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       #Post#: 22220--------------------------------------------------
       PCN for using Loading Bay from Brent Council
   DIR By: Driver86
       Date: May 12, 2024, 5:41 pm
       ---------------------------------------------------------
       Hello everyone...it was a cold wet night on 1st March and I was
       out working as a courier. I parked in a loading bay at North End
       Road to complete my deliveries to a block of flats. I was parked
       there for about 20 minutes. When I returned to my car I was
       stunned to get a PCN, especially as I had put a note on my
       dashboard.
       Here is the bay 4 N End Rd
  HTML https://maps.app.goo.gl/hp6eUcz8Psi9EGJo7
       The PCN has code 25 parked in a loading bay during restricted
       hours without loading.
  HTML https://ibb.co/VS4GJtD
       I appealed the PCN, stating that I am a courier driver and that
       I work alone, and could not risk leaving my windows/doors
       unlocked and open for the benefit of a CEO or a thief. I
       highlighted that I had left a message on my dashboard and I used
       the bay within the restrictions as stated on the sign plate.
       I was also unable to obtain delivary confirmation due to GDPR,
       which I advice the LA.
       Brent responded to my appeal on 2nd May, here is their reply
  HTML https://ibb.co/smYWJ8b
  HTML https://ibb.co/QrcM5nK
       To summarise they state
       ●the bays are only for delivering to locations next to the
       bay
       ●PCN would be issued if no evidence of loading is
       observed.
       The CEO observed my vehicle for 6 minutes out of the 40 the
       signage permits. Do I have any grounds to keep fighting this?
       #Post#: 22250--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: fraser.mitchell
       Date: May 13, 2024, 4:38 am
       ---------------------------------------------------------
       Well, of course their letter is complete tosh, (no surprise
       there !). However the key question is - did you provide any
       collateral with your representations like a delivery schedule,
       proof of employment as a delivery driver etc ?
       It would also help if you posted your representation text.
       It should be reasonably easy to overturn this, assuming you have
       some collateral as above, but as they've rejected your informal
       reps, the next stage is the Notice to Owner if you are prepared
       to take this further. The NtO is sent to the name and address on
       the V5.  So, are you the owner of the vehicle and is it your
       name and address on the V5 Registration Certificated, and is it
       up=to-date ?
       #Post#: 22322--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: Driver86
       Date: May 13, 2024, 4:00 pm
       ---------------------------------------------------------
       Yes I submitted my insurance schedule. Unable to obtain proof of
       specific delivary info.
       Here is my informal rep:
       I am challenging this PCN as I do not believe that the
       contravention occurred. I am a courier driver and vehicle is
       classed as a commercial vehicle. Please see attached document. I
       am unable to provide delivary information as that is
       confidential relating to a customer and restricted by GDPR. I
       used the loading bay for a maximum of 20 minutes to complete my
       deliveries. I work alone and therefore I am unable to leave my
       vehicle unlocked with doors and windows open whilst I deliver
       the parcels. However, as can be seen in the enforcement officers
       photos, I left a note on my front dashboard windscreen
       indicating that I am currently making deliveries. The signage,
       as can be seen next to the bay and photo taken by your
       enforcement officer, clearly states "loading only 40 minutes, no
       return within 2 hours". Therefore I am uncertain which rule I am
       alleged to have contravened. The CEO observed my vehicle for 6
       minutes. The enforcement officer alleges I was parked outside of
       restricted hours, but there are no restricted hours stated on
       the sign plate. It is therefore wholly unreasonable for the
       Local Authority to continue pursuing this and should take the
       appropriate action to cancel this PCN.
       #Post#: 22336--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: fraser.mitchell
       Date: May 13, 2024, 5:45 pm
       ---------------------------------------------------------
       I don't think what you have provided proves you were delivering.
       You need something much more positive, and that has to be either
       a schedule of your deliveries, but without specific addressees.
       A contract with the delivery company would also help, or a
       letter confirming you were delivering that day.  Sorry, but you
       have to convince the council you really were in that bay for
       delivery purposes.
       #Post#: 23056--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: ivanleo
       Date: May 19, 2024, 7:39 am
       ---------------------------------------------------------
       [member=73]Driver86[/member] this is easily winnable but we need
       to substantiate your representations for the next stage.
       Firstly, please read the guidance here
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/<br
       />and repost the PCN without any redactions.
       Secondly, who do you work for? Amazon? Evri? Whatever company it
       is that pays you, you must have some documentation confirming
       you actually work as a courier. A work schedule would help, or
       even something confirming you were paid for work done on that
       day.
       Also if you have any correspondence (emails, whatsapp messages,
       text messages, whatever) showing that you tried to get delivery
       information but this was refused because of GDPR, copies of that
       correspondence would be important supporting evidence.
       Lastly do you remember roughly how many deliveries there were,
       and which buildings they were in?
       #Post#: 35109--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: Driver86
       Date: August 30, 2024, 4:47 pm
       ---------------------------------------------------------
       Hi everyone, so i have a response back from them regarding this
       Loading bay contravention. The enforcement team are fixated on
       getting the customers home address which seems to be the block
       to overturning this. I did manage to get a letter from the
       courier service owners(Amazon) confirming I was on a delivary
       block, and that they can not provide addresses. Links below and
       left details to locate PCN if required. Feedback appreciated.
       NOR
  HTML https://ibb.co/XsCGQ3z
  HTML https://ibb.co/ZgZ3PMp
  HTML https://ibb.co/CWhrGZm
       Letter evidence
  HTML https://ibb.co/VWbPSZD
       --- Quote from: cp8759 link ---
       >
       > [member=73]Driver86[/member] this is easily winnable but we
       need to substantiate your representations for the next stage.
       >
       > Firstly, please read the guidance here
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/<br
       />and repost the PCN without any redactions.
       >
       > Secondly, who do you work for? Amazon? Evri? Whatever company
       it is that pays you, you must have some documentation confirming
       you actually work as a courier. A work schedule would help, or
       even something confirming you were paid for work done on that
       day.
       >
       > Also if you have any correspondence (emails, whatsapp
       messages, text messages, whatever) showing that you tried to get
       delivery information but this was refused because of GDPR,
       copies of that correspondence would be important supporting
       evidence.
       >
       > Lastly do you remember roughly how many deliveries there were,
       and which buildings they were in?
       >
       --- End Quote ---
       I used the loading bay to deliver to 3 locations, one of them
       being the building on that side of the bay.
       #Post#: 35115--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: H C Andersen
       Date: August 31, 2024, 2:42 am
       ---------------------------------------------------------
       Procedural impropriety of the worst kind IMO.
       1. A NOR is the end of the council's involvement in considering
       any reps. It does not lie with them to offer to reconsider as
       they've stated.
       2. The NOR does not contain the correct mandatory info regarding
       the form and manner in which an appeal may be made. Specifically
       it omits the highlighted part of the following:
       (2) An appeal under this regulation must be made within—
       (a)the period of 28 days beginning with the date of service of
       the decision notice under regulation 6(4)(b) which states that
       the enforcement authority does not accept the recipient’s
       representations, or
       (b)such longer period as the adjudicator may allow.
       3. Not only is this vital information omitted, the authority
       reinforce the impropriety by stating the following which is
       found in lines 4 and 5 of the last para. on page 2 of the NOR:
       '...penalty charge may increase by 50%. At this stage you would
       have missed the opportunity to appeal.'
       What arrogance, it's breathtaking. The adjudicator may and often
       does accept appeals made even after a charge cert has been
       issued.
       4. The council's threat to apply for costs. This is intimidating
       in that they are effectively trying to limit the scope and
       content of any appeal. OP, I've referred to this as point 4
       because you could then use it to lead in to ..'as regards the
       issue of costs, you would respectfully ask the adjudicator for a
       steer as regards any application that you might make given the
       cumulative effect of the improprieties detailed above..'
       OP, when and how did you submit reps against the NTO - you've
       skipped this step in the thread? You should aim to register your
       appeal no later than 13 Sept.
       #Post#: 35629--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council (Adjudication
       stage)
   DIR By: Driver86
       Date: September 4, 2024, 10:15 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       >
       > OP, when and how did you submit reps against the NTO - you've
       skipped this step in the thread? You should aim to register your
       appeal no later than 13 Sept.
       >
       --- End Quote ---
       Thanks for the feedback. I did think there was alot of arrogance
       in there too! I submitted the formal rep in June I believe. At
       the time I was on holiday whilst awaiting a Subject Access
       Request with Amazon which unfortunately didn't yield anything I
       can use. So requested they confirm my schedule for the day.
       I'll start drafting up an appeal to take to adjudication in the
       coming days.
       #Post#: 36262--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: Driver86
       Date: September 9, 2024, 4:24 pm
       ---------------------------------------------------------
       I've drafted up a rep for adjudication...
       I am submitting this representation on the grounds that I do not
       believe the contravention occurred for the following reasons:
       The vehicle was parked and made use of the loading bay at 20:11,
       as I believe I was entitled to do so. I am a courier driver
       working for Amazon’s “flex” programme, and therefore I am a 3rd
       party contractor.
       Here is an image of the restriction I am alleged to have
       contravened.
       <image of signage>
       Being a private contractor, I therefore do not have access to
       Amazon’s internal customer database, and any request for this
       information is restricted by GDPR, which the enforcement
       authority appears to dismiss.
       I have, however, provided the enforcement authority with
       information detailing that in between the hours of 19:00 and
       21:00 I was on a shift making deliveries. I also explained to
       the enforcement authority that as I work alone, I cannot leave
       my vehicle’s windows and doors unlocked for the consideration of
       a CEO with the risk of theft.
       
       Furthermore, I have reason to believe there is procedural
       impropriety on behalf of the authority Notice to Owner.
       The NOR does not contain the correct mandatory info regarding
       the form and manner in which an appeal may be made. Specifically
       it omits the highlighted part of the following:
       (2) An appeal under this regulation must be made within—
       (a)the period of 28 days beginning with the date of service of
       the decision notice under regulation 6(4)(b) which states that
       the enforcement authority does not accept the recipient’s
       representations, or
       (b)such longer period as the adjudicator may allow.
       3. Not only is this vital information omitted, the authority
       reinforce the impropriety by stating the following which is
       found in lines 4 and 5 of the last para. on page 2 of the NOR:
       '...penalty charge may increase by 50%. At this stage you would
       have missed the opportunity to appeal.'
       Please advise what else I can add to stregnthen?
       #Post#: 36450--------------------------------------------------
       Re: PCN for using Loading Bay from Brent Council
   DIR By: Driver86
       Date: September 11, 2024, 9:55 am
       ---------------------------------------------------------
       Hi all, just a bit worried that with deadline coming up if
       someone with experience can look over?
       What would be ideal reps for this, a telephone hearing or submit
       written?
       Thanks!
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