 15:30   On Hold: PRE DEBT
18/07/2023 07:21   Charge Certificate Issued
16/06/2023 11:22   Notice of Rejection
16/06/2023 10:55   Off hold no compensate
16/06/2023 10:55   Representation submitted Under review
16/06/2023 10:55   Representation Rejected
12/06/2023 17:02   On Hold :Representation Received
12/05/2023 07:16   NTO/Enforcement Notice Issued
26/04/2023 14:34   Challenge Rejection
26/04/2023 13:07   Offer £35.00 until 11/05/2023
26/04/2023 13:07   Offer Period Revoked
26/04/2023 13:06   Off hold no compensate
26/04/2023 13:06   Representation Rejected
24/04/2023 18:01   On Hold: Challenge Received
24/04/2023 18:01   Off Hold Compensate
18/04/2023 13:50   On Hold: Challenge Received
18/04/2023 10:40   Evidence Request
18/04/2023 10:32   Offer £35.00 until 03/05/2023
18/04/2023 10:32   Off hold no compensate
18/04/2023 10:32   Representation Rejected
18/04/2023 10:32   Further information requested
26/03/2023 13:03   On Hold: Challenge Received




Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Enceladus on June 20, 2024, 01:30:15 pm
The TE9 Witness Statement that you posted earlier shows the box for 'no response to representations' option has been ticked. At some point you indicated you had not received a Notice of Rejection.

In such cases the case should be referred to the Adjudicator for direction on how to proceed. I would have expected that the Adjudicator would direct the Council to re-serve the Notice of Rejection, assuming they had sent one in the first place. Else the Adjudicator would direct the matter be heard as an appeal.

The NTO should only be resent if you had ticked the box the NTO not received box. So sending a new NTO is out of process and out of process invariably ends badly.

Please confirm that the TE9 Witness Statement you posted up is the one that was submitted and there was only the one box ticked.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 20, 2024, 12:42:36 pm
TBF I'm confused myself, and apologies if I've not found my way round the threads properly.

But I was advised on here to 'just send' the County Court submission form where it only gives you four options when I know that BHCC had missed out a part of the process.

Now after going back to the PCN and claiming 70 pounds they say they will send an a new NtO - which I'm still yet to receive.

Does this process begin again? Seems ludicrous. The warden didn't hang around long. His notes were all compiled within the same minute at  16.31 after issuing the ticket at 16.29

Thanks all for the assistance, god knows I need it.




Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: H C Andersen on June 20, 2024, 12:32:51 pm
What does this mean?


....I was told at the Notice of Rejection on June 6 2023 [the council's timeline says NoR issued 16 June] that ‘If, after 28 days, you take no action, we may send you a Charge Certificate increasing the £70.00 charge by 50%. You will then have 14 days to pay this increased charge. If after 14 days this charge has not been paid, we may apply to the County Court to recover the money, plus court costs, from you.’

Surely this means you received the NOR?

Indeed, your first lengthy submission to TEC makes no reference to not receiving the NoR but repeats what I've quoted above.

What seems to have happened subsequently is that you did not action this and received a CC. You established that this couldn't be challenged so submitted an improperly formatted WS which was rejected. You then seem to have resubmitted citing 'did not receive the NoR'.

Anyway, perhaps all will come out in the wash.

Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on June 20, 2024, 12:14:53 pm
As advised I've posted this back on the original thread. There is a link to my dropbox with the pic files in.

In reference to previous thread: https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/charge-certificate-sent-ignoring-my-nto-representations-brighton-council-ignore-/msg2252/#msg2252

Hi Guys

I responded as advised and received a response from the Traffic Enforcement Centre at Northampton CC:

Order for recovery: revoked
Charge certificate: cancelled

Thank you.

of course this does not cancel original PCN and true to form BHCC Parking Services are back.
They say an NtO is on its way after failing to send one originally.

Here's a link to the files: https://www.dropbox.com/scl/fo/wpswr1x04gvknn0kzgg5i/ANI3lZ9C_Lc6Yq-9_YuXeYo?rlkey=h3ipouyjcf4ym4vtfujvf2lz1&st=93jvv2dz&dl=0
I've attached the CC judgement, plus the new correspondence from BH Parking services, wondering what to do now.

Thank you for all your help.

Jack
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: H C Andersen on June 20, 2024, 07:16:31 am
OP, you posted:

....I was told at the Notice of Rejection on June 6 2023 [the council's timeline says NoR issued 16 June] that ‘If, after 28 days, you take no action, we may send you a Charge Certificate increasing the £70.00 charge by 50%. You will then have 14 days to pay this increased charge. If after 14 days this charge has not been paid, we may apply to the County Court to recover the money, plus court costs, from you.’

Which means you received the NTO, made reps and received a Notice of Rejection.

What box exactly did you tick on the witness statement??

If you received the NoR then you don't have legitimate grounds to challenge the Order for Recovery. Also, if - as they are required to do - the authority refer the matter to the adjudicator you would be asked to substantiate your claim which with the current evidence you could not do.

Setting aside for one moment that another NTO might be hoving into view from Brighton, the matter is procedural:
What box did you tick on the WS;
Did you receive a NoR;
Did you just tick this because there wasn't an option to claim that you didn't receive the Charge Cert?
Title: Re: Council NtO promise and response after CC revocation and cancellation
Post by: Enceladus on June 20, 2024, 07:00:30 am
.............
.............
of course this does not cancel original PCN and true to form BHCC Parking Services are back.
They say an NtO is on its way after failing to send one originally.
'''''''''''''
'''''''''''''
NtO is on its way? Surely not?

AIUI you did receive the NtO, some time ago, and submitted formal representations against it. No response (Notice of Rejection) was received and eventually you successfully submitted a Witness Statement with that boxed ticked.

Please post up the letter you received that says an NtO is on the way.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: cp8759 on June 20, 2024, 12:39:58 am
@JackFB I have merged your threads, please do not create duplicate threads for the same case.

Please read the guidance here on how to post images: https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/
Title: Re: Council NtO promise and response after CC revocation and cancellation
Post by: John U.K. on June 19, 2024, 06:56:19 pm
Quote
Wondering what to do now.

Please post this on your original thread, and ask a Mod to delete this one.

Quote
I've tried to attach but it says the upload folder is full.

Please have a read of this
https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/


and then post on that thread all sides of the new paperwork, redacting only name & Address.
Title: Re: Council NtO promise and response after CC revocation and cancellation
Post by: JackFB on June 19, 2024, 06:46:38 pm
I've tried to attach but it says the upload folder is full. My files are small enough etc.
Title: Council NtO promise and response after CC revocation and cancellation
Post by: JackFB on June 19, 2024, 06:41:54 pm
In reference to previous thread: https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/charge-certificate-sent-ignoring-my-nto-representations-brighton-council-ignore-/msg2252/#msg2252

Hi Guys

I responded as advised and received a response from the Traffic Enforcement Centre at Northampton CC:

Order for recovery: revoked
Charge certificate: cancelled

Thank you.

of course this does not cancel original PCN and true to form BHCC Parking Services are back.
They say an NtO is on its way after failing to send one originally.

Wondering what to do now.

Thank you for all your help.

Jack
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: cp8759 on May 15, 2024, 08:08:05 pm
Fair enough thank you. Will do.
Have you done this?
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Neil B on May 09, 2024, 06:27:06 pm
https://www.legislation.gov.uk/uksi/2022/71/regulation/23/made

Read sub para (7) for what happens next.

You will get your chance to make submissions to the adjudicator.

DO NOT opt for a postal decision, especially in a loading case where your personal testimony is vital.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on May 08, 2024, 12:00:21 pm
Fair enough thank you. Will do.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Neil B on May 07, 2024, 05:09:06 pm

Here's a copy of the statement as I thought this was what I was supposed to reply with. I point out the fact I didn't receive a Charge Certificate. I was unclear about the process and whether I was supposed to get one. I tried to phone BH Parking Services but it's a stonewall of convoluted telephone machines.

I couldn't get through to BH Parking Services. There does seem a long time between processes here.

Anyway: here is the statement:

To: Traffic Enforcements Centre
County Court Business Centre
St Katherine’s House
21-27 St Katherine’s Street
Northampton
NN1 2LH 

24th April 2024

Witness Statement in response to Order for Recovery

Regarding Penalty Charge Notice (PCN) BH10240956

Date: 11/03/2023
Time: 16:29
Registration: EN52FMG

I am writing this witness statement in response to the order for recovery of an unpaid penalty charge issued to me. Upon receiving the order, I reviewed the PCN history at the provided website link (https://brighton-hove.tarantoportal.com/PCNs/PCN/KeyEvents) and was surprised to find that a Charge Certificate was issued on 18/07/2023 at 07:21, as I have no record of receiving this certificate either via email or by post.

I must clarify that currently I am suffering from Chronic Fatigue Syndrome (CFS) and experience episodes of brain fog, which affects my memory and cognitive functions - this can be verified with Dr Burgess at Pavilion Surgery,2-3 Old Steine, Kemptown, Brighton and Hove, Brighton BN1 1EJ. One of the reasons I am challenging this is because this PCN seems inordinately harsh and since losing my job, I am having trouble with money.

Despite my condition, I diligently searched through my emails, including deleted items and spam folders, but found no trace of the Charge Certificate for the aforementioned date.

I was told at the Notice of Rejection on June 6 2023 that ‘If, after 28 days, you take no action, we may send you a Charge Certificate increasing the £70.00 charge by 50%. You will then have 14 days to pay this increased charge. If after 14 days this charge has not been paid, we may apply to the County Court to recover the money, plus court costs, from you.’

I reiterate that I received no such Charge Certificate so was unaware this process was activated. I had I done I would have taken steps to address the matter.

Additionally, I find it concerning that there is a nine-month gap between the issuance of the Charge Certificate, which I did not receive, and the unexpected Order for Recovery. I seek clarification if such a lengthy delay is standard procedure.

As Form TE3 advised I phoned the Brighton Parking dept and was met with a series of automated messages saying that they weren’t legally permitted to share information about my own PCN and appeal.

I kindly request guidance on the necessary steps to address this matter further.

Additional supporting points that may be relevant, please ignore if they have already been dealt with:

I also provided valid grounds for why my vehicle was parked on Church Street at the time of the PCN issuance, if permitted I politely ask for them to be taken under consideration.

Firstly, I stated that I was loading leads for the Toads games at a nearby pub. Despite the Civil Enforcement Officer's assertion of not witnessing this activity, I reiterate that the absence of evidence does not negate the occurrence of the event. I provided contact details of the pub and the individual I was assisting to support my claim.

Secondly, I questioned the allowance of 40 minutes for loading and unloading activities. While Brighton Parking indicated that there is no provision for a specific time-frame, I argue that the nature of the items being unloaded, namely Toads tables, which are heavy and cumbersome, and the lack of immediate parking availability directly outside the pub, should be considered.

Thirdly, I inquired about the possibility of photographic evidence of my vehicle at the location after the specified times. While I understand that there is no legal requirement for Civil Enforcement Officers to take photographs, I believe such evidence could substantiate my claims. Although the CEO said there is no legal duty to do so, it stands to reason that had the vehicle not been there, this would have been observed.

Fourthly, I stated that I didn't register the sign because I assumed, like most of the UK, parking on yellow lines is permitted at the weekend. It is well known wardens usually give a grace period of ten minutes for parking.

Fifthly, I noted that the PCN was open and wet when I arrived at the car and asked if a ticket in this state is valid or if it may have been tampered with. This calls into question the propriety of its issue.

Sixthly, I raised the issue of receiving the response as a PDF in my junk mail. I assumed that the correct issue is when I receive the response, not when it's created in an office, as we have no record of its arrival.

Lastly, I asked about responding with evidence and the lack of a deadline date provided in the PDF. I believe this is a fair question given my unawareness of any wrongdoing and the expectation of being able to discuss any issues with a warden.

In conclusion, I respectfully request a review of the circumstances surrounding the issuance of PCN BH10240956. I am willing to provide any additional evidence or information required to support my case and seek a fair resolution to this matter.

Yours sincerely,
None of that has any place on a TE9.
If attached it will be ignored or worse. you may get rejected again.

Complete the form ticking just the relevant box and get it sent to tec@justice.gov.uk

Come back here to confirm you've received an acknowledgement e-mail.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on May 07, 2024, 04:37:38 pm
Thank you

Here's their reply, as I didn't tick a box - I just responded with a witness statement and added I didn't receive the Charge Certificate, because I only saw it for the first time when notified about the last update on the BH website.

I have ticked the box now having revisited this thread... but obviously haven't sent it.

Here's a copy of the statement as I thought this was what I was supposed to reply with. I point out the fact I didn't receive a Charge Certificate. I was unclear about the process and whether I was supposed to get one. I tried to phone BH Parking Services but it's a stonewall of convoluted telephone machines.

I couldn't get through to BH Parking Services. There does seem a long time between processes here.

Anyway: here is the statement:

To: Traffic Enforcements Centre
County Court Business Centre
St Katherine’s House
21-27 St Katherine’s Street
Northampton
NN1 2LH 

24th April 2024

Witness Statement in response to Order for Recovery

Regarding Penalty Charge Notice (PCN) BH10240956

Date: 11/03/2023
Time: 16:29
Registration: EN52FMG

I am writing this witness statement in response to the order for recovery of an unpaid penalty charge issued to me. Upon receiving the order, I reviewed the PCN history at the provided website link (https://brighton-hove.tarantoportal.com/PCNs/PCN/KeyEvents) and was surprised to find that a Charge Certificate was issued on 18/07/2023 at 07:21, as I have no record of receiving this certificate either via email or by post.

I must clarify that currently I am suffering from Chronic Fatigue Syndrome (CFS) and experience episodes of brain fog, which affects my memory and cognitive functions - this can be verified with Dr Burgess at Pavilion Surgery,2-3 Old Steine, Kemptown, Brighton and Hove, Brighton BN1 1EJ. One of the reasons I am challenging this is because this PCN seems inordinately harsh and since losing my job, I am having trouble with money.

Despite my condition, I diligently searched through my emails, including deleted items and spam folders, but found no trace of the Charge Certificate for the aforementioned date.

I was told at the Notice of Rejection on June 6 2023 that ‘If, after 28 days, you take no action, we may send you a Charge Certificate increasing the £70.00 charge by 50%. You will then have 14 days to pay this increased charge. If after 14 days this charge has not been paid, we may apply to the County Court to recover the money, plus court costs, from you.’

I reiterate that I received no such Charge Certificate so was unaware this process was activated. I had I done I would have taken steps to address the matter.

Additionally, I find it concerning that there is a nine-month gap between the issuance of the Charge Certificate, which I did not receive, and the unexpected Order for Recovery. I seek clarification if such a lengthy delay is standard procedure.

As Form TE3 advised I phoned the Brighton Parking dept and was met with a series of automated messages saying that they weren’t legally permitted to share information about my own PCN and appeal.

I kindly request guidance on the necessary steps to address this matter further.

Additional supporting points that may be relevant, please ignore if they have already been dealt with:

I also provided valid grounds for why my vehicle was parked on Church Street at the time of the PCN issuance, if permitted I politely ask for them to be taken under consideration.

Firstly, I stated that I was loading leads for the Toads games at a nearby pub. Despite the Civil Enforcement Officer's assertion of not witnessing this activity, I reiterate that the absence of evidence does not negate the occurrence of the event. I provided contact details of the pub and the individual I was assisting to support my claim.

Secondly, I questioned the allowance of 40 minutes for loading and unloading activities. While Brighton Parking indicated that there is no provision for a specific time-frame, I argue that the nature of the items being unloaded, namely Toads tables, which are heavy and cumbersome, and the lack of immediate parking availability directly outside the pub, should be considered.

Thirdly, I inquired about the possibility of photographic evidence of my vehicle at the location after the specified times. While I understand that there is no legal requirement for Civil Enforcement Officers to take photographs, I believe such evidence could substantiate my claims. Although the CEO said there is no legal duty to do so, it stands to reason that had the vehicle not been there, this would have been observed.

Fourthly, I stated that I didn't register the sign because I assumed, like most of the UK, parking on yellow lines is permitted at the weekend. It is well known wardens usually give a grace period of ten minutes for parking.

Fifthly, I noted that the PCN was open and wet when I arrived at the car and asked if a ticket in this state is valid or if it may have been tampered with. This calls into question the propriety of its issue.

Sixthly, I raised the issue of receiving the response as a PDF in my junk mail. I assumed that the correct issue is when I receive the response, not when it's created in an office, as we have no record of its arrival.

Lastly, I asked about responding with evidence and the lack of a deadline date provided in the PDF. I believe this is a fair question given my unawareness of any wrongdoing and the expectation of being able to discuss any issues with a warden.

In conclusion, I respectfully request a review of the circumstances surrounding the issuance of PCN BH10240956. I am willing to provide any additional evidence or information required to support my case and seek a fair resolution to this matter.

Yours sincerely,



[attachment deleted by admin]
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: Incandescent on May 07, 2024, 02:54:36 pm
YOu'd better let us see what you put on the TE9.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: JackFB on May 07, 2024, 02:45:12 pm
I've got an update on this PCN and frankly I'm a bit confused.

I've attached the history of it from BH Parking site in screengrabs.
I've re-read this thread and come to it after they have taken a long time to process this. I wonder where I stand.
I responded that there was no Charge Certificate - and their logging of it was a surprise.

But of course this is not how i can respond and have had my TE9 returned.

Having read this thread I will reply having ticked the 'not receive a rejection notice' within 28 days.
I am also wondering when I can send a statement from my friend I was helping with the tables. Should I send it back with the amended TE9?

Thank you for your assistance,

Kind regards
Jonny

[attachment deleted by admin]
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: cp8759 on August 02, 2023, 05:44:06 pm
Much of what you wrote is misguided, but the key point that you are entitled to load and unload is correct.

What isn't clear is what evidence you supplied to substantiate your assertion that you were loading (you can't just say you were loading or else we could all park wherever we want and just say we were loading), but presumably you could gather evidence to confirm what you were unloading (photos of the lead tops, any emails / text messages / whatsapp messages about the event and so on. In due course a statement from your friend would be helpful.

Your reps have not been ignored or disregarded, rather it seems a Notice of Rejection was sent and never delivered (and the council cannot be responsible for lost post):

(https://i.imgur.com/B8gDB5D.png)

(https://i.imgur.com/3qwcEL6.png)


However right now you need to deal with the charge certificate, which is dealt with by ignoring it. The next document in the chain is the Order for Recovery, which you then challenge by making a witness statement to the Traffic Enforcement Centre, the full process is explained here: https://www.trafficpenaltytribunal.gov.uk/charge-certificates-and-orders-for-recovery/

The statutory ground that applies to you is "Representations were made to the local authority or charging authority within 28 days of the NtO / PCN being received, but no Notice of Rejection (NoR) of Representations was received".

However you don't want to risk the Order for Recovery going missing in the post as well, so you need to keep an eye on the amount due on https://brighton-hove.tarantoportal.com/PCNs

Once the 14 day charge certificate period has expired, check the amount due at least once a week. As soon as it goes up to £114 or the status changes from "CC Sent" to "OFR Sent", you can download form TE9 (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1094491/Parking_TE9.pdf) and fill it in (no need to print, just type it out on your computer and save), remember you are not the "applicant", the "applicant" is the council.

Once that's done you can email it to tec@justice.gov.uk with the PCN number in the subject line and both the Order for Recovery and the Charge Certificate will be revoked.

The council will then refer the case to the Traffic Penalty Tribunal for the appeal to be decided on its merits.

If anything isn't clear please ask, and also please confirm what evidence you can gather to corroborate your claim that you were loading.

Also please post all sides of the PCN and the Notice to Owner.
Title: Re: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case d
Post by: guest179 on July 31, 2023, 03:01:00 pm

I've copied in my response to the NtO which I sent on the 8/6/23, below.

How was this sent?
Title: Charge Certificate Sent Ignoring my NtO Representations, Brighton Council - ignore representations and online case disap
Post by: JackFB on July 31, 2023, 02:42:48 pm
Hi Guys

The local council here in Brighton seemed to have jumped to a Charge Certificate without responding to my posted representations.

I'd already made one in response to the original PCN online but that too seems to have disappeared from the page and offers me only the option to pay the upgraded fine.

PCN: BH10240956

The NtO was issued and 'posted' on 12/5/23 and arrived with me on 16/5/23.
I've copied in my response to the NtO which I sent on the 8/6/23, below.

I'm wondering if my reps have been disregarded.
There is no phone number to see what's happened.

Kind regards
FBJ

Response to NtO

FAO: Brighton and Hove City Council
PO Box 204
Sheffield, S98 1LS

Re: Response to NtO and representations against Penalty Charge Notice [PCN] – Reference: BH10240956, Registration: EN52 FMG

Dear Sir/Madam,

I hope this letter finds you well. I am writing to formally challenge the Penalty Charge Notice (PCN) issued to me on 11/3/2023 for an alleged parking violation. I would like to bring the following points to your attention:

Delayed Arrival of the Notice to Owner (NtO):
I must highlight that the NtO arrived at my address on the 16th of May, rather than the stated date of posting being the 12th of May. I kindly request that Brighton and Hove City Council (B&HCC) considers this discrepancy and takes into account any potential postal issues that may have occurred. Moreover, it is worth noting that these representations are being posted to you on the 9th of June, which falls within the statutory time-frame of 28 days, being 19 working days after the 12th of June, and 15 working days after the NtO arrived on the 16th of May.

Inability to Complete Online Form:
I regret to inform you that I was unable to submit the form online as your system appears to be preventing me from entering my correct address details, specifically, Flat 3, 16 Lower Rock Gardens, BN2 1PG (date attempted: 8/6/2023). I would appreciate clarification on why this issue has arisen, as I had previously been able to provide accurate information using your online platform at https://brighton-hove.tarantoportal.com/PCNs.

Challenge Regarding the Incident:
I hereby challenge the occurrence of the alleged parking violation as stated in the PCN. During the time in question, I was actively engaged in assisting with a local games tournament known as "Toad in the Hole," where I was responsible for delivering heavy lead tops for the tables on behalf of a friend. I would like to emphasize that these events are organized largely on a not-for-profit basis by the players and has a significant role in generating interest in Brighton through the promotion of an old Sussex game.

Regarding loading and unloading rights, according to the relevant UK legislation, specifically the Traffic Signs Regulations and General Directions (TSRGD) 2016, loading and unloading is permitted on single yellow lines, provided certain conditions are met. It is my understanding that drivers are allowed a reasonable period of up to 40 minutes for loading and unloading, and there was nothing in the signage to indicate I couldn’t use the space to unload or load. One would expect a ‘No Loading at any time sign’ for example.

Additionally, as this was a Saturday, it is important to note that loading and unloading rights are not typically suspended on weekends, unless explicitly stated. Therefore, I assert my right to utilize the 40-minute loading and unloading period on this occasion.

Excessive and Incorrect Charge:
I dispute the charge imposed, as it appears to be both excessive and inaccurate. According to my understanding of the relevant legislation, the warden was present for only five minutes, whereas I believe the law allows for a 40-minute loading period on single yellow lines. Additionally, there is no record of my arrival or departure, nor any documented discussion between the warden and myself to verify the alleged violation.

Therefore I respectfully dispute the parking attendant's claim that I exceeded the permitted time limit by parking for more than five minutes. It is worth noting that the attendant did not witness my arrival or departure, nor was there any documented discussion between us. Consequently, their observation fails to provide conclusive evidence regarding the duration of my presence at the location.

Photographic Evidence:
I have taken the liberty of capturing photographs which demonstrate that the PCN in question was open and wet from the rain. This raises concerns regarding its authenticity and, at the very least, casts reasonable doubt on the overall accuracy of the fine. I believe this circumstance highlights a casual and inattentive approach towards the residents and car owners of Brighton.

Knowledge of Loading Rights and Supporting Contact Information:


I wish to highlight that I am aware of my rights regarding loading on single yellow lines for a maximum duration of 40 minutes. In support of my claim, I have already provided contact details for the craftsman whom I assisted during the time of the alleged violation. It is my understanding that this information should provide sufficient evidence to warrant some leniency in this particular case.

I trust that the Brighton and Hove City Council will thoroughly investigate and consider the issues I have raised. Furthermore, I kindly request a detailed response addressing each of the aforementioned points within a reasonable timeframe.

Should you require any further information or documentation, please do not hesitate to contact me at the address provided above or via email at jonnywills@hotmail.com.

Best regards
J