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PROCEDURAL ISSUE?

I may have found an issue with the Traffic Management Order, would appreciate others' thoughts:

I was reflecting that it is an odd place for a single yellow as no clear reason for it.

So I checked the TMO: Restriction I think made under an Experimental TMO (pdf linked here if convenient:)<https://pre.hillingdon.gov.uk/downloads/file/2403/24-april-experimental-waiting-restrictions-to-support-the-existing-traffic-calming-measures-in-tavistock-road-yiewsley>)

(Schedule 1 a) iii) details relevant ‘Mon-Fri, Midday – 1pm’ waiting times restriction).

ETO purportedly made under s9 Road Traffic Regulation Act 1984. s9(3) RTRA provides 'no ETO shall continue in force for longer than 18 months'.
(s9 RTRA: <https://www.legislation.gov.uk/ukpga/1984/27/section/9>)

ETO entered into force 1 May 2024 (see link above, page 1). 18 months elapsed on 1 November 2025? Purported PCN issued 10 February 2026.

Am I correct to believe this should be a slam-dunk?

I’m aware a new/permanent TMO may have been made, but cannot find any more recent on Hillingdon’s website or elsewhere. I've made an FOI request for any and all TMOs affecting relevant road and will update.

That's v helpful, thanks.

Their web portal has a 1000 character limited >:-( so I submitted this:

The PCN was issued at 12:59. The restriction ended at 13:00. The CEO's first photo with PCN attached is timestamped 12:59:42; I think I am even visible in the top left of that photo (18 seconds before restriction ends). The CEO's final photo is timestamped 13:00:04 (restriction over).

My challenge:
I made every effort to comply. I checked the signs and my car's clock. I spent about a minute unloading my car and walked away, believing the restriction had ended.

I have a medical condition which means I can move slowly, so I believed my unloading was ample for the restriction to end. There were several vehicles already parked on the single yellow line (shown in the CEO's photos - none of which were ticketed), supporting my belief that the restriction had ended. The wet road under the car shows it has literally just been parked.

Even if you were to decline this de minimis exemption, in the absence of any loading restriction signs I also claim the statutory exemption of unloading.

How about this:

Dear Hillingdon Parking Appeals and Processing,

I am writing to ask you to exercise your discretion and cancel PCN No: HN24219947 against VRN: Y200WLD.

[My address etc.]

The facts of the PCN:
The PCN was issued at 12:59. The parking restriction ended at 13:00. The first evidence photograph taken by the CEO of the car with the PCN attached is timestamped 12:59:42 (18 seconds before the restriction ended). The final evidence photo taken by the CEO is timestamped 13:00:04 (restriction no longer in effect).

My appeal:
I made every effort to comply with the restriction. I checked the signs and then my car's clock, which indicated that the restriction was just about to end. I then spent around a minute unloading my vehicle and walked away, believing that enough time had elapsed and that the restriction had ended.

I have a medical condition which means I sometimes move slowly, therefore I believed the time I spent unloading would have been ample for the restriction to end. There were several other vehicles already parked on the same single yellow line when I arrived (shown in the CEO's photos), which reinforced my reasonable belief that the restriction had ended.

I believe I may even be visible walking away from the car in the top left of the evidence photograph taken by the CEO at 12:59:42 (18 seconds before the restriction ended). It was raining at the time and it is clear from the wet road underneath the car that it has been parked for moments.

Summary of mitigating factors:
I have never before been issued with any form of penalty notice. I am a law abiding citizen and took every effort to comply with this restriction.

I believe any contravention lasted, at most, seconds. I do not understand how the CEO can claim to have observed my car from 12:55.

There were several other vehicles parked on the same single yellow restriction, all visible in the CEO's photos. None of those vehicles appear to have been issued with a PCN.

[Kind regards etc.]

Just checked car clock, is just under 2 minutes ahead of my phone (i.e. 12:58 would actually have been 12:56). Doh.

Where might a mitigation factor into the council's decision-making?

Parking restriction is prescribed hours 12:00 (midday) to 1pm.
- I have received a PCN for 12:59.
- I must have literally just walked away from the car.
- (Think I may even be visible walking away in one of evidence photos).

Late photo evidence provided by issuer:
- 12:58:45 First photo evidence timestamp (no ticket yet on car).
- 13:00:04 (outside prescribed hours) last photo evidence timestamp.

Claimed observation period:
- 12:55 - 12:59 claimed observation period (stated on PCN).
- Hillingdon's Enforcement Protocol (v2.4, page 11) states code 01 minimum observation period is 5 minutes.

Photo of PCN:


Google Maps/Street View:
https://maps.app.goo.gl/uZqCPYWcfwSJ1SZJ8

Photo evidence taken at 13:00:04 by council:


Photo evidence possibly with me in background walking away (top left):