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       #Post#: 122502--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: fraser.mitchell
       Date: June 20, 2026, 3:59 pm
       ---------------------------------------------------------
       Your point (ii) is not correct. Procedural impropriety is
       defined in the Regulation 2(2) and 2(3) :-
  HTML https://www.legislation.gov.uk/ukdsi/2022/9780348232752/regulation/2
       --- Quote ---
       > (2) A “procedural impropriety” means a failure by an
       enforcement authority to observe any requirement imposed on it
       by—
       >
       > (a)the TMA 2004,
       > (b)the 2022 General Regulations, or
       > (c)these Regulations,
       >
       > in relation to the imposition or recovery of a penalty charge
       or other sum.
       >
       > (3) For the purposes of paragraph (2) such a failure includes,
       in particular, the taking of any step, whether or not involving
       the service of any document, otherwise than—
       >
       > (a)in accordance with the conditions subject to which, or
       > (b)at the time or during the period when,
       >
       > it is authorised or required by the 2022 General Regulations
       or these Regulations to be taken.
       --- End Quote ---
       #Post#: 122504--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: Hippocrates
       Date: June 20, 2026, 5:01 pm
       ---------------------------------------------------------
       What was the original informal challenge? Apart from that, the
       signage is pants and clearly not maintained or even
       substantially compliant.
       #Post#: 122527--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: tincombe
       Date: June 21, 2026, 6:29 am
       ---------------------------------------------------------
       OP, unfortunately 'substantially compliant' is subjective and
       there will be views. But for you only one view counts, and you
       cannot ask that person here.
       For your benefit, I will try and break down the issue.
       IMO, the matter wholly turns on whether the council has placed
       'on or near the road .. such traffic signs in such positions as
       the order making authority may consider requisite for securing
       that adequate information as to the effect of the order is made
       available to persons using the road;' because if an adjudicator
       disagrees then the burden on the council of proving the
       contravention has not been met and your appeal would be allowed.
       In this case the 'traffic signs' are DYL and double kerb blips.
       In both cases, substantial compliance with the Traffic Signs
       etc.  Regs. is the standard. It is also recommended that DKB be
       placed between 2 and 4m apart, preferably 3m, so that in every
       circumstance a driver must park alongside one or 2 sets of DKB
       because there won't be an upright sign to consult.
       Here, the authority is focusing on a single set of DKB, and if
       you know where to look, because it's front and centre in a
       photo, then arguably it's visible.
       But IMO what is unarguable from their perspective is that the
       DKB are not as visible as the DYL and if one was looking for
       another marking with equal prominence, then you would be likely
       to not see the DKB. And given that these markings come in pairs
       i.e. DYL and DKB then, IMO, in order to ensure that adequate
       information as to the [combined] effect of the Order is made
       available' the council should ensure that equal prominence is
       given to both parts AND that the DKB are spaced as recommended
       in the Traffic Signs Manual, Chapter 3. I cannot see another DKB
       in view.
       IMO, make reps but flesh out and not just state 'substantial
       compliance'.
       #Post#: 122530--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: stamfordman
       Date: June 21, 2026, 6:42 am
       ---------------------------------------------------------
       I really don't think there is anything substantially compliant
       here. It isn't necessary to go into detail. I would be inclined
       to make these reps.
       ------
       I am repeating my challenge that the contravention did not
       occur.
       You persist in saying the double yellow lines at this location
       have yellow stripes and no loading signs, but neither are in
       clear evidence in your pictures and nor were they visible to me
       when I parked in good faith as I was displaying my blue badge
       and clock.
       As you are no doubt aware any signage must be compliant and
       clear, and whatever you rely on here is not.
       I trust you will at least check this location for compliance
       rather than reject again and look forward to your cancellation
       this time.
       #Post#: 122584--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: almep13
       Date: June 21, 2026, 4:50 pm
       ---------------------------------------------------------
       Good evening Incandescent, Hippocrates, Tincombe, Stamfordman
       and others.
       I hope you are all well and thank you so much for your views, I
       really appreciate.
       My representation was mainly on the three points below, which
       can also be found on the attached links:
       i) No contravention occurred;
       ii) (Lack of) Restrictions on Canham Road based on list of
       restrictions across Ealing Borough as per its website.
       iii) Unfair treatment of Blue Badge holders.
  HTML https://imgpile.com/p/bSdRplK#TwB9UKx
       - first part of the
       representation
  HTML https://imgpile.com/p/bSdRplK#4tCoZrx
       - 2nd part
       For completeness I'm also attaching on the same post their
       initial decline and then the second decline following my email
       to Ealing Parking Services that there are no visible
       restrictions on Canham Road.
  HTML https://imgpile.com/p/rJWJ1SC#OuIvUI0
       - first decline letter
  HTML https://imgpile.com/p/yfns4Xo#8c0MJLL
       - 2nd decline letter, part
       1
  HTML https://imgpile.com/p/yfns4Xo#Bit7Z0c
       - 2nd decline letter, part
       2
       Thank you and have a good night.
       Kind regards,
       Almep13
       
       #Post#: 122605--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: tincombe
       Date: June 22, 2026, 4:24 am
       ---------------------------------------------------------
       '..the car was stopped to check the electronic entrance gate..'?
       Where's the PCN pl?
       You have said that the driver and passenger(who holds a BB) were
       in the vehicle which you then parked, both of you exited,
       apparently for a purpose associated with an electronic gate, and
       that ???
       You managed to open the gate, went inside and left the vehicle
       or what? Away from the vehicle for ** minutes?
       Saw or didn't see the CEO?
       I suggest you start at the beginning and not the condition of
       DKB?
       #Post#: 122613--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: almep13
       Date: June 22, 2026, 5:43 am
       ---------------------------------------------------------
       Good morning Tincombe,
       The BB holder was on its own and wanted to get through the gate
       to the residential parking. As the gate was indicated as
       "malfunctioning" considering the red/white stripes ribbon, the
       BB holder stopped the car where the alleged contravention took
       place to assess the gate. The BB holder didn't see the warden/
       CEO as the car would have been behind the back of the BB holder
       assessing the gate.
       The BB holder genuinely believed that someone in its position
       may park there for up to three hours (max limit for parking on
       DBL) as no restrictions are indicated and other BB holders tend
       to park time to time in that spot.
       The BB holder was probably away from the car for 5-10 min. But
       the time indicator was shown as 10:30am and the PCN was issued
       at 10:31am. It seems that while the BB holder was assessing the
       gate and unaware what was going on behind its back, the CEO
       issued the PCN. It seems like the CEO has taken max two minutes
       to take pictures and issue the PCN.
       Here are links to the front and back side of the PCN attached to
       the screen of the car.
  HTML https://imgpile.com/p/Rd06rqd#tEUYT9A
       - front side
  HTML https://imgpile.com/p/Rd06rqd#uweJUeY
       - back side
       Thank you and kind regards,
       Almep13
       
       #Post#: 122616--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: tincombe
       Date: June 22, 2026, 6:07 am
       ---------------------------------------------------------
       Thanks. No observation time.
       Personal or vehicular access to Canham Mews, I cannot see
       anything else in the area?
       I'm trying to see if you have another approach other than
       condition of DKB.
       #Post#: 122628--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: almep13
       Date: June 22, 2026, 7:54 am
       ---------------------------------------------------------
       Hi Tincombe,
       it's not access to Canham Mews, the electric gate is for access
       to Factory Quarter.
       However, lack of DKB or visible DBK is an important factor in
       establishing if a contravention took place or not.
       I'll draft an appeal and place it here for comments.
       Thanks and regards,
       Almep13
       #Post#: 122647--------------------------------------------------
       Re: Contravention 02 - Canham Rd, W3 - Parked on double yellow
       line with Blue Badge 
   DIR By: tincombe
       Date: June 22, 2026, 11:34 am
       ---------------------------------------------------------
       An adjudicator would either agree that the markings were not
       substantially compliant or not. A subjective decision.
       The alternative statutory grounds are that you stopped
       momentarily at the location in order to move your vehicle off
       the road via the vehicle access gates, something which should
       have taken no more than 1-2 minutes.
       I've no idea what 'assess the gate' means and I would suggest
       neither would the adjudicator. Neither do I follow that the
       vehicle stopped after the 'gate indicated malfunctioning'.
       'Stopped momentarily' could be a defence IMO, but as this cannot
       be proved objectively, then credibility and plausibility come
       into focus. If the facts, and only you know these, do not fit an
       alternative approach then I agree that you should focus on the
       condition of the DKB in the council's evidence and similarly the
       DKB which are recommended to be repeated regularly in Chapter 3
       of The Traffic Signs Manual and which are equally vague,
       especially when compared to the clarity of the DYL.
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