Reply from the council:
Camera Type: LaneWatch Unattended Enforcement Camera LW Mk2 / MAV 52
Manufacturer: Yunex Traffic (Previously named Siemens & Zenco)
Draft representation:
Dear Reading Borough Council,
I challenge the PCN on the grounds that it is a defective document, because the council claims that if the penalty charge is not paid or challenged then a charge certificate "will" be issued, while under the regulations it can only state that a charge certificate "may" be issued. I refer you to the easons given by the Traffic Penalty Tribunal in the decisions at LINK1, LINK2, LINK3 and LINK4.
It follows that in light of that procedural impropriety, the PCN must be cancelled.
Yours faithfully,
I will PM you the links to put in the representation, they will redirect to Anthony Hall v Kent County Council (with Tunbridge Wells BC) (KU-00042-1810, 07 December 2018) (https://drive.google.com/uc?id=1EoqML5pVDJePtRNZ11St3yHfKbSK8IuZ), Claire Jones v Cheshire West and Chester Council (AW00056-1811, 19 December 2018) (https://drive.google.com/uc?id=1AdoQ7mC9-5qqfkLxsfrifY889pbT7cp0), David Chapman v Portsmouth City Council (PO00086-1811, 09 January 2019) (https://drive.google.com/uc?id=1diUBnlDzjbOdvKif0pUA3y_GxnIMY0L6) and Ammar Abdul Hadi v Coventry City Council (CV00067-1902, 05 April 2019) (https://drive.google.com/uc?id=1gPi42KZHLS7iMTbzgM1YIafEg_4jN_gs) but if you give them the links I'll PM you, we can use the click count to confirm whether they've looked at them or not (obviously do not click on the links I PM you as we want the click count to remain at zero). If they don't click on them, we can then prove they've failed to consider all of the evidence. If they say in the rejection that they've considered all the evidence, we've got them for lying as well.