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       #Post#: 29856--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: ivanleo
       Date: July 14, 2024, 3:58 pm
       ---------------------------------------------------------
       [member=1774]Admiration[/member] the notice to owner must, by
       law, demand the full penalty. However if you make a
       representation before midnight on 24 July, then if a notice of
       rejection is issued the discount should be reoffered for a
       further 14 days.
       I don't have anything to add to the previous draft but for the
       sake of completeness, do you have any mitigating circumstances
       worth raising, especially anything unconnected to the
       contravention itself?
       #Post#: 29858--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 14, 2024, 4:11 pm
       ---------------------------------------------------------
       Thank you again [member=12]Incandescent[/member].
       cp8759 kindly helped me in the initial appeal (before NTO) and
       asked to wait for NTO.
       Many Thanks for your kind response about online portal.
       Kind Regards
       --- Quote from: Incandescent link ---
       >
       > [quote author=Admiration link=topic=1936.msg29792#msg29792
       date=1720899906]
       > Thank you [member=12]Incandescent[/member].
       >
       > I am willing to respond. I need guidance on how I do it, and
       what are things I need to put in my appeal to get it right
       please.
       >
       > Also, wanted to check if the communication from here onwards
       from council will be through email or a portal or they will send
       letters again, if you know, please?
       >
       > Many Thanks
       >
       >
       > [quote author=Incandescent link=topic=1936.msg29676#msg29676
       date=1720808017]
       > You must respond to the Notice to Owner, because if you don't
       you lose all chance of appealing to the adjudicators.
       >
       > The discount is normally only ever offered on the PCN, but
       many councils do re-offer it when refusing reps  against a
       Notice to Owner. Whether Bradford do you'll only find out when
       you submit representations. If you do, make sure you submit them
       within 14 days like a PCN.  Their refusal letter is tosh; there
       is no legal requirement for loading at the roadside to be
       continuous. Sone unloading requires several trips to and from
       the vehicle, which drivers usually lock to prevent theft.
       >
       --- End Quote ---
       [/quote]
       Their portal is best, because you get a response on-line which
       you must keep carefully, (print it out as well).  Rejections to
       formal representations against a Notice to Owner must be in the
       form of a letter in the post.
       If cp8759 is going to prepare some text for you, I'll stand
       aside at this point.
       [/quote]
       #Post#: 29862--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 14, 2024, 4:42 pm
       ---------------------------------------------------------
       Thank you [member=1]cp8759[/member].
       That day, I went to a visa office on that street to submit some
       important documents that were required by the visa office. I had
       an appointment which I wanted to make in time. Before I parked,
       a driving instructors’ car was parked there. I waited for him to
       leave, as he indicated that he was leaving, before I parked my
       car there, believing it was a normal parking space similar to
       the other marked areas. I ensured that I skipped the yellow
       marked area for disabled parking and loading bay (I thought they
       were the same).
       This was my 2nd visit only on that street and on first visit, I
       parked, paid for ticket, displayed it and picked my car after my
       appointment was finished. This time I did exactly the same. I
       did not even give it a second thought, as I checked the markings
       and a car was parked already there, and similar looking signs.
       The signage and road markings were not clear, and I reasonably
       believed I was parking in a permitted area due to the similarity
       in the markings. It was an honest mistake by interpreting the
       signs and markings incorrectly.
       I purchased and displayed a valid parking ticket for the entire
       duration of the stay, which indicate my intention to comply with
       parking regulations. I observed another vehicle parked in the
       same spot and assumed it was a legal parking space, and this
       contributed to my belief that it was permissible to park there
       (same as on the other side of the road, where I parked two weeks
       ago.
       The lack of a clear distinction between the loading bay and the
       pay-and-display parking area also contributed to my confusion.
       If the council can improve the clarity of the signage and
       markings, this will prevent future misunderstandings for all the
       drivers.
       I don’t what else to say, as I believed at the time of parking,
       that I was being a responsible citizen, adhering to the rules of
       the council, and paid correct parking charges, and displayed my
       ticket, as I always do.
       I hope they understand my genuinely honest mistake and cancel
       this PCN.
       Kind Regards
       
       --- Quote from: cp8759 link ---
       >
       > [member=1774]Admiration[/member] the notice to owner must, by
       law, demand the full penalty. However if you make a
       representation before midnight on 24 July, then if a notice of
       rejection is issued the discount should be reoffered for a
       further 14 days.
       >
       > I don't have anything to add to the previous draft but for the
       sake of completeness, do you have any mitigating circumstances
       worth raising, especially anything unconnected to the
       contravention itself?
       >
       --- End Quote ---
       #Post#: 30274--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 18, 2024, 1:13 pm
       ---------------------------------------------------------
       Hi [member=1]cp8759[/member].
       Could you please let me know what should I appeal with, for this
       please? Do I need to use the same text as last time, or anything
       to add from what "H C Andersen" and "Phantomcrusader" have
       suggested, or something you want to add please?
       Kind Regards
       --- Quote from: Admiration link ---
       >
       > Thank you [member=1]cp8759[/member].
       >
       > That day, I went to a visa office on that street to submit
       some important documents that were required by the visa office.
       I had an appointment which I wanted to make in time. Before I
       parked, a driving instructors’ car was parked there. I waited
       for him to leave, as he indicated that he was leaving, before I
       parked my car there, believing it was a normal parking space
       similar to the other marked areas. I ensured that I skipped the
       yellow marked area for disabled parking and loading bay (I
       thought they were the same).
       >
       > This was my 2nd visit only on that street and on first visit,
       I parked, paid for ticket, displayed it and picked my car after
       my appointment was finished. This time I did exactly the same. I
       did not even give it a second thought, as I checked the markings
       and a car was parked already there, and similar looking signs.
       >
       > The signage and road markings were not clear, and I reasonably
       believed I was parking in a permitted area due to the similarity
       in the markings. It was an honest mistake by interpreting the
       signs and markings incorrectly.
       >
       > I purchased and displayed a valid parking ticket for the
       entire duration of the stay, which indicate my intention to
       comply with parking regulations. I observed another vehicle
       parked in the same spot and assumed it was a legal parking
       space, and this contributed to my belief that it was permissible
       to park there (same as on the other side of the road, where I
       parked two weeks ago.
       >
       > The lack of a clear distinction between the loading bay and
       the pay-and-display parking area also contributed to my
       confusion. If the council can improve the clarity of the signage
       and markings, this will prevent future misunderstandings for all
       the drivers.
       >
       > I don’t what else to say, as I believed at the time of
       parking, that I was being a responsible citizen, adhering to the
       rules of the council, and paid correct parking charges, and
       displayed my ticket, as I always do.
       >
       > I hope they understand my genuinely honest mistake and cancel
       this PCN.
       >
       > Kind Regards
       >
       >
       >
       > [quote author=cp8759 link=topic=1936.msg29856#msg29856
       date=1720990700]
       > [member=1774]Admiration[/member] the notice to owner must, by
       law, demand the full penalty. However if you make a
       representation before midnight on 24 July, then if a notice of
       rejection is issued the discount should be reoffered for a
       further 14 days.
       >
       > I don't have anything to add to the previous draft but for the
       sake of completeness, do you have any mitigating circumstances
       worth raising, especially anything unconnected to the
       contravention itself?
       >
       --- End Quote ---
       [/quote]
       #Post#: 30308--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: ivanleo
       Date: July 18, 2024, 7:06 pm
       ---------------------------------------------------------
       [member=1774]Admiration[/member] I think the text you've put in
       reply 22 above is fine, if nobody suggests anything additional
       within the next couple of days I suggest you submit it.
       #Post#: 30317--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: H C Andersen
       Date: July 19, 2024, 2:55 am
       ---------------------------------------------------------
       Why does the NTO not use the correct contravention description?
       To elaborate:
       The PCN and NTO both give the following:
       'Parked in a loading place during restricted hours without
       loading'
       The mandated form is:
       'Parked in a loading place or bay during restricted hours
       without loading.'
       The authority are obligated to use the mandated version(The 2022
       Charges Regulations and Annex B to the Secretary of State's
       Statutory Guidance refer). The authority must state why they
       have unilaterally chosen to depart from these grounds which
       prima facie is a procedural impropriety.
       #Post#: 30629--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 21, 2024, 11:39 pm
       ---------------------------------------------------------
       Thanks [member=1]cp8759[/member]. Sorry, due to travel, I could
       not respond earlier.
       --- Quote from: cp8759 link ---
       >
       > [member=1774]Admiration[/member] I think the text you've put
       in reply 22 above is fine, if nobody suggests anything
       additional within the next couple of days I suggest you submit
       it.
       >
       --- End Quote ---
       #Post#: 30639--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 22, 2024, 2:41 am
       ---------------------------------------------------------
       Thanks [member=428]H C Andersen[/member]
       Sorry, due to travel, I could not respond earlier. I have used
       this in my response text in the post below. Please let me know
       if I need to update/amend it in any way necessary.
       Kind Regards
       --- Quote from: H C Andersen link ---
       >
       > Why does the NTO not use the correct contravention
       description?
       >
       > To elaborate:
       >
       > The PCN and NTO both give the following:
       >
       > 'Parked in a loading place during restricted hours without
       loading'
       >
       > The mandated form is:
       >
       > 'Parked in a loading place or bay during restricted hours
       without loading.'
       >
       > The authority are obligated to use the mandated version(The
       2022 Charges Regulations and Annex B to the Secretary of State's
       Statutory Guidance refer). The authority must state why they
       have unilaterally chosen to depart from these grounds which
       prima facie is a procedural impropriety.
       >
       --- End Quote ---
       #Post#: 30641--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 22, 2024, 2:45 am
       ---------------------------------------------------------
       Parking Services
       City of Bradford Metropolitan District Council
       Subject: Appeal Against PCN No. [PCN Number] and Notice to Owner
       (NTO)
       Dear Sir/Madam,
       I am writing to formally contest the Penalty Charge Notice (PCN)
       number [PCN Number] issued to my vehicle, registration number
       [Vehicle Registration Number], on [Date of Incident] at
       [Location]. I also wish to address an issue with the Notice to
       Owner (NTO) that I received.
       Contravention Description Discrepancy: Both the PCN and the NTO
       provide the contravention description as:
       "Parked in a loading place during restricted hours without
       loading."
       However, according to the 2022 Charges Regulations and Annex B
       to the Secretary of State's Statutory Guidance, the mandated
       contravention description is:
       "Parked in a loading place or bay during restricted hours
       without loading."
       The authority is obligated to use the exact wording as mandated.
       The unilateral decision to deviate from the prescribed
       description constitutes a procedural impropriety. As the issuing
       authority, you must adhere to the statutory requirements, and
       any deviation from this constitutes grounds for cancellation of
       the PCN.
       In light of this discrepancy, I request that you provide an
       explanation for the departure from the mandated contravention
       description. Failing to do so and maintaining the issuance of
       the PCN under incorrect procedural grounds would be unjust.
       Additional Mitigating Circumstances: In addition to the
       procedural impropriety mentioned above, I would like to
       reiterate the following mitigating circumstances that I have
       previously outlined:
       1. Purpose of Visit: That day, I went to a visa office on that
       street to submit some important documents that were required by
       the visa office. I had an appointment which I wanted to make in
       time. Before I parked, a driving instructors’ car was parked
       there. I waited for him to leave, as he indicated that he was
       leaving, before I parked my car there, believing it was a normal
       parking space similar to the other marked areas. I ensured that
       I skipped the yellow marked area for disabled parking and
       loading bay (I thought they were the same). The necessity and
       urgency of this appointment required my presence, and I made
       every effort to comply with parking regulations by purchasing a
       valid ticket, and following the road markings.
       2. Ambiguity in Signage and Road Markings: This was my 2nd visit
       only on that street and on first visit, I parked, paid for
       ticket, displayed it and picked my car after my appointment was
       finished. This time I did exactly the same. I did not even give
       it a second thought, as I checked the markings and a car was
       parked already there, and similar looking signs. The signage and
       road markings at the location were confusing and not distinctly
       clear. This led me to reasonably believe that the area was a
       permitted parking space.
       3. Genuine Mistake: I made an honest mistake in interpreting the
       signs and markings. To comply with parking regulations, I
       purchased a valid parking ticket (receipt attached) and
       displayed it prominently in my car for the entire duration of my
       stay.
       4. Observed Prior Parking Behaviour: Before parking, I noticed
       another vehicle parked in the same spot. This further reinforced
       my belief that it was a legal parking space, contributing to my
       belief that it was permissible to park there (same as on the
       other side of the road, where I parked two weeks ago). I waited
       for the vehicle to leave and then parked in good faith.
       5. Lack of Clear Distinction: The lack of a clear distinction
       between the loading bay and the pay-and-display parking area
       significantly contributed to my confusion. I strongly urge the
       council to consider improving the clarity of the signage and
       road markings to prevent future misunderstandings for other
       motorists.
       6. First-Time Offense: I believed at the time of parking, that I
       was being a responsible citizen, adhering to the rules of the
       council, and paid correct parking charges, and displayed my
       ticket, as I always do. This is my first parking offense, and I
       have always adhered to parking regulations in the past. I assure
       you that I have learned from this experience and will be more
       vigilant in the future.
       Request for Cancellation: In light of the procedural impropriety
       and the additional mitigating circumstances, I kindly request
       the council to exercise discretion and consider cancelling the
       PCN. I have demonstrated my intention to comply with parking
       rules and have provided evidence of my genuine mistake.
       Thank you for considering my appeal. I look forward to your
       favourable response.
       Yours faithfully,
       #Post#: 30642--------------------------------------------------
       Re: PCN - Loading Bay - Code 25 - Bradford
   DIR By: Admiration
       Date: July 22, 2024, 2:54 am
       ---------------------------------------------------------
       Respected members, I have shared my text in Post #28 which I am
       planning to use in the appeal.
       [member=904]Phantomcrusader[/member] - I could not find more
       details on your response (Post #13) about "The NTO appears to be
       missing this ground of appeal." Could you please let me know
       what I need to use in my appeal for the 3 things you mentioned,
       please?
       [member=428]H C Andersen[/member] - I hope I have used your
       inputs correctly, but please let me know I have not.
       [member=1]cp8759[/member] - I request you to please review and
       edit/approve as necessary please.
       As always, thank you so much for your guidance and support in
       this.
       Kind Regards
       *****************************************************
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