Author Topic: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over) (Read 1357 times)

FaeLLe · « **on:** August 18, 2024, 03:53:25 pm »

This PCN relates to a long and convoluted series of events, including an appeal to IAS dismissed by the ‘independent’ adjudicator. Liability has not been accepted, and the driver has not been named. Moorside Legal has contacted the registered keeper, offering payment of £170 in instalments) threatening legal action.

Apologies for not getting advice earlier, but once the PePiPoo website went down, I was not made aware of this forum till recently.

There is also a lot of content due to the chain of events so please let me know if I can help extract and highlight some information.

Summarily,

- Signs were not visible and maintained and the driver thought parking was permitted without any conditions at the site.
- IAS was provided several images showing that the terms of parking were not visible anywhere throughout the journey taken by the driver.

Evidence from PCM is not relevant and does not address the fact that sufficient signage was present.

PCM relied on historical images from several years ago to state sufficient signage is present, and IAS seems to accept this (timestamps embedded in the pictures submitted show the photos of signage and the site are not current) – pictures supplied by PCM were taken during the construction stage of the building).
PCM indicates that the registered keeper knew the site's T&Cs since they have a parking permit allocated to the apartment— registered keeper (who occupied the apartment) was not offered a parking place by the landlord and hence never used the parking facilities at the site (the tenancy contract was uploaded as proof); the tenant was told by the estate agents that no parking exists for this apartment.
Due to the point above, PCM asserts on the balance of probabilities that the driver was the registered keeper.

As indicated above, this is a false claim (keeper didn’t even know the apartment had a parking bay as landlord stated ‘no parking is offered’ in tenancy contract).

The Letter of representation (linked below) includes details and images of the site and parking location.

If this matter ever gets in front of a District Judge, I believe the PCN should be dismissed since PCM has failed in its duty to maintain and advertise traffic conditions as required.

I would appreciate any advice, please. Is there anything else I should provide to Moorside Legal at this stage?

PCN reason

Reason for PCN issue: Parked in restricted area

RELEVANT DOCUMENTS (REDACTED TO REMOVE PII)

Latest letter from Moorside Legal: https://drive.google.com/file/d/1su8KuvYfw37yP8NI-VXPFhxl9mxhiWHX/view?usp=sharing

Initial appeal from registered keeper to PCM: https://drive.google.com/file/d/1gHJLGOoabA1WHfhm_KXTh6XOqVRO0cFm/view?usp=sharing

Prima Farce case from PCM to IAS: https://drive.google.com/file/d/104gEp9rH8jswSptTrqAlg8PXiJqMQDmD/view?usp=sharing

Letter of Representation to IAS (sent by registered keeper):
https://drive.google.com/file/d/1d6Va3RaxIqtDIWM6cT1utfu_r2OMnl9I/view?usp=sharing

Second Letter of Representation sent to IAS (sent by registered keeper): https://drive.google.com/file/d/1YT0K2UTiL5UMyF5xjP3FggAmi7Wr3a-T/view?usp=sharing

TIMELINE OF EVENTS RELATING TO PCN

Alleged date of parking offence – 11 Nov 2023
Appeal made to PCM (by registered keeper) – Within time 22 Nov 2023
Rejection of appeal from PCM – 05 Dec 2023 (letter dated 27 Nov 2023)
IAS appeal submitted – 15 Dec 2023
IAS decision from the Independent Adjudicator – Dismissed on 11 Jan 2024
PCM data subject address rectification with PCM – Notified new address – 05 Aug 2024
Letter from Moorside Legal (on behalf of PCM) – Offering payment of £170 in 4 instalments – 13 Aug 2024

OUTCOME OF APPEAL FROM IAS

Appeal Dismissed: The parking charge has been upheld.

You may view the adjudicator's comments in the section below.

Adjudicator's Decision: (emphasis added by me within the text below)

The adjudicator made their decision on 10/01/2024 09:10:07.

It is important that the Appellant understands that the adjudicator is not in a position to give his legal advice. The adjudicator's role is to look at whether the parking charge has a basis in law and was properly issued in the circumstances of each particular case. The adjudicator's decision is not legally binding on the Appellant (it is intended to be a guide) and they are free to obtain independent legal advice if they so wish. However, the adjudicator
is legally qualified (a barrister or solicitor) and decides the appeal according to their understanding of the law and legal principles.

The terms of this appeal are that I am only allowed to consider the charge being appealed and not the circumstances of other drivers or other parking events. The guidance to this appeal also makes it clear that I am bound by the law of contract and can only consider legal challenges not mistakes or extenuating circumstances. I am satisfied that the Operator's signage, which was on display throughout the site and seemingly visible from the position of the vehicle, makes it sufficiently clear that the terms and conditions are in force at all times and that a PCN will be issued to drivers who fail to comply with the terms and conditions, regardless of a driver's
reasons for being on site or any mitigating factors. While noting their comments, it is clear from the evidence provided to this appeal that the Appellant did indeed enter and use the site otherwise than in accordance with
the displayed terms by allowing their vehicle to be parked in a restricted area as alleged by the Operator, having been allowed an adequate consideration period prior to the charge being issued. It is the driver's (rather than a
third party's) responsibility to ensure that the terms and conditions of parking are properly complied with. I am satisfied on the evidence provided that the Operator has the authority to issue and enforce PCNs at this site. I
am further satisfied as to the location of the contravention, that the correct vehicle has been identified parked at the time suggested in the images provided and that the correct Appellant is pursued. I note the Appellant's comments with regards to service however the Operator's code of conduct states that 'Where notification of a parking charge is not affixed to the vehicle or given to the driver at the time of the parking event then you may provide postal
notification of the charge to the registered keeper.' On the evidence provided I am satisfied that the charge has been served correctly using the postal system.

I am satisfied that the Operator has proven their prima facie case. Whilst having some sympathy with the Appellant's circumstances, once liability has been established, only the Operator has the discretion to vary or cancel the
parking charge based on mitigating circumstances. Accordingly this appeal is dismissed.

Motorist Details:

You reported that you were the registered keeper but is not prepared to state who was driving at the time the parking charge was issued.

You reported that you are being held liable for the parking charge.

My Appeal:

You completed the appeal on 15/12/2023 11:39:44.
Please find attached our detailed Letter of Representation to support the appeal.

Operator's Prima Facie Case:

The operator made their Prima Facie Case on 15/12/2023 13:12:09.

The operator reported that...

The appellant was the driver.

The appellant was the keeper.

ANPR/CCTV was used.

The Notice to Keeper was sent on 15/11/2023.

A response was received from the Notice to Keeper.

The ticket was issued on 11/11/2023.

The Notice to Keeper (ANPR) was sent in accordance with PoFA.

The charge is based in Contract.

Appellant's Response:

The appellant made their response on 15/12/2023 22:21:07.

Please find attached our further response as a 'Second Letter of Representation' along with a supporting Exhibit with the filename 'REDACTED - Assured Shorthold Tenancies - Flat REDACTED The Duke.pdf'.

The operator made the following comments...

Please see attached.

DOCUMENTS SENT BY PCM TO IAS

Sitemap 1 – Aerial view map showing which signs are located where – IAS ignored the fact that the signs are not visible and maintained (vandalised)

https://drive.google.com/file/d/1Y2b-szP1a2lRscoGXgw2ODTwUizQJjQz/view?usp=sharing

Various PDF files showing the design template of several sign boards (none of which were visible and some irrelevant e.g. there are no bays with signs stating Red Resident Permit anywhere) :

https://drive.google.com/drive/folders/1RYGJsW5IvV4t7Ye150dVrdsdpTzQA1re?usp=sharing

Standard Permit Marked bay (PAR0091-289) – Large version of the design of a sign board the (physical site
does not show a sign with all these details visible)

1855 - ENTRANCE SIGN 2021 (PAR0091-1855) – As per my evidence to IAS this sign cannot be seen when entering the road or parking location

NP - AREA TC (PAR0091-375)

2464 - Loading Bay - 30min max - NO PERMIT (PAR0091-2464)

NO Parking AREA (PAR0091-302)

Standard Permit MB GDPR Aug 2020 (PAR0091-1313)

BP SIGN - Numbered - Red Resident Permit (PAR0091-1108)

[/list][/list]

FaeLLe · « **Reply #1 on:** August 18, 2024, 04:02:15 pm »

b789 · « **Reply #2 on:** August 18, 2024, 06:43:06 pm »

Good job that the driver has not been identified. The NtK does not fully comply with ALL the requirements of PoFA to be able to hold the keeper liable for the charge.

Quote

PoFA 9(1) A notice which is to be relied on as a notice to keeper for the purposes of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met.

9(2) The notice must—

9(2)(e) state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—

9(2)(e)(ii) if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver;

Show me where in that NtK there is any mention of passing the notice to the keeper. There isn't as far as I can see in the low quality image of the NtK.

Partial or even substantial compliance is not sufficient.

FaeLLe · « **Reply #3 on:** August 18, 2024, 08:20:43 pm »

PCM argue that this is an invitation to volunteer the information.

Unfortunately, would the below text not meet the requirements of PoFA 2012 9(2)(e)?

Quote

This notice is being given to you in line with Schedule 4 of the Protection of Freedoms Act 2012 ('the Act'). In relation to a parking contravention that occurred on 11/11/2023. Records from the DVLA show that you were the registered keeper at the time of the contravention and as we do not know the name and current address for service of the driver, this notice is served to you
[..]

Quote

[..]
As the registered keeper of the vehicle, you are invited to do one of the following
[..]
ii. if you were not the driver at the time of the contravention, pleae provide us with the full name and serviceable address of the driver to which this notice can be served.
[..]

b789 · « **Reply #4 on:** August 18, 2024, 09:14:02 pm »

It is missing this little bit on the end of that sentence you have shown: "and to pass the notice on to the driver". It is crucial that ALL the requirement of PoFA are FULLY complied with. As I have mentioned already, partial or even substantial compliance is not sufficient.

FaeLLe · « **Reply #5 on:** August 18, 2024, 09:23:36 pm »

Quote from: b789 on August 18, 2024, 09:14:02 pm

It is missing this little bit on the end of that sentence you have shown: "and to pass the notice on to the driver". It is crucial that ALL the requirement of PoFA are FULLY complied with. As I have mentioned already, partial or even substantial compliance is not sufficient.

Thanks a lot, I missed out the 'pass the notice' bit of the requirement.

Should I just write to the legal firm asking that they cease enforcement due to non-compliance with PoFA?
Do we need to highlight the specific manner in which they have not complied with PoFA? I guess not but thought of confirming.

I will look for a template on here and share back a draft for review if you believe this is the only thing that needs

b789 · « **Reply #6 on:** August 19, 2024, 12:55:37 am »

This is way beyond any appeal stage and there is no point corresponding with the claimants solicitor unless it is to respond to an actual Letter of Claim (LoC).

The PoFA flaw is only one arrow in the quiver. It simply means that they cannot sue the keeper for the charge. Not that that will stop them trying.

What about the lease. What does it say about parking? What it doesn’t say about parking is equally important. Any mention of requiring permits or being liable to a third party to pay invoices for breaching any specified terms?

Is the PPC relying on a contract flowing from the landowner through the managing agent? If so, is there anything in the lease that gives that right? Has the managing agent changed or altered anything in the head lease and if so, did they comply fully with the Landlord & Tenant Act

Section 37 5(a) or 5(b) applies

FaeLLe · « **Reply #7 on:** August 19, 2024, 01:10:16 am »

Quote from: b789 on August 19, 2024, 12:55:37 am

What about the lease. What does it say about parking? What it doesn’t say about parking is equally important. Any mention of requiring permits or being liable to a third party to pay invoices for breaching any specified terms?

The tenancy contract the registered keeper had have specifically prohibits them from applying for permits.

The registered keeper does not have a copy of the leasehold agreement as I was merely a tenant.

Should the registered keeper obtain the authority to act from PCM through correspondence?
If they refuse to share this then they can show un reasonable litigation conduct when/if this proceeds to a claim?

Quote from: b789 on August 19, 2024, 12:55:37 am

Is the PPC relying on a contract flowing from the landowner through the managing agent? If so, is there anything in the lease that gives that right? Has the managing agent changed or altered anything in the head lease and if so, did they comply fully with the Landlord & Tenant Act

Section 37 5(a) or 5(b) applies

What do you suggest is the best way to obtain this? FOIA?

H C Andersen · « **Reply #8 on:** August 19, 2024, 09:29:52 am »

OP, are you the registered keeper?

As regards what has been posited as a silver bullet in terms of PoFA, I suggest that you do not hitch your wagon to this point.

Let's see it in its correct context:

4));

(e)state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—

(i)to pay the unpaid parking charges; or

(ii)if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver;

Elsewhere in PoFA you will see similar references, for example when a car is hired and the creditor issues a Notice to Hirer this must include a copy of the original Notice to Keeper to the hire company.

What does this mean?

The law doesn't want a hirer or, in your case, the driver to receive a demand from the creditor without any legal context. In a hirer's case they get a copy of original NTK sent by the creditor, in yours the driver would also get the NTK but this time sent by the keeper....'to pass to the driver'.

This is the provision's sole purpose.

But you did NOT provide the driver's details, so the point is irrelevant as regards the option which you chose i.e. to make reps as keeper.

Does the NTK omit these words, yes?

Would this save you in front of a judge who interprets these provisions in a purposive manner? IMO, no.

But this is why you get a range of views here, we do not all agree.

FaeLLe · « **Reply #9 on:** August 19, 2024, 12:05:43 pm »

I think we cannot rely on PoFA non-compliance due to my comments below Requirements for Notice to Keeper – Second condition as per p(6)

Markuped up comments against the legislative requirements is provided below.

Conditions that must be met for purposes of paragraph 4 – Protection of Freedoms Act 2012 (2012 c9)

FIRST CONDITION[/u]

Quote

Conditions that must be met for purposes of paragraph 4
5
(1) The first condition is that the creditor—
(a) has the right to enforce against the driver of the vehicle the requirement to pay the unpaid parking charges; but
(b) is unable to take steps to enforce that requirement against the driver because the creditor does not know both the name of the driver and a current address for service for the driver.

Okay the driver is unknown at this point.

Quote

(2) Sub-paragraph (1)(b) ceases to apply if (at any time after the end of the period of 28 days beginning with the day on which the notice to keeper is given) the creditor begins proceedings to recover the unpaid parking charges from the keeper.

The creditor can enforce charges against the keeper; if driver not named after end of 28 days.
SECOND CONDITION[/u]

Quote

6
(1) The second condition is that the creditor (or a person acting for or on behalf of the creditor)—
(a) has given a notice to driver in accordance with paragraph 7, followed by a notice to keeper in accordance with paragraph 8; or

Does not apply in this scenario as we are NtK stage and driver is unknown (so a notice to driver cannot be issued by the creditor).

Quote

(b) has given a notice to keeper in accordance with paragraph 9.

Okay so a PoFA compliant notice as per p9 is required, let us look at that next.
NOTICED TO KEEPER REQUIREMENTS – REQUIRED BY SECOND CONDITION – p6(1)(b)[/u]

Quote

9
(1) A notice which is to be relied on as a notice to keeper for the purposes of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met.
(2) The notice must—
(a) specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;

Vehicle specified – OK
Period of notice – OK
Relevant land it was parked on – NOT OK – Creditor uses the term LANGLEY SQUARE, this seems to be a marketing name for the development no one recognises and there are no sign boards that state this name.
(Judge – might not agree as the appeal to IAS highlights the relevant land using aerial maps)

Quote

(b) inform the keeper that the driver is required to pay parking charges in respect of the specified period of parking and that the parking charges have not been paid in full;

OK – PCN states amount paid £0.

Quote

(c) describe the parking charges due from the driver as at the end of that period, the circumstances in which the requirement to pay them arose (including the means by which the requirement was brought to the attention of drivers) and the other facts that made them payable;

OK – I guess given the text in 2nd and 4th paragraph of PCN. Please share thoughts.

Quote

(d) specify the total amount of those parking charges that are unpaid, as at a time which is
(i) specified in the notice; and
(ii) no later than the end of the day before the day on which the notice is either sent by post or, as the case may be, handed to or left at a current address for service for the keeper (see sub-paragraph (4));

OK.

Quote

(e) state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper—

First paragraph of PCN seems to cover this (as per my previous post).
(i) to pay the unpaid parking charges; or
[/quote]
OK

Quote

(ii) if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver;

PARTIALLY COMPLIANT – the underlined text is not covered. Hence, the driver does not have the PCN if keeper did not know legally they should have given it to them.
But as per the previous post, I think a Judge might decide to enforce the keeper's liability because the driver would have received the notice in either case if they had been identified by the keeper (the creditor would have re-issued the PCN).
This could be risky as a ‘sole defence’.

Quote

(f) warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—
(i) the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and
(ii) the creditor does not know both the name of the driver and a current address for service for the driver,
the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;

OK – cant see any non-compliance here (yet).

Quote

(g) inform the keeper of any discount offered for prompt payment and the arrangements for the resolution of disputes or complaints that are available;

OK

Quote

(h) identify the creditor and specify how and to whom payment or notification to the creditor may be made;

OK – reverse side of PCN has this.

Quote

(i) specify the date on which the notice is sent (where it is sent by post) or given (in any other case).

TO VALIDATE – can the date of notice be ‘one day after’ the ‘date of posting’? Forgot what the standard is.

Quote

(3) The notice must relate only to a single period of parking specified under sub-paragraph (2)(a) (but this does not prevent the giving of separate notices which each specify different parts of a single period of parking).

OK.

Quote

(4) The notice must be given by—
(a) handing it to the keeper, or leaving it at a current address for service for the keeper, within the relevant period; or
(b) sending it by post to a current address for service for the keeper so that it is delivered to that address within the relevant period.
(5) The relevant period for the purposes of sub-paragraph (4) is the period of 14 days beginning with the day after that on which the specified period of parking ended.
(6) A notice sent by post is to be presumed, unless the contrary is proved, to have been delivered (and so “given” for the purposes of sub-paragraph (4)) on the second working day after the day on which it is posted; and for this purpose “working day” means any day other than a Saturday, Sunday or a public holiday in England and Wales.
(7) When the notice is given it must be accompanied by any evidence prescribed under paragraph 10.
( In sub-paragraph (2)(g) the reference to arrangements for the resolution of disputes or complaints includes—
(a) any procedures offered by the creditor for dealing informally with representations by the keeper about the notice or any matter contained in it; and

(b) any arrangements under which disputes or complaints (however described) may be referred by the keeper to independent adjudication or arbitration.

All seems OK.

b789 · « **Reply #10 on:** August 19, 2024, 12:51:44 pm »

Quote from: FaeLLe on August 19, 2024, 12:05:43 pm

PARTIALLY COMPLIANT – the underlined text is not covered. Hence, the driver does not have the PCN if keeper did not know legally they should have given it to them.
But as per the previous post, I think a Judge might decide to enforce the keeper's liability because the driver would have received the notice in either case if they had been identified by the keeper (the creditor would have re-issued the PCN).
This could be risky as a ‘sole defence’.

Overthinking is not going to get yo anywhere. You or HC Andersen may "think" that a judge "might" decide to enforce keeper liability but you are ignoring the fact that as long as you point out to a judge, assuming this ever got as far as a hearing in court, that the rules are the rules. The word "MUST" is included in the Act for a reason. "FULL" compliance means just that.

If the NtK does not FULLY comply with ALL the requirements of the Act, then it cannot be relied on to hold the keeper liable for the unknown drivers alleged breach of contract.

Hence the wording, "partial or even substantial compliance is not sufficient". Only "FULL" compliance allows the keeper to be liable. Is the NtK FULLY compliant with ALL the requirements of the Act? No it isn't.

Anyway, it will not stop the greedy operator from trying it on as they will put the following in their Particulars of Claim should they file one: "The Defendant is pursued as the driver or in the alternate as the keeper under PoFA 2012". One leg of the defence is to deny keeper liability as per the argument above and then the burden of proof is on the claimant to show that the person they are pursuing is the driver. There is a ton of persuasive legal precedence to show that they are not allowed to infer or assume that the keeper must also be the driver.

As you have such a vested interest in this, have a read of the following appeal judgments where keeper liability was refused:

VCS v Edward [2023] H0KF6C9C

FaeLLe · « **Reply #11 on:** August 19, 2024, 01:13:01 pm »

Quote from: b789 on August 19, 2024, 12:51:44 pm

Quote from: FaeLLe on August 19, 2024, 12:05:43 pm
PARTIALLY COMPLIANT – the underlined text is not covered. Hence, the driver does not have the PCN if keeper did not know legally they should have given it to them.
But as per the previous post, I think a Judge might decide to enforce the keeper's liability because the driver would have received the notice in either case if they had been identified by the keeper (the creditor would have re-issued the PCN).
This could be risky as a ‘sole defence’.
There is a ton of persuasive legal precedence to show that they are not allowed to infer or assume that the keeper must also be the driver.

Yes I agree. This was also tested in the UKSC for Road Traffic offences within Cameron v Liverpool Victoria Insurance Co Ltd [2019] UKSC 6, [2019] All ER (D) 103 (Feb).

It suggests that proceedings should not be issued against persons unknown unless it is possible either to serve via a method likely to bring proceedings to their attention or to meet the high threshold for dispensing with service altogether.

There needs to be a reliance on a statutory scheme (PoFA compliance as in our case) that requires the drivers identity to be revealed.

What did the Supreme Court decide within Cameron v Liverpool Victoria Insurance Co Ltd?

The respondent’s claim against the unknown driver was struck out, as he could not be described in a way that would allow him to be identified, and there was no means of service that would bring proceedings to his attention. The court emphasised that, subject to statutory schemes to the contrary, alternative methods of service still had to be such as would bring proceedings to a defendant’s attention.

The court rejected the argument that it should allow the claim to proceed so as to facilitate a direct right of action against the appellant as the insurer of the culpable vehicle, which was arguably required by EU law, on the narrow ground that the remedy sought in the proceedings was not a direct remedy, but rather a right to a judgment against an unknown driver which the appellant would simply have a statutory obligation to meet thereafter. The court therefore did not decide whether the UK had failed to transpose EU law correctly by failing to create a direct right of action against an insurer in a case where insurance could be identified but a driver could not.

Quote

As you have such a vested interest in this, have a read of the following appeal judgments where keeper liability was refused:

VCS v Edward [2023] H0KF6C9C

For sure I will be reading this tonight in full.

Free Traffic Legal Advice

Author Topic: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over) (Read 1357 times)

FaeLLe

PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

b789

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

b789

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

b789

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

H C Andersen

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

b789

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)

FaeLLe

Re: PCM - Langley Square - PCN despite insufficient signage (signs do not exist on site and were sprayed over)