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       #Post#: 23312--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: guest17
       Date: May 21, 2024, 2:55 am
       ---------------------------------------------------------
       Ground 3
       The sign governing the bay is not contained within The Traffic
       Signs Regulations and General Directions 2016 nor have the
       Council obtained DfT permission to use it. There is no provision
       within the legislation to use the term "Residents" nor a permit
       identifier for anything other than a dedicated bay reserved for
       an individual disabled person.Therefore the traffic sign is a
       nullity and cannot be enforced, making the PCN invalid.
       Ground 4
       The Council's intention of reserving disabled bays for residents
       only is discriminatory (against non-resident disabled people)
       and I would refer you to both the Equality Act 2010 and moreso
       to The Equality Act 2010 (Amendment) Regulations 2023.
       Therefore the traffic management rationale giving rise to the
       TMO is fatally flawed to the extent that the Council actions are
       ultra vires. In such circumstances enforcement of this bay
       cannot proceed.
       Mike
       #Post#: 23329--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: LondonTraveller84
       Date: May 21, 2024, 3:50 am
       ---------------------------------------------------------
       Thanks Mike! let me send the amended Groundds 3 & 4 in addition
       to my 1 & 2 across now.. and see what they come back with,
       fairly confident it'll be rejected then independant adjudicator
       it is.
       Groudn 4 surely they'll just laught it off, while it makes sense
       however to them they don't even consider such things and will
       see this as a null point assuming as would the adjudicator?
       #Post#: 23339--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: John U.K.
       Date: May 21, 2024, 4:11 am
       ---------------------------------------------------------
       Date of Service is defined in law as two working days from date
       of posting which is assumed to be date of letter unless
       rebutted.
       When sending reps online make sure you keep a copy and also a
       copy of the receipt/automated acknowledgement.
       #Post#: 23350--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: H C Andersen
       Date: May 21, 2024, 4:40 am
       ---------------------------------------------------------
       With respect, I disagree and I'll set out my thinking.
       There is no ISA (wheelchair) symbol on the sign, therefore it is
       not a 'parking place reserved for disabled badge holders.'
       Instead, there is the standard 'P' and it is a 'Parking place' -
       see item 2 of the Part 4 Sign Table -
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/4/made
       (the bay also looks like it doesn't meet the min. size
       requirements for a disabled bay)
       IMO, it is a permit bay and the type of user and permit
       identifier are Disabled Resident Permit Holder E.
       The other way of looking at the issue would be that if it was a
       dedicated disabled bay then as it doesn't carry the ISA symbol
       (column 3) then this wins on its own and it's not necessary to
       explore column 4 issues.
       OP, the car was parked without displaying or holding the
       required permit. If you are going to rely upon an exemption, in
       this case loading, then it is your legal burden to prove your
       entitlement.
       The CEO's photo shows an unattended vehicle.
       You claim that you were in the process of '..loading at premises
       adjacent to the parking place in which the vehicle is waiting
       and the vehicle does not wait for such purpose for more than
       twenty minutes or for such longer period as a parking attendant
       may approve.'
       So, IMO you need something like:
       On ** I had been visiting ** who lives at no. *** which is a
       property adjacent to the parking place in question....and then
       your account. I suggest you start with this because as regards
       the facts regarding what you were doing, you're the only one who
       knows and there are very important matters which as yet haven't
       been aired. Your reps leap straight into legal matters when, if
       you are entitled to the exemption, the only issue is to set out
       why you are entitled.
       For example:
       Looking at your photo, there's enough luggage etc. for an army.
       If it's yours, then you must have been stating..in which case if
       you only moved your car into the parking place at the time of
       loading, where was it until then and why couldn't loading have
       waited until another parking place was free etc. etc.
       'Adjacent', which I think is key, is not defined and therefore
       subjective. Here's one I saw online:
       Adjacent means close to or near something. You may consider the
       people up and down your street to be neighbors, but your
       next-door neighbor is the person who lives in the house or
       apartment adjacent to yours. Adjacent can refer to two things
       that touch each other or have the same wall or border.
       #Post#: 23361--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: guest17
       Date: May 21, 2024, 5:29 am
       ---------------------------------------------------------
       @hca
       The contravention is a Code 16 with the suffix "5" "dedicated
       disabled bay"; the sign reads "Disabled Resident Permit Holders
       Only"; the road marking reads "Disabled", all of which, I
       believe, is sufficient to identify what we are dealing with.
       That's without the clear steer from the TMO.
       The Council were given permission to dispense with the
       wheelchair logo here:-
  HTML https://assets.dft.gov.uk/trafficauths/case-3311.pdf
       In other words the sign at "Q" has the same meaning as a Diagram
       661A here:-
  HTML https://www.legislation.gov.uk/uksi/2002/3113/schedule/2/made
       Mike
       #Post#: 23397--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: LondonTraveller84
       Date: May 21, 2024, 8:15 am
       ---------------------------------------------------------
       HC Anderson, so are we not to use Grounds 3 and 4, sorry all
       this goes way above my head yet am trying my best to make sense
       of it. - If you and Mike can give me some direction on what to
       do around the points of contention, do I add both points..
       As for the Ground 1, which was the core point I'm relying on, so
       the property on xx, is my parents and I live there with them,
       teh car is also my parents with me a named driver, and we were
       loading the car as we were going up north.
       "On X date I had bought my car around from the next road where
       it was parked to where we/parents live at no. ***, which is a
       property adjacent to the parking place in question....and then
       your we started loading the car?
       I can check if my ring camera has recordings showing how long it
       was parked?
       Good question, from what I remember I had bought the car from a
       car wash, so had not been parked, prior to this it was parked on
       a different road, which would have made it very difficult to
       carry the luggage across. I could have waited for a spare space,
       but this could be minutes or hours, and that too no garauntee
       it'll be near or at the end of the road. So in a nut shell I
       guess I would be saying
       And based on waht John said around service, does that give me
       another day or so to place with although have had bads
       experience, so am keen to get this across  today - asume for the
       intial PCN appeal to teh council this concept doesn't apply
       right?
       #Post#: 23398--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: John U.K.
       Date: May 21, 2024, 8:23 am
       ---------------------------------------------------------
       --- Quote ---
       > my parents and I live there with them, teh car is also [b]my
       parents[/b] with me a named driver
       --- End Quote ---
       The reps against the NtO must be in the name of the person named
       on the NtO (should = registered keeper).
       #Post#: 23402--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: LondonTraveller84
       Date: May 21, 2024, 8:39 am
       ---------------------------------------------------------
       --- Quote from: John U.K. link ---
       >
       > [quote]my parents and I live there with them, teh car is also
       [b]my parents[/b] with me a named driver
       --- End Quote ---
       The reps against the NtO must be in the name of the person named
       on the NtO (should = registered keeper).
       [/quote]
       Okay in that case do i have to act on behlaf of my father purely
       because the NtO is in the reigstered keepers name, going forward
       when it goes to adjudication, would I be able to take it forward
       or he will have to, even though I was teh driver ?
       Or does this change what I say, I should it be said my son had
       driven the car and was loading etc?
       #Post#: 23408--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: John U.K.
       Date: May 21, 2024, 9:08 am
       ---------------------------------------------------------
       --- Quote from: LondonTraveller84 link ---
       >
       > [quote author=John U.K. link=topic=1954.msg23398#msg23398
       date=1716297799]
       > [quote]my parents and I live there with them, teh car is also
       [b]my parents[/b] with me a named driver
       --- End Quote ---
       The reps against the NtO must be in the name of the person named
       on the NtO (should = registered keeper).
       [/quote]
       Okay in that case do i have to act on behlaf of my father purely
       because the NtO is in the reigstered keepers name, going forward
       when it goes to adjudication, would I be able to take it forward
       or he will have to, even though I was teh driver ?
       Or does this change what I say, I should it be said my son had
       driven the car and was loading etc?
       [/quote]
       He can certainly give you written authority to act for him at
       adjudication: I thinkl (but am not certain) he can to the same
       for reps against NtO. Probably simpler (as you're online) to
       write the reps as from him.
       #Post#: 23411--------------------------------------------------
       Re: Disabled Bay - Notice to Owner
   DIR By: LondonTraveller84
       Date: May 21, 2024, 10:07 am
       ---------------------------------------------------------
       --- Quote from: John U.K. link ---
       >
       > [quote author=LondonTraveller84
       link=topic=1954.msg23402#msg23402 date=1716298748]
       > [quote author=John U.K. link=topic=1954.msg23398#msg23398
       date=1716297799]
       > [quote]my parents and I live there with them, teh car is also
       [b]my parents[/b] with me a named driver
       --- End Quote ---
       The reps against the NtO must be in the name of the person named
       on the NtO (should = registered keeper).
       [/quote]
       Okay in that case do i have to act on behlaf of my father purely
       because the NtO is in the reigstered keepers name, going forward
       when it goes to adjudication, would I be able to take it forward
       or he will have to, even though I was teh driver ?
       Or does this change what I say, I should it be said my son had
       driven the car and was loading etc?
       [/quote]
       He can certainly give you written authority to act for him at
       adjudication: I thinkl (but am not certain) he can to the same
       for reps against NtO. Probably simpler (as you're online) to
       write the reps as from him.
       [/quote]
       Sure I'll do the rep as from him, but I guess in temrs of the
       incident I should refer to myself as my son was parked and
       loading correct? as the initial appeal I wrote from myself and
       said I was loading?
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