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General discussion => The Flame Pit => Topic started by: Bustagate on June 21, 2025, 02:20:53 pm

Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Hippocrates on September 23, 2025, 07:57:19 pm
@Hippocrates: Any views on the chances of success with this?

Merton's web page about school safety zones (https://www.merton.gov.uk/streets-parking-transport/school-safety-zones) states:
Quote
Restrictions don't apply during school holidays, inset days, weekends or bank holidays. See each school's website for details of its term dates and inset days.
so their policy is clear and in conflict with the TMOs.

I wonder whether Merton were conscious of the risks of having TMOs which applied all year and placed the "School term time" signs to justify not issuing PCNs when the school wasn't in session. The signs might well have sufficed to keep within administrative law. If so, their removal to satisfy adjudicators would be a fine irony: out of the frying pan into the fire.
I am sorry as I have just seen this. We have won several cases on this issue which are on the forum.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on September 23, 2025, 11:15:40 am
Quote
I wonder whether this is observed?

I doubt it, but I do remember seeing several warning notices in 2022, notably Greenwich and Hammersmith.

I've seen the explanatory memos for the 2022 regs, but not the above document... thanks.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on September 22, 2025, 02:50:55 pm
DfT Advice Note about Moving Traffic Contraventions
---------------------------------------------------------
@John_S I happened across Civil Enforcement of Parking, Bus Lane, and Moving Traffic Contraventions – Updated Advice Note (https://moderngov.rotherham.gov.uk/documents/s138829/Appendix%201%20-%20TMA%202004%20Part%206%202022%20Advice%20Note%20Updated.pdf) issued by DfT in March 2022. The Annex (pp 6-8) sets out "Traffic Signs Subject to Moving Traffic Enforcement" (with my italics):
Quote
Schedule 7 to the 2004 Act lists those traffic signs below (prescribed in the Traffic Signs Regulations and General Directions 2016 as amended: ‘TSRGD’) as civilly enforceable as moving traffic contraventions. This applies to any permitted variant under TSRGD; for example, diagram 606 when varied to point ahead or to the right.

It should be noted that the Government committed only to introduce moving traffic enforcement powers in respect of those signs listed below. Regulatory traffic signs (other than those for parking and bus lanes) that are not listed below will remain enforceable only by the police (for example, diagram 626.2A indicating structural weight limits).

[ list of diagram numbers including 618.3C and 953 but not 953A or 953B; the list follows the tables in Regulations 3 and 4 of The Civil Enforcement of Traffic Contraventions (Consequential Amendments) (England) Regulations 2018 (https://www.legislation.gov.uk/uksi/2018/488/contents/made) ]

It does, therefore, look very much as though DfT did not intend to allow civil enforcement of contraventions involving specially-authorised traffic signs. This Advice Note is addressed to London local authorities, including Merton, as well as those outside London.


PCNs involving contravention of diagram 953A or 953B
-----------------------------------------------------------
In the body of the Advice Note, DfT opined:
Quote
The Department for Transport’s view, which does not constitute legal advice, is that ongoing bus gate enforcement should not require an application for designation of moving traffic enforcement powers, and that any TRO made under the 2005 bus lane regime for this purpose should remain enforceable under the forthcoming 2022 regulations. This view also applies to bus gates introduced after the 2022 regulations enter force.

In coming to this view, the Department for Transport notes a 2010 High Court ruling statement that the question of the adequacy of traffic signing is a fact sensitive issue depending on the particular circumstances of a case. Local authorities should therefore seek their own legal advice if they have any particular concerns.

The 2010 High Court ruling is evidently the Oxford bus gate case. It allows PCNs to be issued in respect of bus gates under Part 2 of Schedule 7 of Traffic Management Act 2004 (https://www.legislation.gov.uk/ukpga/2004/18/schedule/7/part/2) (or the equivalent in London). However, to use this judgment, the PCN must be for a contravention which relates to being in a bus lane, i.e. code 34.

But what actually happens at bus gates? The PCN issued is usually 33E - Using a route restricted to certain vehicles: buses, cycles and taxis only. This is a moving traffic contravention issued under Part 4 of Schedule 7 of Traffic Management Act 2004 (https://www.legislation.gov.uk/ukpga/2004/18/schedule/7/part/4) (or the equivalent s.4 of LLATfL Act 2003 in London). If the bus gate uses a diagram 953 (or an equivalent diagram 616 with an Except plate), that's fine.

If the bus gate uses diagram 953A or 953B (i.e. it allows solo motor cycles through), they can't use Part 4. Instead they must use Part 2 with contravention code 34J: Being in a bus lane. I've checked Cumberland Road, Bristol: they do use 34J. I thought I was on to something. Apparently not, except that it does confirm that local authorities don't use moving traffic contraventions when the associated traffic sign isn't in the list. It also makes the judgment in the Oxford bus gate case central to adjudications of such PCNs: they can't pick and choose from the judgment they're relying on.


Issuing Warnings for First-time Contraventions in First Six Months
----------------------------------------------------------------------
The body of the document includes this statement (italics used instead of underlining in the original):
Quote
Though not critical for the transition to the 2022 regulations, those local authorities intending to acquire moving traffic enforcement powers will also need to ensure that their IT systems are ready to reflect the requirement in the forthcoming statutory guidance that, for a period of six months following implementation of moving traffic enforcement in practice, at each particular camera location, local authorities outside London should issue warning notices for first-time moving traffic contraventions. This also applies to any new camera location in the future. The warning notice should set out the six-month period and advise that any further moving traffic contravention at the same camera location would result in the issue of a PCN.

Although outside the scope of statutory guidance, within London where moving traffic contraventions have been enforced for many years under the London Local Authorities and Transport for London Act 2003, enforcement authorities are expected to issue warning notices in the same way as set out above for first-time contraventions of cycle lane, cycle route and ‘buses prohibited’ contraventions (civilly enforceable in London for the first time from 00:00 on 31st May).
I hadn't been aware that, as well as an initial period of a few weeks when they issue warnings rather than PCNs, traffic authorities outside London are expected to issue a warning rather than a PCN during the first six months of operation at a new site if the contravention is the first at the site by the vehicle involved.

I wonder whether this is observed?-
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on September 14, 2025, 10:54:26 pm
Makes you wonder whether anyone is advising Merton. So many errors in their reply.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on September 05, 2025, 10:48:19 am
@John_S I've had a reply from Merton (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch/response/3145208/attach/3/IR598%20F22185%20school%20street%20signs.pdf) to my FoI about their issuing PCNs in respect of a non-permitted variant of diagram 618.3C. I have sent them a follow-up (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch#outgoing-1931832).

La lutte continue.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on August 27, 2025, 04:12:38 pm
@John_S I agree. I think Charlton Road, Harrow is a much better candidate for a collateral challenge under administrative law. I've started a new thread (https://www.ftla.uk/the-flame-pit/a-new-line-of-attack-against-pcns-on-charlton-road-jw-d-arcy-drive-harrow) with my suggested representations.

Charlton Road is an example of the misuse of Keep Left signs where "special" vehicles (other than the emergency services) are permitted to go on the "wrong" side of the sign (Islington has many of these). What makes Charlton Road such a good candidate is that the TMO states that vehicles on Council service can go on the "wrong" side of the sign if they are "being lawfully used" on Council services. As going on the "wrong" side of the sign is unlawful, the TMO doesn't actually authorise vehicles providing Council services to go on the "wrong" side.

I'd feel much more comfortable in using a collateral challenge under administrative law for Merton School Streets if I could point to success of such an approach elsewhere. Charlton Road would be a lovely nut to crack as it's been considered impregnable: the only successful appeal has been about a timeout on delivering the PCN.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on August 26, 2025, 11:55:02 am
@Bustagate I’m aware of one PCN going through the appeal process at present where the ‘scheduled traffic sign’ argument may be used, but my view is that we need a fresh PCN so we can make a collateral challenge from the outset without distracting the adjudicator.

A collateral challenge could be made using your arguments, but I’d be more comfortable using the ‘scheduled traffic sign’ argument (reply#11) and linking it to the issues you raise about the inconsistency of the TMOs and their enforcement by Merton.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on August 24, 2025, 03:21:03 pm
@Hippocrates: Any views on the chances of success with this?

Merton's web page about school safety zones (https://www.merton.gov.uk/streets-parking-transport/school-safety-zones) states:
Quote
Restrictions don't apply during school holidays, inset days, weekends or bank holidays. See each school's website for details of its term dates and inset days.
so their policy is clear and in conflict with the TMOs.

I wonder whether Merton were conscious of the risks of having TMOs which applied all year and placed the "School term time" signs to justify not issuing PCNs when the school wasn't in session. The signs might well have sufficed to keep within administrative law. If so, their removal to satisfy adjudicators would be a fine irony: out of the frying pan into the fire.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Hippocrates on August 24, 2025, 11:11:58 am
Most adjudicators entertain a collateral challenge.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on August 23, 2025, 10:29:15 pm
@John_S I've now had a reply from Merton to my FoI (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch?unfold=1#incoming-3125998). I don't consider it addresses the issues and have requested an internal review (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch#outgoing-1922233).

While I consider that Merton deserve heat on their signage for the school streets, I'm not convinced that the courts would accept that the addition of an "Except authorised vehicles" plate (even with the erroneous "for") renders the pedestrian and cycle zone invalid. De minimis comes to mind.

On the other hand, I do think that there's a strong line of argument to do with the Council's failure to apply its TMO consistently. While Merton's website (and Council papers) talk about applying the scheme only during term time, the TMOs don't, e.g. the TMO for Hollymount School (https://www.merton.gov.uk/system/files/TMO%202022-21%20The%20Merton%20%28Pedestrian%20and%20Cycle%20Zone%29%20%28Hollymount%20Primary%20School%29%20Traffic%20Order%202022.pdf). This TMO declares:
Quote
3. Without prejudice to the validity of anything done or to any liability incurred in respect of any act or omission before the coming into force of this Order, no person shall cause any vehicle to enter any road or length of road specified in column 2 of the Schedule to this Order during the corresponding prescribed hours specified in column 3 of the Schedule to this Order.

Schedule
column 2. Cambridge Road, between its junction with Pepys Road and its junction with Lambton Road
column 3. Between 8.15am and 9.15am and between 2.45pm and 4pm Mondays to Fridays

While you may consider that Merton are under no obligation to issue PCNs during school holidays, they are obliged to administer the law fairly. While the intention of the scheme may well have been that it should only apply during term time, that isn't what they have actually legislated. The TMO applies during the specified hours Monday to Friday throughout the year.

If you get a PCN for entering a school zone one Monday and another person doesn't who enters the same school zone at the same time a week later (perhaps on a Bank Holiday), you are entitled to feel aggrieved. Why have Merton issued you with a PCN when they haven't issued a PCN to someone who did the same thing a week later? Merton may say "Ah, but the school wasn't in session". So what? Merton have legislated to prohibit entry at that time on a Monday regardless of whether the school is in session or not.

This failure to be even-handed in administering justice violates the fundamental doctrine on which administrative law is based: the Rule of Reason. This dates from the sixteenth century and states that discretionary powers must be exercised for sound reasons; if they are not, the courts can intervene and overrule the decision taken.

The modern version of this is the concept of Wednesbury unreasonableness. In the words of Lord Greene MR
Quote
... a person entrusted with a discretion must, so to speak, direct himself properly in law. He must call his own attention to the matters which he is bound to consider. He must exclude from his consideration matters which are irrelevant to what he has to consider.   
Actions by public bodies can be challenged by judicial review, which is essentially concerned with whether or not the Rule of Reason has been observed. Many cases of judicial review turn on whether a public body has acted from improper motives or irrelevant considerations, or has failed to take account of relevant considerations. In either case, the body's actions may be found ultra vires and therefore void.

[I have been very conscious of this because shortly after I joined the Department of Education and Science, it was dealt a body-blow by the House of Lords (now the Supreme Court) in the Tameside case. This found that the Secretary of State had acted unreasonably in not allowing Tameside MDC at short notice after an election to change its plans to go comprehensive.]

While the costs of judicial review are large, it is possible to make a collateral challenge to the reasonableness of an administrative action in the course of other proceedings. Thus a PCN can be challenged on the grounds that the local authority is acting Wednesbury unreasonably in issuing the PCN to the appellant and not to other people who have contravened the TMO in a like manner.

Such a challenge would fail if the council used folding signs which were covered up during school holidays (Cornwall) or signs which lit up when the pedestrian and cycle zone was in force and were blank at other times. In those cases, the council could point to the absence of visible signage as a relevant consideration in its decision not to issue a PCN notwithstanding that the TMO specified that the zone was in force.

Note that the test of unreasonableness is not "the man on the Clapham omnibus" but Wednesbury. The man on the Clapham omnibus might well say that it's reasonable only to issue PCNs when the school is in session. But if the TMO doesn't say anything about the school term or the school being in session, those are irrelevant considerations, so the decision is likely to be Wednesbury unreasonable.

If a collateral challenge is made to a PCN on the grounds of Wednesbury unreasonableness, the adjudicator will be obliged to consider it. This is likely to prove a very hard chestnut: adjudicators can hardly dismiss it out of hand, but to concede it is likely to lead to judicial review proceedings by the local authority against the traffic penalty tribunal (so zero financial risk to the appellant). The easy escape (for both the local authority and the tribunal) is to allow the appeal on other grounds which have been included in the appeal. So much the better if these are ones which involve findings of fact by the adjudicator, as those are final.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Hippocrates on July 28, 2025, 10:12:49 am
I drove on the A298 the other day and still they have yellow warning signs with school term time on them.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on July 24, 2025, 09:34:37 am
@Bustagate I’ve answered as many of your general questions as I can:

Quote
So they've removed all the "School term time" plates?
I believe so. All the sites I’ve passed no longer have them.

Quote
What about their yellow advisory signs which also refer to school term time?
They’re all still in place. They are non-compliant and inadequate in any case, but not necessarily required at every site.

Quote
Does this mean that they now issue PCNs during the school holidays?
Not to my knowledge, but the TMOs I've seen make no mention of holidays to they could do if they wish.

Quote
If not, how do they square that with the administrative law doctrine of not taking account of irrelevant considerations?
IMO there’s no legal requirement/duty for any council to actually issue PCNs.

Quote
Any idea when they started issuing PCNs for these signs, i.e. was it before 4 October 2022?
Well before January 2022 for several sites in Merton, but don’t know the exact dates.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on July 22, 2025, 11:33:34 pm
One place where "may be" is regularly used in legislation involving traffic signs is Except plates for No Entry signs, e.g. Schedule 3 to LLATfL Act 2003 (my capitalisation):
Quote
The traffic sign with diagram number 616 is a scheduled traffic sign for the purposes of section 4 (Penalty charges for road traffic contraventions) of this Act only if it indicates a restriction or prohibition which MAY BE indicated by another sign listed in the table.
In other words, if the restriction is one which can be represented by a blue roundel such as diagram 953, it's OK. If it's a plain vanilla diagram 616, it's not (because contravening one of those cannot be the subject of civil enforcement).

From the early days of bus restrictions (before TSRGD 1975), authorities have used diagram 616 + Except plates to implement bus gates. As they weren't signed as bus lanes, bus gates couldn't use the thick white line (diagram 1049) to separate the bus gate from other traffic. Instead, authorities separated them using traffic islands. To stop bus gates being used by other traffic, authorities put rising barriers across them, hence "bus gate". Here's what may have been the last of them (but the bus lanes approaching Hammersmith Bridge had rising barriers until 2019 to ensure at most two buses on the bridge at any time):

[attachimg=1]

From the late 1980s, the predecessor of DfT developed the blue roundel signs and started encouraging authorities to apply for special permission to use them. They became freely available in TSRGD 1994 as diagram 953 etc. DfT tried to get authorities to switch to the new signs, but some insisted on sticking with the old signage.

When DfT came to write legislation for civil enforcement, they included diagram 616 as a sign but required it to be accompanied by an Except plate which defined a restriction which could be imposed using one of the other signs which was the subject of civil enforcement. I surmise that the use of "or may be" in Schedule 3 LLATfL Act 2003 was a "catch-all" provision to cover authorities which used weird and wonderful signage which wasn't in Schedule 3 where they could have signed the restriction using signage which was in Schedule 3.

That's my perception of where "may be" came from in legislation for civil enforcement. I agree with @John_S that those writing the legislation had it in mind that civil enforcement of moving traffic offences was only to apply to a subset of possible signage as set out in a list of diagram numbers.


P.S Someone might like to check whether the City are issuing PCNs at the bus gate shown above (junction of Byward Street and Great Tower Street). It now has a No Entry sign with "Except cycles and authorised buses". That's not a restriction which can be signed using any of the blue roundels. Presumably the City authorises (for a fee) certain bus tours to use it; if they just wanted to restrict it to scheduled bus routes, they'd specify "local buses", for which they could use diagram 953 with "local" superimposed over the bus pictogram.

P.P.S. Is there any requirement with PCNs alleging contravention of a traffic order to specify the title of the traffic order? With my son's PCN, Harrow didn't specify it on the PCN but included a copy of the traffic order in the papers submitted for the appeal. Under section 7.2(3) of the Criminal Procedure Rules
Quote
(3) If the offence charged is one created by or under any Act, the description of the offence shall contain a reference to the section of the Act, or, as the case may be, the rule, order, regulation, bylaw or other instrument creating the offence.

[attachment deleted by admin]
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on July 22, 2025, 10:25:53 pm
"may be" = "is capable of being"

The fact that special authorisation was sought and obtained is a very strong indicator of a restriction which could not be conveyed by a scheduled traffic sign.

Does anyone know why Merton sought special authorisation in 2022? The scheme had been in place since 2020, initially under an experimental traffic order, with signs bearing the legend "Except for authorised vehicles"; see Merton School Streets newsletter of 18 September 2020 (https://www.merton.gov.uk/system/files?file=hillcross20-monkleigh20-school20street20newsletter.pdf)
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: cp8759 on July 22, 2025, 08:28:43 pm
Strategy of last resort: https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/ealing-cumberland-road-w7-code-53j-failing-to-comply-with-a-restriction-on-vehic/msg56444/#msg56444

Cases decided this year:

Nashrin Master v London Borough of Hackney (2240537076, 19 February 2025) (https://drive.google.com/file/d/1hu-p41Pvxehyuky0GpFJ7bt6_YdR-tuy/view)
Guaranteed Cleaning Ltd v London Borough of Lewisham (224056645A, 8 March 2025) (https://drive.google.com/file/d/1C-1hJTsZNNPIV4N1R9VSPcsagIjHS_b8/view)
Patrick Tuohy v London Borough of Haringey (2240550573, 18 March 2025) (https://drive.google.com/file/d/1XVZGa7keCakZ7K7uJ41_GiqLwClNVR3K/view)
Ivan Bachkov v London Borough of Newham (2250079444, 20 June 2025) (https://drive.google.com/file/d/1iBy4Gj1CzFEza6nfV9y8mLwolvbZ-C5a/view)
Fardowsa Ahmed v London Borough of Waltham Forest (2250119673, 18 July 2025) (https://drive.google.com/file/d/1YlT08xehrX48rHhVg0OjTDKf9lTVBo3g/view)

One variation on the same theme is to send a video on a physical CD by post, as councils seems to ignore them:

Stanmore Quality Services Ltd v London Borough of Islington (2250176349, 14 July 2025) (https://drive.google.com/file/d/1sqxZ124P0gtfBr-_3PQ4r1QwV4zRrPjF/view)
Commercial Plant Services Ltd v London Borough of Islington (2250222967, 21 July 2025) (https://drive.google.com/file/d/1aNhToW6R3O-D_udBdpVi6AMqeokQUVIW/view)

I suspect they've farmed out postal receipts to a third-party scanning centre that just throws CDs and other media in the bin.

As the name suggests, the strategy of last resort can win virtually any case if executed correctly, regardless of the underlying merits of the case. The only exception I've seen are Tower Hamlets and sometimes Brent.

Of course in any case where representations have been made already, it's too late.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on July 22, 2025, 07:33:56 pm
I’d be interested in the opinions of others on this. When powers were given to local Councils to enforce moving traffic contraventions it was widely publicised that they were limited to certain types of traffic sign - hence Schedule 3.

LLATFLA section 4 goes on to define (re sub-section (5)(a)):

“prescribed order” as: “an order under section 6 or 9 of the Act of 1984 which makes provision for a relevant traffic control”;

then “relevant traffic control” as “any requirement, restriction or prohibition (other than a requirement, restriction or prohibition under the lorry ban order) which is or may be conveyed by a scheduled traffic sign”;

then “scheduled traffic sign” as “a traffic sign of a type described in Schedule 3 to this Act”.

Put these three definitions together and IMO you get: (5)(a) requires a scheduled traffic sign to be in place. I believe the underlying intention of the LLATFLA draftsman was to limit PCNs to certain traffic signs. This is further supported by the limited contravention codes that have been assigned for use on PCNs.

EXCEPT... I can’t be sure what’s meant by the words “or may be” in the definition of “relevant traffic control” - hence my original question 12 months ago.

An alternative way of looking at it is that Merton School Streets TMOs are too complex to be conveyed by scheduled traffic signs because the TMO exemptions are not permitted variants of such signs. So they need special authorisation signs. So their TMOs fall outside the definition of “relevant traffic control”. It then follows that PCNs cannot be issued.

Hope this all makes sense.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on July 22, 2025, 03:49:00 pm
I've taken another look at s.6 LLATfL Act 2003 and now think I answered your initial question wrongly. Sorry!

While Merton's signs are not "scheduled section 36 traffic signs", that merely means that someone passing such a sign does not engage subsection (5)(b):
Quote
fails to comply with an indication given by a scheduled section 36 traffic sign.
but subsection (5)(a) is still engaged:
Quote
acts in contravention of a prescribed order;

Subsection (6) ensures that a single action does not give rise to the issuing of two PCNs. The result is:

IF someone fails to comply with a scheduled section 36 traffic sign
THEN a penalty charge is payable under subsection (5)(b)
ELSE IF someone acts in contravention of a prescribed order
THEN a penalty charge is payable under subsection (5)(a)
END IF

The Parliamentary draftsmen are better at their job than Merton are at theirs. Merton's correct answer to my FoI would have been:

We haven't issued any PCNs for contravening signs to diagram 618.3C because we haven't got any signs to diagram 618.3C.

To the supplementary question which I didn't ask, the answer would have been:

We've issued lots of PCNs for contravening TMOs under our School Streets programme

I conclude that challenges to Merton's PCNs have to be about the adequacy of the signage, in particular that which people see before they're committed to entering the Pedestrian and cycle zone.

Back to Rivercourt Road, Camrose Avenue and the like: there, although the TMO is legally valid (because it wasn't challenged within the first six weeks), the restrictions which the TMO imposes may not be what the Council thinks they are.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on July 22, 2025, 02:20:24 pm
@John_S So they've removed all the "School term time" plates? What about their yellow advisory signs which also refer to school term time? Does this mean that they now issue PCNs during the school holidays? If not, how do they square that with the administrative law doctrine of not taking account of irrelevant considerations?

While the policy objective may be about discouraging the use of cars to take children to school, the TMOs do not make any distinctions. Either Merton issue PCNs consistently to those contravening the TMOs or they act ultra vires. If they had hinged signs, they could remove them from display during the school holidays and stop issuing PCNs.

Any idea when they started issuing PCNs for these signs, i.e. was it before 4 October 2022? Also, when did they put "   Except   " over "Except for"?
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on July 22, 2025, 11:02:58 am
@Bustagate This is a tricky one. I’m not aware of any Merton School Streets appeals that have been won on signage alone since they removed all the ‘School term time’ plates. I’ve briefly checked the appeals register and noted that appeals are still being refused for Merton School Streets.

A starting point might be to appeal a PCN based on the LLATFLA argument alone. If that loses, it’s back to the drawing board.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on July 22, 2025, 09:59:20 am
@John_S I've had a reply from Merton (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch#incoming-3059309) to my FoI about their issuing PCNs in respect of a sign which is not diagram 618.3C. They make the true but irrelevant statement that they can issue PCNs for contraventions where the sign used is diagram 618.3C. I've replied (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch#outgoing-1902178) to point out that they have special authorisation for their sign, so it isn't included in Schedule 3 to LLATfL Act 2003, hence they don't have the power to issue PCNs.

Any thoughts about how to pursue this further? I agree that judicial review carries unacceptable risks. What I'm trying to do at this stage is to put Merton on public notice that, as their sign isn't in Schedule 3, they can't use s.4 of LLATfL Act 2003 to issue PCNs. While one could make a report to the City of London police about suspected fraud (obtaining money by making false representations), I'd be very surprised if they picked it up.

What I might do is to report the matter to Merton's auditors and suggest that a note to the accounts would be appropriate about a contingent liability in respect of PCN income. While it's not material yet, it will grow over time as more PCNs are issued and with accumulated interest on eventual refunds (just ask the banks about PPI or interest rates on car loans). Having the auditors asking questions might discomfit Merton.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: cp8759 on June 23, 2025, 02:12:54 pm
Unfortunately, legislation.gov.uk only has LLATfL Act 2003 in its enacted form and one needs to check subsequent legislation to work out what the current version is. I searched for primary and secondary legislation since then which included the words "London Local Authorities" and within them for "2003". There are no SIs which are relevant and no Acts since 2013, so it's not surprising that I couldn't find any reference to diagram 618.3C in the Acts which do reference the LLATfL Act 2003; these are the LLA Act 2007 and the LLATfL Act 2008.
Look at the this box:

(https://i.imgur.com/W3jL7YA.png)

on this spreadsheet (https://docs.google.com/spreadsheets/d/1pVrE76_RYY6bNmEpYGbsZkxtpfIeud_BT3SKfg7TzQM/edit?gid=104124265#gid=104124265&range=A37:A50).
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: cp8759 on June 23, 2025, 01:55:36 pm
Thank you. Does the source for your statement that diagram 618.3C is now included cite the legislation which amended Schedule 3 of LLATfL Act 2003?
I assume southpaw82 just looked at the consolidated legislation on LexisNexis, but to answer your question see regulation 4 of The Civil Enforcement of Traffic Contraventions (Consequential Amendments) (England) Regulations 2018 (https://www.legislation.gov.uk/uksi/2018/488/regulation/4/).
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on June 23, 2025, 01:55:17 pm
Thank you to @John_S for referencing the drawing number of the DfT special authorisation (https://assets.dft.gov.uk/trafficauths/case-5067.pdf) for the Merton signs. [A warning to those using the DfT page for special authorisations (https://www.dft.gov.uk/traffic-auths/): unlike most search functions, this one is case-sensitive: a search for "merton" doesn't find any.]

The fact that the signs are special authorisations means that they aren't permitted variants and so lie outside the scope of Schedule 3 of LLATfL Act 2003 and therefore of section 4 of the Act.

While this may appear to be a bit of a technicality, and therefore less attractive as a line of argument before an adjudicator, it strikes at the heart of Merton's practices. It appears to me that they have been acting ultra vires and potentially fraudulently (obtaining money by false representations) by issuing PCNs without a sound legal basis.

While they may be able to claim that they have lacked mens rea until now, I have now made an FoI request to them (https://www.whatdotheyknow.com/request/pcns_issued_for_signs_not_in_sch) which puts them on notice that the legislation does not support their issuing PCNs for contravening their non-prescribed (but authorised) version of diagram 618.3C.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: John_S on June 23, 2025, 10:01:03 am
@Bustagate makes some very interesting points here and in relation to Rivercourt Road / Great West Road, Hammersmith. I’ll deal with two issues briefly:
- Merton School Street signs, and
- Advance Warning signs.

Merton School Streets

Their signs are specially authorised - see DFT: GT50/090/0025 (01.10.2022). However in my opinion the use of the signs are inappropriate and create unnecessary confusion. At some school streets sites they are poorly positioned and require advance warning.

About 12 months ago I posed the question, “Can specially authorised signs be used to enforce moving traffic contraventions?” I tend to agree with @Bustagate in that it appears they cannot. Neither the TMA2004 nor the LLATFLA 2003 mention special authorisations. If I’m wrong, I'd very much appreciate guidance towards the legislation that allows this. I wonder whether @cp8759 or any of the other experts have a view on this?

In the recent Merton cases I’ve taken to adjudication, I’ve won on other substantive grounds and not applied the special authorisations argument.

Advance Warning Signs

In my opinion, advance warning signs are required for an enforcement authority to comply with the LATO Regulations 1996 in some cases. The main question here is, “Do they need to be compliant?”

@Bustagate cites R (Oxfordshire County Council) v. The Bus Lane Adjudicator [2010] EWHC 894 (Admin) in another post, which helps but doesn’t in my view go far enough. The closest I have come to answering the above question is Costello v LB Merton, ETA ref 2240078999 application for review/reasons for refusal, Apr 2024.

Although this is not a binding judgement, it states that adjudicators acknowledge that advance warning signs need to be at least ‘adequate’. I would argue that anything less than substantial compliance with the regulations would render most advance warning signs inadequate - especially worded signs that need to be assimilated by drivers on the move.
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on June 22, 2025, 09:04:56 am
Thank you. Does the source for your statement that diagram 618.3C is now included cite the legislation which amended Schedule 3 of LLATfL Act 2003? If so, what is it, please?

Paragraph 3 of Schedule 3 of LLATfL Act 2003 states:
Quote
The signs include permitted variants of the signs as described in the 2002 Regulations.
Is there an analogous statement referencing TSRGD 2016 in the amended Schedule 3? If so, Merton's sign would appear still not to fall within its scope as "Except authorised vehicles" is not a permitted variant for the middle panel of diagram 618.3C.
[attachimg=1]

There is also the issue as to whether TSRGD 2016 permits the variation of "time period" in the upper panel to display two time periods. Two time periods are shown on the bus lane signs in TSRGD, e.g. diagrams 958, 959B. The wording in Chapter 3 of the Traffic Signs Manual is quite different:
Quote
Bus lanes
9.3.7.  The times during which the bus lane operates are shown in the bottom panel of the signs to diagrams 958 and 959B. Where there is more than one bus lane along a particular length of road or within the same geographical area, the times of operation should be consistent, where possible, to avoid driver confusion. The working drawings show how time periods are accommodated within the fixed width of the signs. Time periods must be expressed in the manner described in S18‑1 (see also Chapter 7).

Pedestrian and Cycle Zones
6.2.2.  Where the zone is operational for 24 hours on every day of the week, no times are shown on the sign other than those relating to the exceptions. If the zone is part‑time, the operational period is shown in the upper panel below the legend “No vehicles” or below the “no motor vehicles” roundel as appropriate. Where the zone operates only on certain days of the week and for 24 hours on those days, the days only are shown on the sign; the expression “At any time” is not used. Examples of the top panel for zone entry signs are shown in Figure 6‑3. The operational period is not normally shown where a variable message sign is used.

DfT was evidently concerned about the complexity of the pedestrian and cycle zone signs and how readily they could be assimilated by drivers:
Quote
6.2.5.  If the entry restrictions change during the day or on different days of the week, a variable message sign is recommended to avoid a complex legend that can be confusing and difficult to read. In this case, the upper panel should not include a time period. The sign should show a complete blank grey or black face, as defined in Schedule 1, during the times when the zone is not operational. The lower yellow panel can be displayed on the variable message sign only during the operational period of the zone (i.e. when the upper and middle panels are displayed).
In effect DfT were saying: if it's complicated, use a variable message sign which lights up when the restrictions apply and is blank when they don't. That was based on their experience while the signs were special authorisation. Then they could reject signs which could not readily be understood from a moving vehicle.

Once DfT put the sign in TSRGD, councils could do what they wanted. Councils have: why incur the cost of a variable-message diagram 618.3C when a complex static sign generates income from PCNs which is mostly paid by those who are from outside the borough?

[attachment deleted by admin]
Title: Re: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Southpaw82 on June 21, 2025, 06:14:51 pm
Diagram 618.3C is indeed listed in the table in the current version of Paragraph 4 of Schedule 3 to the London Local Authorities and Transport for London Act 200.
Title: Merton's PCNs for Contravening Pedestrian and Cycle Zone Signs to Diagram 618.3C
Post by: Bustagate on June 21, 2025, 02:20:53 pm
I've come late to the thread Moving Traffic Contraventions in London (https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/moving-traffic-contraventions-in-london/) in the context of "sign overload" at Rivercourt Road (https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/hammersmith-and-fulham-code-52m-failing-to-comply-with-a-prohibition-on-certain-). I was intrigued by the OP's question "can ‘special authorisation’ signs be used for moving traffic contraventions under the 2003 Act?"

The sign which is at the heart of Merton's signage and which they use to allege a contravention is diagram 618.3C, TSRGD 2016 Schedule 8 (https://www.legislation.gov.uk/uksi/2016/362/schedule/8/made) Part 2 Item 2. This was not in TSRGD 2002 but, in accordance with DfT practice, was held in reserve as a sign which they rolled out with special authorisation when someone asked for it. Having tested it as a special authorisation sign for some years, they then made it available for general use in TSRGD 2016. They seem to have used this practice repeatedly over the years: in the late 1980s/early 1990s they tested diagrams 953 and associated signs before introducing them in TSRGD 1994. 

In accordance with TSRGD 2016, the signs which Merton use omit the bottom panel (which shows waiting restrictions). TSRGD 2016 provides various options for the Except panel, which include "permit holders" but not "authorised vehicles". I do not know whether Merton obtained special authorisation for this. I consider that, however, to be a minor detail.

The main issue is the one raised by the OP: is the sign one for which moving traffic PCNs can be issued? As a London authority, Merton's moving traffic PCNs are issued under London Local Authorities and Transport for London Act 2003. Schedule 3 of this Act (https://www.legislation.gov.uk/ukla/2003/3/schedule/3/enacted) lists the signs which are scheduled for the purposes of section 4, i.e. contraventions which can be the subject of PCNs. As this schedule was written for TSRGD 2002, it's not surprising that it doesn't list diagram 618.3C.

Unfortunately, legislation.gov.uk only has LLATfL Act 2003 in its enacted form and one needs to check subsequent legislation to work out what the current version is. I searched for primary and secondary legislation since then which included the words "London Local Authorities" and within them for "2003". There are no SIs which are relevant and no Acts since 2013, so it's not surprising that I couldn't find any reference to diagram 618.3C in the Acts which do reference the LLATfL Act 2003; these are the LLA Act 2007 and the LLATfL Act 2008.

It therefore appears to me that the answer to the question which the OP posed is "No". The relevant legislation, LLATfL Act 2003, does not define a contravention of diagram 618.3C as being an offence under section 4. That being so, it appears to me that all of Merton's PCNs alleging contravention of diagram 618.3C were false allegations. 

This argument may help others facing PCNs for contravening any of Merton's signs to diagram 618.3C. How the legal system handles past false allegations by Merton I leave to others.