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I'm so sorry if I have confused things. I submitted the appeal on grounds of the kerb stripes not being visible and it was rejected on grounds [they say] A no waiting enforcement being in place there. The actual sign however says 'No Loading or Unloading' which makes me think - The PCN was contravention 02.but 'no waiting' comes under code 01. I looked on ukparking.info which states:

01: Parked in a restricted street during prescribed hours

Higher. Possibly the least obvious from the wording, this is for “No waiting” restrictions, usually single yellow lines or double yellow lines, but also some RPZs, where the restriction is posted on signs as you enter an area. These are most often used in pedestrianised areas or historic town centres, where yellow lines would have too much of an impact on the appearance of the area.

Loading or unloading, blue badge holders, picking up or setting down passengers, and vehicles used in execution of a statutory duty are usually exempt.
02: Parked or loading/unloading in a restricted street where waiting and loading/unloading restrictions are in force.

Higher. Used where there is a no loading restriction; usually marked by yellow lines off the edge of the kerb, but like code 01, may be used in a RPZ, where the restriction is posted on signs as you enter the area. These are most often used in pedestrianised areas or historic town centres, where yellow lines would have too much of an impact on the appearance of the area.

Loading or unloading and blue badge holders are not exempt, picking up or setting down passengers, and vehicles used in execution of a statutory duty are usually exempt.

[Interesting how it's mentioned Yellow Lines aren't used in historic town centres yet you couldn't get more historic than Romford].

I can post the rejection letter if it helps.

I have thought about this further as the reply to to the informal appeal states I have given careful consideration to all the matters raised in your correspondence. I consider,
nevertheless that the Penalty Charge should apply and have rejected your challenge for
cancellation for the following reasons.
Your vehicle was observed in High Street at 15:41:14 hours during a period when the relevant
order prohibits waiting..

If I remember correctly no waiting prohibits stopping but allows dropping off a passenger whereas the sign prohibits loading [whereas code 02 prohibits both]. [he sign being maybe a relic of the building the sign is in front of which used to be Romford Brewery many years ago and the windows now in place were previously doors].The said image in the NTO is blank but what would have the council put there, a pic of the vehicle parked wih no kerb stripes visible or the no loading sign or an attempt to photograph both in one frame which would be almost impossible ?

images of the kerb

https://i.postimg.cc/T1nfM7B0/h1.jpg

https://i.postimg.cc/tTxHWvRG/h2.jpg

https://i.postimg.cc/MKx8fYCw/h3.jpg

Anyone can see the kerb stripes ?

Below are images of the sign and it's placement

https://i.postimg.cc/ZnLYvsHD/s1.jpg

https://i.postimg.cc/gj4d2XkJ/s2.jpg

https://i.postimg.cc/MKPqkQFY/s3.jpg
 
As can be seen the sign is in a place where no-one would notice it [I certainly didn't know it existed] and as was pointed out out to me years ago by my driving instructor that if you drive a car using one had on the steering wheel [using a steering ball/mushroom]you should not turn your head to one side as your shoulder and arm and thus the wheel diverts causing the car to move dangerously. Large signs are quite visible so any disabled driver can be at a disadvantage.   

Images Below:

https://i.postimg.cc/50Tj6MR8/car1.png

https://i.postimg.cc/kMRBLB2Y/car2.png

https://i.postimg.cc/KvXRbxLv/car3.png

https://i.postimg.cc/L6zh6wBt/car5.png

https://i.postimg.cc/MpqHc5dr/car7.png

I submitted an informal appeal which Havering rejected although still no pics on website. On 08/01/2026 received an NTO stating ‘to the right is a photo of your vehicle committing he alleged contravention’ but no photo. On the 13th I got an email stating ‘Good morning
Sorry for the delay in replying to your enquiry.
Please find attached the photos taken at the time of issue’ Am I correct in believing there is a procedural impropriety in that images should be supplied within a reasonable time as in:  The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 paragraph 3 (a) and 4 and not doing so has created an an unfairness.

I can supply images if requested.

That sounds like a fair route to take especially as I didn't even notice any no stopping kerb markings when parking and when I looked again they are so faded and faint I don't think anyone would've seen them- thank you.

Yes you are correct they do not which was what puzzled me but I took [a reasonable] assumption the penalty was on hold until they either produced the images or reported there were none as the penalty remained at £80 then suddenly shot up randomly. I know they are short staffed and nearly bankrupt but last year the parking dept made about £6 million pounds !!

I have until Friday to submit a rep - should I submit a rep referring to their error here ?

Thank you for posting the relevant regs that if read carefully and a few times to a layman make a degree of sense but could've been written better, however the version on the Havering PCN makes no sense at all to the layman [well to me as a layman] There is no reference to the regs and I thought the text on a PCN/NTO had to be easily readable to avoid any confusion or misunderstanding.