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Well, they don't actually state that loading is an exemption, just that they note your reps stating you were unloading. Your case hinges on whether loading/unloading from a vehicle that is not a M/c is an exemption in the m/c parking bay. The Traffic Order is the document that defines what is allowed.

Also, your reps were an informal challenge against the paper PCN, and all London councils game the system ruthlessly and reject virtually all informal reps knowing that most people then just cough-up to get the discount. I call them "Fob Off" letters. So if you are prepared to stand your ground, you must wait for the Notice to Owner, sent to the name and address on the V5C for the vehicle. So, is this your vehicle, and is the V5C Registration Certificate up-to-date ?

That's strange. The letter I've received is in response to my second challenge and was flagged as a formal representation. It feels like I might've been fobbed off twice. On another part of the letter that I haven't included it says my next option is to go to a tribunal whch I think I might do. Yes my V5C certificate is up-to-date so I should get all correspondence.

You may as well add in the point that the PCN does not fully describe the contravention, and London Councils says the suffix is required but is missing.

Evening, I've finally had a reply following my representation. The response is below:



I'm debating now taking this to a tribunal as I was under the impression that unloading/loading is an exemption which has been acknowledged in this letter.

As ever, any advice appreciated.

I can't find the order. This is code 23 in London Councils CEO handbook.

Thank you for this, I've rephrased my representation and added in about the CEO handbook. I've removed the legislation content as I assume it is no longer relevant as teh 2007 legislation has been revoked.

Here is my current representation:

I am making representations that the contravention did not occur as I was engaged in the exempt activities of both unloading and loading, which I am disappointed you did not address following my initial challenge.

On 30th November 2025 I parked in the space to begin unloading a mattress. As you will see by my address that I live Sandon Court, 261 Green Lanes, London, N4 2UX. This spot was the nearest available to the property as no unloading/loading bays or parking spaces are provided by Hackney council at this address. Please see the photo attached (Image1) which is of the mattress box that was being unloaded from the vehicle in the Sandon Court lift. As can be seen by the images provided by yourselves, all other parking bays were occupied and this was the only available space to pull over to start unloading.

The duration that I was parked in this bay was only as long as was necessary to unload/load the new and old mattress. As per the Civil Enforcement Handbook (https://www.cityoflondon.gov.uk/assets/Services-Environment/civil-enforcement-officers-handbook.pdf) Code 23, unloading/loading is referenced as an exemption.

I only stopped in the spot pictured to load/unload, and I have not stopped/parked in this motorcycle bay or any others previously, as can hopefully be verified by yourselves that I haven’t received any other PCNs from Hackney Council in the almost 3 years I’ve lived at this address.

Furthermore, I would also like to add to this representation that due to the direction in which I approached this spot I didn't initially see the motorcycle sign and there is a lack of a road legend for the bay (Image2), this makes it unclear due to there being two spaces that look exactly the same for motor vehicles right next to it. It is clear that the council is inconsistent in clearly marking motorcycle bays to bring their status unambiguously to drivers' attention. Especially as the bay near to this is has a clear road legend for Electric Vehicles (Image3)

In Summary, my main challenge in this representation regarding this PCN is that I was engaging in exempt activities of unloading/loading from my vehicle which is clearly demonstrated due to my close proximity to my registered property and images of the unloading taking place.

I would also assume representation is being made based on the top option:

The contravention did not occur

I was not the owner of the vehicle at the time the contravention occurred

The vehicle had been taken without the keepers consent (i.e. it was stolen)

We are a hire firm and will provide details of the hirer

The PCN exceeded the amount applicable

The PCN has been paid

The Traffic Management Order is invalid

The CEO was not prevented from serving the PCN

There has been a procedural impropriety on the part of the enforcement authority

I wish to make representations about this PCN for other reasons
 

Check your last sentence. Please give a link to this, because I think you're possibly out-of-date.

I think you might be correct that the legislation is now out of date and has changed to:

The Civil Enforcement of Road Traffic Contraventions (England) Regulations 2022.
(https://www.legislation.gov.uk/uksi/2022/71/contents)


Looking in the legislation I'm not clear on if my rationale for challenge on this basis still applies.

Any advice from you or @stanfordman would be greatly appreciated. I still feel the loading/unloading is applicable grounds for dismissal of PCN but I'd like to add as much to the representation as possible.

You need to start off by saying something like:

I am making representations that the contravention did not occur as I was engaged in the exempt activities of both unloading and loading, which I am disappointed you did not address following my initial challenge.
 

Loading is an exemption so you should lead with this, enclosing the picture of the box, and noting you returned with an old mattress. But how long did this take? The key is as long as necessary only.

On the PCN, the wording of the contravention doesn't say what class is OK, and at least a suffix is required to fully describe the contravention - in this case g for motorcycle bay. This is worth a try as per:

https://drive.google.com/file/d/1QtmX9lLTLTQx6uRa9NDzJvfXcJuhzylV/view

But a lengthy discussion in a case by our admin failed:

https://drive.google.com/file/d/1duurfYJ4orQSwrQhRNYL1wgYnXtEpheb/view

Finally, note you did not initially see the motorcycle sign and there is a lack of a road legend for the bay, and that you believe the council is inconsistent in clearly marking motorcycle bays to bring their status unambiguously to drivers' attention.

Thank you ever so much for your help here stamfordman, I will go back with the points you've suggested mentioning.

Fingers crossed.

We have several tribunal cases to cite on the contravention.

Loading is the strongest ground as it is an exemption.

I'll help you with reps - there is no rush.

Thanks again stamfordman, won't rush to respond but do let me know if there is anything you need me to do in the meantime.

Hi,

Can I first start by thanking anyone that assists with this case, this is my first time getting a PCN and I'm hoping I will be able to get representation to get this dismissed with your essential help.

On Sunday 30th November 2025 at 09:11am I received a PCN due to the following code:

Code 23- Parked in a parking place or area not designated for that class of vehicle.

I had approached Lordship Park Road from Green Lanes and parked in the only available parking space due to unloading a rather heavy mattress box with my partner. I live in a property round the corner on the main road which does not have any designated parking/allocated spaces or designated areas to unload. When I turned into the road I checked the times/restrictions on the sign near the only available space which mentioned restrictions that were in place and I was sure I wasn't causing any issue by unloading there. I got out my vehicle and unloaded the large box with my partner.

When we returned to load the car with our old mattress the PCN had been issued and it was at this point that I did see that the post next to the car did say for Motorcycles only but there was no clear road markings designating the space for motorcycles so we hadn't noticed this when parking up. Due to the direction I approached I hadn't seen this motorcycle sign which was affixed to the side of the lamppost. From seeing the images on the PCN we then saw the image of the motorbike at the very top of the parking sign, but hadn't noticed this initially as the rest of the parking sign was the same as others in the area and we'd checked it wasn't an Event Day.

I did feel that this PCN was issued unfairly with no road markings saying Motorcycles but there is road markings for the Electric Vehicles spaces a few feet away. The fact we were unloading and loading as well I would hope will have some bearing here, but as we were loading/unloading heavy items for our own home we obviously don't have any official delivery documents etc to support this.

As I was unloading and as my property round the corner from the location of the PCN does not come with any areas to unload/park I'm looking for support to challenge this PCN and hopefully have it dismissed.

Evidence Timeline
PCN Issued (30th November 2025):


Official images taken at the time of alleged contravention (30th November 2025):








Personal images taken in the evening (30th November 2025):










Informal dispute sent to Hackney Council on PCN issue (3rd December 2025):






Response to informal dispute (9th December 2025):


Image of box that was unloaded:


Formal Notice To Owner - Received Today (5th Jan 26) but dated 2nd Jan 2026:


Google Maps Location - https://maps.app.goo.gl/hRGey7BJ9d4RPWgr6

Thank you once again to anyone that might be able to help with this, I'd be happy to provide any other information where needed and apologies for any incorrect formatting of this post, I'll be sure to correct with guidance. I'm aiming to give formal representation to this Notice To Owner as soon as possible and any advice would be appreciated.