There is no bus lane signage in place. The only signs placed are signs conveying a route restricted to certain vehicles. In this case the signs convey that the route is restricted for use by buses, pedal cycles and taxis only. Contravening this sign is, according to (https://assets.publishing.service.gov.uk/media/6294ddfa8fa8f5039a1bd695/annex-a-traffic-signs-subject-to-moving-traffic_enforcement.pdf)Govt guidance (https://assets.publishing.service.gov.uk/media/6294ddfa8fa8f5039a1bd695/annex-a-traffic-signs-subject-to-moving-traffic_enforcement.pdf), a moving traffic contravention and not a bus lane contravention. Therefore the appropriate contravention description is Code 33 - Using a route restricted to certain vehicles. You can use the text below in your formal reps but also wait to see if others offer other angles of attack.
The Statutory Guidance for Local Authorities Outside London on Civil Enforcement of Bus Lane and Moving Traffic Contraventions issued by the Secretary by State for Transport does under Annex A, advise that the round blue sign is a traffic sign conveying a moving traffic contravention. The Council has wrongly accused me of a bus lane contravention. The correct description for contravening the sign is code 33 "using a route restricted to certain vehicles"
As demonstrated by the aforementioned Annex A, the wrong contravention description is stated on the PCN and for this it should be cancelled. Should the Council not agree with this point of law, I require the Council to give full reasoning for any rejection with counter arguments directing me to the law that the Council rely upon for their rejection and for dismissing the guidance issued by the Secretary of State.
I suggest you also point out that the PCN is missing the statutory ground of appeal below which also merits cancellation of the penalty under the ground of procedural impropriety.
(i)the enforcement notice should not have been served because—
(i)the penalty charge has already been paid in full, or
(ii)the penalty charge has been paid, reduced by the amount of any discount set in accordance with Schedule 9 to the TMA 2004, by the applicable date as specified in paragraph 1(3) of Schedule 3 to the 2022 General Regulations.