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       #Post#: 21244--------------------------------------------------
       27 - Parked in a special enforcement area adjacent to a footway,
       lowered ... STREATHAM
   DIR By: LemonTootski
       Date: May 1, 2024, 3:50 pm
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       Hi There,
       I wonder if one could cast eyers over this one.
       Parked on a lowered driveway, but trhe driveway was closed a
       closed off, residential place. No opening and no obstruction.
       A street parking officer issued this.
       Considering the no obstruction occurred, i wondered is there a
       case for no conrravention?
       Your thoughts would be most appreciated.
       Thanks.
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       #Post#: 21247--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: guest17
       Date: May 1, 2024, 4:15 pm
       ---------------------------------------------------------
  HTML https://maps.app.goo.gl/ovWHpnanz9Gs5di99
  HTML https://www.legislation.gov.uk/ukpga/2004/18/section/86
       I would say it's defunct therefore no contravention.
       However if it was designed to allow cyclists to leave the
       carriageway and enter Stanedge Court then you would be in
       difficulty.
       Mike
       #Post#: 21258--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: fraser.mitchell
       Date: May 1, 2024, 5:12 pm
       ---------------------------------------------------------
       Here it is in July 2008; no fence and clearly dropped to give
       access : -.
  HTML https://maps.app.goo.gl/qvhxFKbsRuaaF4SF7
       Later views show a fence with a gate, like here, July 2012, the
       next time the GSV camera van passed: -
  HTML https://maps.app.goo.gl/3rQ13zVAnEi7i7dL8
       So I think it is pretty clear that the purpose of this dropped
       kerb has gone. And what's more GSV shows that it has so a
       credible appeal can be assembled if the council prove to be
       obdurate.
       #Post#: 21381--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: ivanleo
       Date: May 2, 2024, 6:03 pm
       ---------------------------------------------------------
       [member=1458]LemonTootski[/member] I am extremely worried by
       your screenshot and this in particular:
  HTML https://i.imgur.com/QHMOi4V.png
       Please can you confirm if the notice to owner has been received,
       and if so whether a formal representation has been made?
       #Post#: 21387--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: LemonTootski
       Date: May 2, 2024, 6:55 pm
       ---------------------------------------------------------
       --- Quote from: cp8759 link ---
       >
       > [member=1458]LemonTootski[/member] I am extremely worried by
       your screenshot and this in particular:
       >
       >
  HTML https://i.imgur.com/QHMOi4V.png
       >
       > Please can you confirm if the notice to owner has been
       received, and if so whether a formal representation has been
       made?
       >
       --- End Quote ---
       Hi cp8759,
       Yes, i completely realise I've left this a little late. Was
       completely inundated with other bits and pieces as life gets in
       the way. notice to the owner has been received, and no
       representation has been lodged to date. We're just a little late
       on this one.
       But despite the PCN being the full amount, I'm just seeing if
       there's a case to be made as per the use (non-use) as per
       Incandescent's point:
       --- Quote ---
       >
       > So I think it is pretty clear that the purpose of this dropped
       kerb has gone. And what's more GSV shows that it has so a
       credible appeal can be assembled if the council prove to be
       obdurate.
       --- End Quote ---
       It's probably likely the council won't uphold the Rep, and I
       might have to appeal. Does anyone know if there's has been any
       successful prescendents
       Googling, shows a lot of cached information for PCN 27 on the
       old Pepipoo fightback forums, but unfortunately, the page/forum
       is no more (Why did we stop this useful resource,, with all this
       wealth of information?)
       And fiunally, on Mike's point:
       --- Quote ---
       > I would say it's defunct therefore no contravention.
       >
       > However if it was designed to allow cyclists to leave the
       carriageway and enter Stanedge Court then you would be in
       difficulty.
       --- End Quote ---
       If you assert that it's defunct and therefore no contravention,
       how would one encapsulate this in  the form of a representation?
       I do realise that if it's not likely this case is in my favour,
       than just  to cut my losses and cough up ... But would first
       like to explore all avenues, as the initial overriding reason
       just for being at that spot was my understanding that the use of
       the dropped kerb (as entrance to residential area) is no longer
       in practice (Seeing the history from google street view
       imagery).
       Any thoughts?
       #Post#: 21389--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: fraser.mitchell
       Date: May 2, 2024, 7:03 pm
       ---------------------------------------------------------
       Please post the Notice to Owner.  I have a dreadful feeling
       you've left everything too late and have lost the option to
       submit reps against it.
       #Post#: 21478--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: ivanleo
       Date: May 3, 2024, 4:22 pm
       ---------------------------------------------------------
       [member=1458]LemonTootski[/member] well most unhelpfully you've
       redacted the PCN number and the number plate so we're flying
       blind as we can't check the amount outstanding.
       All you can do at this point is check for yourself, if the
       website still allows you to I suggest you submit a
       representation right this very second (not tomorrow morning)
       just saying that the alleged contravention did not occur. This
       should make it easy for them to issue a notice of rejection
       which is what you want.
       If the PCN has already gone up to £165 let us know and we'll
       have to attempt an out of time representation, but there's no
       guarantee the council would agree to consider it.
       #Post#: 21489--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: LemonTootski
       Date: May 3, 2024, 5:42 pm
       ---------------------------------------------------------
       Hi there, thanks for your input. Fortunately, the fine is still
       at £110.
       I can still make representations. The Council PCN notice details
       on the website states:
       --- Quote ---
       > The amount outstanding on the Charge Notice will increase to
       £165.00 on Fri, 31 May 2024. Please pay £110.00 now.
       --- End Quote ---
       So I guess there's nothing to lose now in spending time
       investigating this.
       Why is it still £110 and not £165?
       Lambeth actually extended the allotted time. After seeing the
       ticket, i popped into a corner ship for a minute. When I
       returned to my car I discovered that some schoolkids had ripped
       off the ticket from the car. Consequently, I had to contact the
       council to request a re-issue, which they did, 14 days later,
       hence, granting the additional time. As such, I still think
       there might be a case to investigate the legality of the
       contravention - and there is still time.
       So the route I'm thinking of is the initial use of the dropped
       curve (as seen in historic GSV photos), is no longer the case.
       Yet i lack the firm evidence and legal backdrop to clarify this,
       and thus contest the contravention - hence i am here.
       If we believe there is absolutely no case to make (between now
       and say, 29 March), then I guess I am happy to cut my losses,
       pay the £110, and put it down to experience. This post would
       also help others in same situation.
       But if it can be contested and and evidence proving the
       contravention is not enforceable, this would be highly
       beneficial to others.
       Thanks for listening - Do let me know your thoughts.
       #Post#: 21503--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: ivanleo
       Date: May 3, 2024, 6:38 pm
       ---------------------------------------------------------
       [member=1458]LemonTootski[/member] this is really simple and
       does not require any extensive investigation:
       [indent]
       Dear London Borough of Lambeth,
       It is only a contravention to park adjacent to a dropped kerb if
       the kerb has been lowered for one of the statutory purposes
       listed in section 86 of the Traffic Management Act 2004. It is
       obvious from the Google Street View history that this particular
       dropped kerb was originally installed as a bin access ramp for
       the bins stored in Stanedge Court, see the image from July 2008
       at
  HTML https://maps.app.goo.gl/TSeQBmMtahEK7yreA
       It might have been arguable that the lowered kerb could also be
       used by cyclists entering or leaving the carriageway, and there
       is nothing to suggest that a "dual purpose" lowered kerb could
       not be enforced under section 86.
       However by September 2020 access to this lowered kerb from
       Stanedge Court had been blocked off by the installation of a
       permanent fence, as shown by the image at
  HTML https://maps.app.goo.gl/xt9in4vkLXkPxhxs6
       That fence was present at the time of the alleged contravention
       and as far as I am aware, is still there.
       As such the kerb no longer fulfills any of the statutory
       purposes at section 86 of the TMA 2004, even if one accepts that
       the kerb was ever lowered for the purposes of the statute.
       I refer you to the case of Abigail Mendy v London Borough of
       Enfield (2160476330, 4 January 2017) and while I know councils
       love the mantra that first-instance cases are not binding, there
       is simply no reason to suppose the tribunal would reach a
       different conclusion in this instance.
       In light of the above the alleged contravention did not occur,
       and the penalty charge must be cancelled.
       Yours faithfully,
       [/indent]
       Submit this online and please make sure to keep a screenshot of
       the confirmation page.
       #Post#: 21601--------------------------------------------------
       Re: 27 - Parked in a special enforcement area adjacent to a
       footway, lowered ... STREATHAM
   DIR By: LemonTootski
       Date: May 5, 2024, 8:12 am
       ---------------------------------------------------------
       Thanks very much for this. I actually came across the Mendy case
       by doing some Google research, but could not find/read this
       case. Do you have a link?
       A Google search points back to the old PePiPoo Fightback Forums
       - and sadly, this resource website is down. Please tell me the
       treasure trove of information can still be available to the
       public. I do hope this site is archived.
       But cp875, thanks for this template for a rep. Before I submit,
       I just wanted to clarify. You stated:
       --- Quote ---
       > As such the kerb no longer fulfils any of the statutory
       purposes at section 86 of the TMA 2004, even if one accepts that
       the kerb was ever lowered for the purposes of the statute.
       >
       --- End Quote ---
       Is that your assumption, or is it in fact?
       I ask, because it is indeed my (and anyone else's) reasonable
       assumption that an old dropped kerb next to a blocked
       off/no-longer used entrance.  no longer fulfils its purpose, but
       where is this explicitly manifested in statutory law? Does the
       installation of the green fence nullify this, and is there
       precedent ? (I'm hoping this Mendy case which i cannot see, has
       similar precedent).
       Any concrete info would be more than reassuring, thanks.
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