Free Traffic Legal Advice

The whole basis of these School Streets signs as applying only during school terms is flawed. The traffic orders generally apply throughout the year: if possible, check the one which applies to the specific site. As section 12.4.1 of Chapter 7 of the Traffic Signs Manual explains:

12.4 Time of year
12.4.1. Where the restriction or prohibition applies for only part of the year, the appropriate dates are added to the sign. These can be expressed as specific dates, or months only, to accord with the traffic regulation order. Expressions such as “Term time” (to reflect school periods) are not permitted, but where a named day such as “Good Friday” is consistent throughout the country and familiar to road users, this may be used. References to bank or public holidays are permitted by the Regulations.

The issue is that, in essence, "term time" is not a well-defined legal term, so the lawyers aren't able to include it in the traffic order.

Local authorities pretend that the order applies only during term time. They may issue PCNs only in term time. But in so doing they are failing in their duty to implement the traffic order properly. As you make your bed, so must you lie. Taking account of irrelevant considerations (such as whether the school is in session) opens them to challenges of acting ultra vires, which renders their actions void.

DfT advice about setting up school streets states

As School Streets usually operate only in term-time, flap-type signs are recommended that can be folded to show a blank face during school holidays. Arrangements will need to be made for carrying this out, including access and keyholding.

I believe that Cornwall does this. I don't know what their traffic orders say, but it is a recognised practice to have folding signs for restrictions which apply at irregular times, e.g. road closures around RAF Brize Norton when repatriating dead servicemen and women. Whenever the sign is displayed, it applies.

In my view, the DfT are remiss in failing to explain the legal impediments to using "term time only" on signs, why folding signs should be used instead and what the traffic order should say to allow the signs to be displayed only during term times. I shouldn't be surprised if Hackney, the local authority they quote as a pioneer, doesn't get it right, but for political reasons they don't want to draw attention to this.

For school streets, even with folding signs there's still the issue of the times that they apply. These are written in text which is so small that it's unreadable until you are so close that you're probably committed and would cause an accident if you stopped and tried to turn round. There is a Scottish version of the sign which has flashing lights when the restrictions are in operation. You don't need to know whether it's gone 09:15 or not. That seems a much better approach.

If you go down this line of argument, the problem which you will face is that the council will reject it. Adjudicators will find it a challenge: they have half an hour for each case and a knotty legal argument is the last thing they want. If they were to find in your favour, the local authority might not take it lying down but could seek a review, initially from a more senior adjudicator, but them by judicial review. Although this wouldn't cost you anything (the case is between the council and the tribunal), the very fact that such a case could arise makes adjudicators loth to allow them to arise.

Having said that, if you put in a frontal challenge to school streets and offer the adjudicator an off-ramp of some reason which applies to the particular circumstances, the adjudcator may allow your appeal to satisfy the requirements of justice without exposing the tribunal to the risks of judicial review.

In your case, the inadequacy of advance signage warning of the school streets restriction could be such an off-ramp. All that is provided is a small blue sign declaring "School Streets Ahead" without even saying where it is. A proper advance notice sign would show that a right turn has a restriction and what that restriction is.

I've now worked out how this monstrous bus gate came to be created.

Enfield's Change of Plan

Originally, Enfield proposed a bus gate 20m south of where it is now. It was to be formed as a chicane using large planters. The southern planter is shown on this plan. The northern planter isn't shown because its location has been covered by the revised bus gate. It would have been on the west side of the road, I surmise as far north as the southern area of block paving is.

After the original plan had been approved, Enfield appear to have realised or been told:

• it would cause mayhem because HGVs would no longer be able to access yards on the industrial estate as they had been doing. Instead, they would have to reverse large distances and round corners;
• Haringey wanted to have a new vehicular access into the Bull Lane playing fields which would be in the middle of the bus gate.

That led to revisions to the plan and a second round of consultations. The bus gate was moved north, to where it has been built. The planters were replaced with "carriageway build-outs" which were constructed of block-pavers with granite kerbs around them which were set "flush with the carriageway". In other words, they weren't build-outs at all.

Why the "Build-outs Flush with the Carriageway"?

This unusual (unprecedented?) form of "build-out" was necessitated by the requirement to allow HGVs to enter the yard at 22, Bull Lane (the southernmost commercial premises, which includes Demitris Motors). They do this by going beyond the entrance and then reversing in. In so doing, they make use of the full width of the carriageway. Any physical obstruction, such as build-outs, would prevent their entering the yard.

There wouldn't have been any problems for HGVs if the bus gate had been moved south and converted to build-outs on both sides of the road at the same point rather than a chicane. Such build-outs could have been put to the north of the existing vehicular cross-over and gates into the Bull Lane playing field. This vehicular access could have been widened to 6m without impinging on such a bus gate.

So the bus gate that is there now was an exercise in trying to say "yes" to Haringey's plans when they were a gleam in Haringey's eye. Enfield could have said "Sorry, it's just not possible. We've got to allow HGVs to use the yard at 22, Bull Lane. That means that any bus gate has to be at least 20m (preferably 25m) south of the entrance to the yard. We'll put the shortest bus gate we can south of that, which will leave you space to widen your existing vehicular access just north of the borough boundary from 3m to 6m."

But Enfield didn't. Instead, they built the bus gate we see today.

Approach to the Bus Gate from the North

The bus gate's defects are not just at the southern end of Bull Lane. They extend all the way from Bull Lane's junction with Wilbury Way/Bridport Road ¼ mile to the north. To the north of this, a segregated two-way cycle track has been created on the west side of Bull Lane. But to the south, there are no cycle lanes at all. Nor has the speed limit been reduced from 30 mph to 20 mph by creating a 20 mph zone. This would have enabled the council to install whatever traffic-calming measures it saw fit.

Instead, the council has used a single traffic order both to restrict the vehicles which can pass through the bus gate and to create the traffic-calming features around the bus gate. This means that the vehicle restrictions extend from the start of the traffic-calming features to their end. And from one edge of the highway to the other, i.e. across the footways as well as the carriageway.

Enfield appear not to have taken seriously the advice in the Traffic Signs Manual about the signage of bus gates or about how large signs need to be, especially those which contain words (e.g. map-type advance direction signs). There is a complete absence of signs warning of the bus gate ahead between the junction with Wilbury Way/Bridport Road and the bus gate, a distance of ¼ mile.

That is not normal. It offers scope to challenge PCNs by quoting Coombes v DPP [2006] EWHC 3263 (Admin) and using the argument set out in paragraphs 4.22 - 4.31 of the Chief Adjudicator's Review of TPT Decisions on John Dobson Street, Newcastle.

There's also the "hot potato" of the conduct of Enfield's second round of statutory consultation. This asserted that the revised bus gate had "carriageway build-outs" rather than planters. Any normal reader would interpret that as meaning that the chicane around the bus gate would now take the form of build-outs rather than planters. Yet these "build-outs" were actually areas of block paving flush with the carriageway. They did not narrow the carriageway or force vehicles to slow down. While this could be discovered by careful study of the drawing (which was available on the website), few, if any, of those consulted would have understood this.

The rest of this post presents this history. A further post will analyse the signage.

First Round of Statutory Consultation

On 6 October 2021 Enfield went out to statutory consultation with this letter. It followed an earlier Community engagement letter which included a schematic map. This showed a bus gate at the southern end of Bull Lane but did not show the form which the bus gate took. It is not clear whether more detailed plans of the bus gate were sent to statutory consultees.

The schematic map also showed "modal filters" at the junctions between Bull Lane and Amersham Avenue and between Bull Lane and Shaftesbury Road. These restricted the vehicles which could pass through the filter to pedal cycles. Enfield stated that they would be signed using No Motor Vehicles rather than No Entry with "Except cycles" plates because the latter would prevent the emergency services from using them while No Motor Vehicles did not. Curiously, they don't seem to see any problem with the blue roundels which they have placed at the Bull Lane bus gate, which have exactly the same effect as No Entry signs with "Except buses and cycles" plates.

Second Round of Statutory Consultation

On 9 November 2022 (i.e. more than one year later), Enfield went to a second round of statutory consultation.  This letter started by explaining that the project had been approved and that construction had started:

A statutory consultation on the draft traffic orders for this project was undertaken in late 2021, the project was granted approval in March 2022, and construction began in May 2022.

In other words, no significant changes had been required as a result of the first round of statutory consultation. Everything had been proceeding smoothly until something unspecified had forced a rethink. It continued:

We are now proposing changes to two aspects of the traffic orders which relate to:

• a modal filter at the junction of Shaftesbury Road with Bull Lane, and
• a bus gate at the southern end of Bull Lane.

. . .
All of the changes proposed can be seen on the drawings accompanying the draft traffic orders, which can be found in the document library section on the right-hand side of the project page: http://letstalk.enfield.gov.uk/nmh-ati.
. . .
The main changes, which do not affect the purpose of the previous proposals, are summarised below:
Bull Lane

• Relocation of the bus gate approximately 20 metres further north
• Change from planters at the bus gate to carriageway buildouts

Reading between the lines, I surmise that businesses on Shaftesbury Road and Bull Lane had realised the implications of Enfield's plans: HGVs which accessed industrial premises on the affected roads had been in the habit of making short reversing manoeuvres on entry to or exit from the premises. Enfield's plans would require them to reverse all the way back to the preceding junction. This would cause mayhem and possible gridlock.

Plans of the Bus Gate

The drawings of the bus gate which are available now are Metis Drawing No: 20148-MET-0010-02-DR-001 Revision C dated 30 September 2022. The revision history shows that it was first issued on 16 May 2022, so was not part of the first round of consultations.

But it does show what looks remarkably like a large planter on the east side of Bull Lane 13m north of the boundary with Haringey. I surmise that it was part of the original plan for the bus gate and that there was a second large planter on the west side of the road roughly as far north as the southern area of block paving is now.

If that was the location of the northern planter, its northern end would have been about 8m south of the entrance to the yard at 22, Bull Lane.

Reasons to Move the Bus Gate South

Rigid HGVs are up to 12m long. The reversing manoeuvre to get through a gateway requires an HGV to leave a full vehicle's length clear between the further gatepost and the rear of the vehicle before it starts reversing. I have shown the swept path in the section about Bull Lane on this web page.

Enfield's original plan was therefore not compatible with the well-established use by HGVs of the yard at 22, Bull Lane.

While a change to the bus gate was therefore required, the obvious solution would have been to move it south and convert it from a chicane to build-outs which narrowed the road on both sides at the same point. Bull Lane isn't wide enough to have a cycle gap on even one side, but such a bus gate could have been installed north of the vehicular cross-overs on both sides of Bull Lane just north of the boundary with Haringey. This can be seen (in orange) on the same aerial view as the swept path.

Bus Gate Moved North

The bus gate was not moved south. It was moved north. The drawing shows the "Indicative potential location of future Selby Urban Village Development access". It is where the northern planter would have been. Enfield has evidently responded to a request from Haringey to change its plans for the bus gate to accommodate a future vehicular access to the Bull Lane playing fields. Unlike the planter in Enfield's original proposals, the solution which I outlined in the preceding section of moving the bus gate south would not have interfered with the use of the proposed vehicular access, but it would have put it on the other side of the bus gate from Haringey.

Enfield evidently sought to accommodate Haringey's wishes. They moved the bus gate 20m north. This brought the bus gate right to the entrance to the yard of 22, Bull Lane. An aerial view of it is shown to the right of the aerial view with the swept path. The purple rectangle shows the land defined in the traffic order as subject to its restrictions. The traffic order permits goods vehicle manoeuvring to enter the yard to make use of the land subject to the traffic order.

Failure to Create a 20 mph Zone

The reason why the traffic order covers the full extent of the "carriageway build-outs" is presumably because highway authorities need a traffic order to implement traffic-calming measures. But, as already observed, this is a curious traffic-calming measure which doesn't actually impede traffic (except cyclists, who prefer their road surface smooth).

It's also because Enfield haven't done the obvious thing for a designated cycle route which lacks any cycle lane, whether on or off the carriageway: create a 20 mph zone and apply traffic-calming measures. If they had done that, the "carriageway build-outs could have been authorised under the traffic order imposing the 20 mph zone and the bus gate order could have applied only where Enfield actually propose to enforce the restriction.

As it is, almost every vehicle entering or leaving the yard at 22, Bull Lane or the future entrance to the Selby Centre is legally liable to the Moving traffic penalty and relies on Enfield's forbearance (if that isn't a contradiction in terms) not to issue them with one.

When is a Build-out not a Build-out?

By 30 September 2022 (the date of the drawings of the bus gate which are available today), Enfield's consultants, Metis, had evidently worked out that the only way to allow HGVs to access the yard was to remove any obstructions from the carriageway. The drawings still showed build-outs with kerbs, but the kerbs were marked as "flushed with carriageway level" and the areas of the build-outs were formed of "Grey Block Paving Herringbone ... built to Traffic Loading Standard".

In other words, the "build-outs" weren't build-outs: they were part of the carriageway.

While the drawings do indeed show the nature of these very unusual "build-outs", the attention to detail required to work this out would be beyond most people. The text of the letter for the second round of statutory consultation asserted that the revised bus gate had "carriageway build-outs" rather than planters. This term is sometimes used by other highway authorities to mean a build-out. The usage may refer to the fact that most build-outs are now constructed in the carriageway with either a gutter or a cycle gap between them and the footway. This avoids problems with road drainage which arise when a build-out interrupts the gutter.

DfT's Local Transport Notes about Traffic Calming and Bus Priority Measures define build outs as being kerbed structures at the level of the adjacent footway, as does The Highways (Traffic Calming) Regulations 1999. Build-outs narrow the carriageway. That was not the case here.

Construction and Start of Enforcement

Residents and business owners were sent a letter dated 23 June 2023 informing them that work would begin on 31 July 2023 to construct the bus gate and that it was expected to take 3 - 4 weeks.

A further letter dated 22 August 2023 informed them that camera enforcement would begin on 29 August 2023.

The large advance direction sign is not as prescribed in TSRGD 2016 and so is not a lawful traffic sign. It should not have been placed on the public highway. The error lies (inevitably) in the plate below the blue roundel.

The blue roundel on such a sign is TSRGD 2016 Schedule 12 Part 20 Item 36 with the word "taxi" removed.

The optional symbol representing plates which are prescribed to appear beneath circular symbols (including the blue roundel) are listed in column (4) of Item 45 of TSRGD 2016 Schedule 12 Part 20. The only plate which is permitted for Item 36 is at paragraph 4. of this: "and authorised vehicles".

Nottingham's special authorisation for this plate only allows it to be placed beneath a blue roundel which is being installed under TSRGD 2002. That statutory instrument was superseded by TSRGD 2016 and has now been revoked. Even if Nottingham had special permission for a plate under TSRGD 2016, that would not extend to its use on an advance direction sign unless the special permission included a separate symbol-form of the plate for use in TSRGD 2016 Schedule 12.

The erroneous plate adds to the verbiage on the sign, which is already excessive and diminishes its comprehensibility. Our modern traffic signs were designed by the Worboys Committee in 1963. The third (of seven) principles was:

(c) they should contain only essential information and their significance should be clear at a glance so that the driver’s attention is not distracted from the task of driving;

Signs such as the advance direction sign on Canal Street have become too complicated. Too much information has been crammed onto them. The result is that they cannot be read and assimilated from a moving vehicle.

At the top, there is a panel with the traffic camera symbol. Beside it is the legend "24 hr Bus Lane enforcement ahead". The traffic camera symbol appears nowhere in TSRGD 2016 Schedule 12. Normally, when a sign with a camera symbol appears next to an advance direction sign, it is a separate traffic sign, which is prescribed as diagram 878 (TSRGD 2016 Schedule 11 Part 2 Item 63. The options for the legend are:

• Traffic signal cameras
• Speed cameras
• Average speed check
• Traffic signal and speed cameras
• Traffic enforcement cameras
• Police cameras
• Police enforcement cameras
• Bus lane cameras

The most appropriate in this context would appear to be "Bus lane cameras".

Coming down to the main panel, Worboys' principle (c) suggests that the text identifying the names of the car parks is not essential. Omitting these would allow the location of the Lace Market car park to be shown schematically at the far right of the sign, below an extended horizontal black line.

The omission of the names of the car parks would also allow a warning triangle with a tram (in this context TSRGD 2016 Schedule 12 Part 20 Item 16) to be placed interrupting the horizontal black line. This warns that turning right leads to on-street trams before you reach the Lace Market car parks. Some motorists may be deterred by this and prefer to use the car park just beyond the roundabout ahead.

The words "City centre" seem justified on this sign. They could be placed above the horizontal black line to the right of the red triangle warning of the tram.

The blue rectangles with a white "P" on this advance direction sign provide information. That is very different from the meaning of the blue roundel showing a bus and a cycle. That serves two purposes:

• it conveys information to drivers of the vehicles shown that they are permitted
• it prohibits other vehicles

Red on a traffic sign is immediately understood to convey prohibition or warning. Given the presence of the informatory blue rectangles with a white "P", at a casual glance a blue roundel can easily be misunderstood as similarly informatory. The difference between a circle and a rectangle (which is what distinguishes mandatory from informatory) is far less than that between blue and red.

The effect of the bus gate could be conveyed to the vast majority of road users by the use of a horizontal red bar (TSRGD 2016 Schedule 12 Part 7 Item 8 ) instead of the blue roundel with its plate.

Advance direction signs simplify: they do not show every detail. If they do, they lose comprehensibility. Taxi drivers in Nottingham already know that to use bus lanes they must be wheelchair-accessible. The people who will need to look at and understand the advance direction sign are those who rarely venture into the centre of Nottingham. Few of them will be the drivers of buses and wheelchair-accessible taxis who would miss out by not being told that they can actually get through what is, for the vast bulk of motorists, a dead end.

With the elimination of the space for the blue roundel and its plate, there is now space at the bottom of the advance direction sign to include a section which advises other traffic to do a U-turn at the roundabout. This is used at similar locations (e.g. Parker Street, Cambridge) and consists of the words "Other traffic" with an arrow indicating a U-turn at a roundabout ahead (TSRGD 2016 Schedule 12 Part 5 Item 2).

@John_S (among others) I've previously raised the issue of the comprehensibility of diagram 618.3C signs used for "School Streets" (TSRGD 2016 Schedule 8 Part 2 Item 2). In this post I argued that the signs on Cumberland Road, Ealing were three times the complexity of the most complex days and times shown for these signs in the Traffic Signs Manual and that this caused cognitive overload.

In 2011 as part of their Traffic Signs Policy Review, DfT commissioned research into the understanding of traffic signs. A panel of 820 people were shown a selection of signs and asked questions about them. Each sign was shown to a minimum of 200 people.

Among the signs tested was diagram 959 (now with added motorcycle as diagram 959B TSRGD 2016 Schedule 9 Part 4 Item 10). This sign for the start of a nearside with-flow bus lane has at its bottom a panel with the period of operation. In the sign which was tested this was:

Mon - Fri
7 - 10 am
4 - 7 pm

The survey reported as the Key Area of Misunderstanding

Taking in time restriction when seen on the move (78% of those shown sign statically got all comprehension questions correct compared to just 42% of those who saw it dynamically)

Diagram 959/959B uses an x-height for the text of 50mm. Diagram 618.3C uses an x-height of 37.5mm. If seeing the times dynamically halved respondents' ability to process the information, imagine what effect using text which is 3/4 the size would have.

That's ignoring the other difference between diagram 959 and diagram 618.3C as used in school streets signs: the complexity of the times used. For Ealing's sign it was:

Mon - Fri
8.15 - 9.45 am
2.45 - 3.45 pm

In my earlier post I suggested that the way to compare complexities was to count syllables:

That's where I got the figure of three times the complexity before. For the test it's 1.8.

I also drew attention to DfT's advice in paragraph 6.2.5 of Chapter 3 of the Traffic Signs Manual:

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).

I hope that this will help those fighting PCNs issued for contravening these signs. It's one thing to look at an image of a sign. It's quite another to see a sign as you're driving along. When it is used in residential streets with parked cars around, diagram 618.3C doesn't make sense. It's headed "Pedestrian and Cycle Zone", yet what you're seeing is an ordinary residential street rather than a main shopping street. The Scottish version with flashing lights, diagram 618.3D, TSRGD (Scotland) 2022 Regulation 5.—(4)(b) makes much more sense. It would be even better if they replaced the words at the top with "School Zone".

It appears that West Sussex are part of a trend. I found reports about bans in the following areas:

• North Yorkshire
• Lytham St Annes
• Felixstowe

As this is a long post, I'll set out the conclusions for motor caravanners here: unless the local authority has changed since 2012 (e.g. Northamptonshire has split and Surrey is about to), these signs are valid.

On 5th March 2012, DfT issued special authorisations to 152 local authorities for a package of signs "Traffic signs policy review area-wide authorisation third edition". This package included a yellow plate sign specifying times of parking restrictions for motor caravans.

The special authorisations have no end date and apply throughout the specified authority. As a result, the authority can install the yellow "Motor caravan parking" signs wherever they like within the authority's area.  The signs which they place are lawful and the local authority can enforce PCNs for contravening them.

The rest of this post explains how I discovered this.

North Yorkshire

In North Yorkshire it turns out that there was a ban in three areas from 2012 to 2015. This was allowed to lapse and has now been reimposed. I found this in a document which Google turned up: 2024 report to North Yorkshire Council. Appendix A to this is a copy of a report from 2015 seeking to make permanent the earlier Temporary TRO.

I set out below the section of the 2015 report which shows that the need for authorised traffic signs was recognised, and that the local MP solved the problem by contacting DfT. I have emboldened the most relevant text, but have left the rest as it shows the context.

2.5 Prior to April 2011 Scarborough Borough Council held responsibility for the publicly maintainable highway in the Scarborough Town area, as agents to the County Council, and attempted in a committee report in 2009 to ameliorate issues with motor-caravans in various “honeypot” locations in the town.
2.6 The report contained various measures for on-street parking and also measures involving the restriction of motor-caravans from its off-street car parking facilities (which the borough council remains responsible for) and was presented to its committee on 15 May 2009. The recommendations of the report were agreed and implemented by the Borough Council. 
2.7 Part of the result of the 2009 committee report was the erectiօn of “no overnight camping” signs at various affected on-street locations in Scarborough Town.
2.8 The Borough Council 2009 report identified that there was no legislation or signage available, that allowed any enforceable restriction on a specific category of vehicle at a location, unless Department for Transport approval was sought and granted. Although it was intended, there is no record of this approval being sought or granted. Consequently the “no overnight camping” signs were unenforceable. Furthermore these signs are now superseded by a more appropriate new traffic sign which was authorised by the Department for Transport on 5 March 2012, described below.
2.9 Other examples of historic unenforceable signage, concerning the prohibition of camping, have also been identified in the last couple of years, at locations which have always been under immediate County Council jurisdiction in the wider borough.
2.10 During 2014 all unenforceable signage that had been identified was removed from all locations across the borough by North Yorkshire County Council, following complaints by individuals from the motor-caravanning community. Nevertheless the existence of such signage demonstrates the long-standing problems surrounding the practice and several recent complaints have been received from residents since the signs have been removed. 
2.11 In 2012 the constituency MP Robert Goodwill raised the problems associated with the overnight on-street parking of motor-caravans, on behalf of residents, with the Department for Transport. A letter was received by him, in reply, from MP Norman Baker, the minister responsible for the issue at that time. 
2.12 A copy of the letter was subsequently shared with North Yorkshire County Council for information. The letter informed that on 5 March 2012 the Department for Transport had issued an authorisation of traffic signs and special directions (GT50/113/0008) in respect of appropriate sites on roads for which the Council is the traffic authority, accompanied by a set of drawings (GT50/113/0008-1) of signs, one of which (authorised sign R) specifically shows a prohibition on the waiting of motor caravans during specified hours. 
2.13 The definition of motor-caravans used is the EU definition as follows:
A “Motor Caravan” is a vehicle of Category M: (Motor vehicles with at least four wheels designed and constructed for the carriage of passengers.) with living accommodation space which contains the following equipment as a minimum: 
(a)  seats and table; 
(b)  sleeping accommodation which may be converted from the seats;
(c)  cooking facilities; 
(d)  storage facilities
The definition is contained within European Directive 2007/46/EC. 
2.14 Following the approval of the signage, on 28 June 2012, the County Council applied a temporary order to prohibit overnight parking of motor-caravans between 11pm and 7am, utilising the above-described prescribed signage, and EU definition, to the affected streets, listed in paragraph 2.4. except The Parade Sandsend, which was not included in the temporary orders.

I searched DfT Traffic Authorisations for "North Yorkshire" but couldn't find anything which looked likely. A Google search for "department transport authorisation GT50/113/0008" found it: it was listed under Traffic signs policy review area-wide authorisation third edition. It's authorised sign R on page 7.

Technicalities: Yellow Lines/Parking Bays or CPZ?

Among the conditions imposed was this:

The provisions of Regulations 12, 18 and 19 of the 2002 Regulations shall apply to the Authorised Sign R in the same manner as they apply to the sign shown in diagram 640.2A in Schedule 2 to those regulations

That indicates that the sign was regarded as based on diagram 640.2A. This was the yellow plate sign "Waiting by goods vehicles over maximum gross weight shown prohibited during the periods and in the direction indicated". That sign was used, without accompanying single yellow lines, in a Controlled Parking Zone (CPZ) applying to goods vehicles over maximum gross weight shown. The entry sign to such a CPZ was diagram 665 and the exit sign 666 (all in TSRGD 2002 Schedule 2).

The yellow plate sign 640.2 and the entry sign to the CPZ diagram 665 have been superseded by the "build it yourself" system in TSRGD 2016 Schedule 4. Diagram 666 remains as TSRGD 2016 Schedule 7 Part 2 Item 2.

I found Google Street View imagery from 2014 for Royal Albert Drive, Scarborough. There are parking bays and a white plate advising of parking restrictions. That being so, it made sense to regard the yellow plate for motor caravan restrictions as being essentially the same as an ordinary yellow plate which accompanies single yellow lines.

Other Local Authorities

I checked DfT Traffic Authorisations for the other counties listed and found authorisations for the same package "Traffic signs policy review area-wide authorisation third edition" as for North Yorkshire. I could not find anything for Lancashire.

That's because the Traffic Authorisations search is a bit flaky: the first thing you learn is that it's case-sensitive, but that's not all. The failure to get a hit doesn't mean there isn't something.

Having found special authorisations for the same package for 3 of the 4 local authorities, I searched for "third edition" and got 152 hits, which looked like all local authorities in England at the time. These included Lancashire, so I tried searching again for that, and found the special authorisation.

A comment about West Sussex: on Mill Road, Arundel, there are no yellow lines or parking bays. I think it's distinctly dodgy to be putting up those yellow plates without either a single yellow line (which is omitted if parking bays are marked) or entry and exit signs for a motor caravan CPZ. The latter would require special authorisation.

Comment for the Traffic Signs Community

I'm disturbed that DfT rolled out what should have been a statutory instrument amending TSRGD 2002 as 152 special authorisations and that it then didn't take advantage of a new edition of TSRGD to incorporate the changes into a statutory instrument. Talk about brushing things under the carpet ... and keeping them there.

@John U.K.  Thank you. Unusually, West Sussex appears to keep the TRO Library up to date. It contains WEST SUSSEX COUNTY COUNCIL // ((ARUN DISTRICT)(PARKING PLACES & TRAFFIC REGULATION) // (CONSOLIDATION) ORDER 2010) // (ARUNDEL: MILL ROAD AMENDMENT) ORDER 2025.

The TRO is map-based. It was made on 20th March 2025 and came into operation on 24th March 2025. It purports to restrict motor caravans (whatever they are) from waiting between 10.00pm and 9.00am any day.

Parts 3 and 4 of TSRGD 2016 Schedule 7 specify road markings for waiting restrictions. The language is a bit technical, so I'll just state their effect. There are precisely two types of waiting restriction:

• Double yellow lines: Waiting of vehicles prohibited at all times
• Single yellow lines: Waiting of vehicles prohibited for a time that is not continuous throughout the year

For each of these restrictions, the yellow lines MUST be placed where the restriction applies.

That's it. No fancy stuff about different classes of vehicle. I should be surprised if DfT agreed to have waiting restrictions which were selectively applied.

What DfT might accept would be parking bays (diagram 1028.6) which were restricted to vehicles other than motor caravans. These would have a single yellow line at the edge of the carriageway and dashed white lines delineating the parking bays with upright signs setting out what could be parked and when. I'm not convinced that permitting parking at all times except by motor caravans between 10pm and 9am would be a valid parking restriction, but West Sussex could give it a try.

Another thing which they could do would be to paint the outer edge of the parking bay 1.8m from the kerb. This would prohibit vehicles more than 1.8m wide (including SUVs) from parking, as well as those with less-wide vehicles who are unable to park next to the kerb.

Interesting sign. I can't find it in TSRGD 2016. That doesn't mean that the sign isn't lawful. The council could have obtained special permission for it from DfT. I searched https://dft.gov.uk/traffic-auths/?search=West+Sussex and looked through the 18 hits: nothing about signs for motor caravans. It's still possible that DfT have authorised it but it hasn't got onto their database yet. My suspicion, however, would be that they haven't and the council are pulling a fast one.

The general policy adopted with traffic signs is that "motorised caravans" are a subspecies of caravan and that signs show a towed caravan. That makes sense to me: otherwise I look forward to caravan owners parking their cars with attached caravan beneath the "Motor caravans" sign.

Councils' usual practice is to ban parking overnight. The problem is enforcement. The council has to prove that the vehicle was parked during the prohibited hours. If it's a car park with well-defined entrances and exits, they can use cameras and ANPR; on an ordinary road they've got to have someone going along during the prohibited hours. I expect they're scheduling someone to go along between 8 a.m. and 9 a.m. That's a time when they probably don't want to be banning parking.

I found this article about a TRO which the council made to ban motor caravans. It reported that 14 signs had been removed "unlawfully". It looks to me as though the signs had been placed unlawfully and that whoever removed them was taking the law into his own hands.

To sum up, the council are in a bind. They can pass a TRO to ban motor caravans overnight, but there are no official signs for this. The only way to implement the TRO lawfully is to obtain permission from DfT for special signs and then place them. They may find that DfT won't agree to the signs or suggest that the council should ban overnight parking instead. Either way, it's not as easy as the council thinks.

@satsuki726 Yes, very much to saying that it was dark and that, as you were being followed, it was unsafe for you to brake suddenly and then swerve back into the outer lane. If you appear at the hearing, that is precisely the sort of thing which enables adjudicators to say that they've heard you, you are a credible witness and that they are satisfied that there was no contravention as it was unsafe for you not to go through the bus gate.