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       #Post#: 37305--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: EllHas
       Date: September 18, 2024, 5:44 am
       ---------------------------------------------------------
       One person has 12 PCNs for that one road?!
       Thank you for this, I'll find a sensible place to add it in
       alongside the rest of what you have sent me and I'll post it
       here before replying to the council.
       Thanks again for your help.
       #Post#: 37312--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: Hippocrates
       Date: September 18, 2024, 6:03 am
       ---------------------------------------------------------
       Yes. And his colleague has 10. I await your draft. I am going to
       make a video about this location as it is becoming too infamous.
       Their hearings will be at the end of October after I have
       meditated under my Plane Tree.
       #Post#: 37614--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: EllHas
       Date: September 20, 2024, 7:36 am
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > Yes. And his colleague has 10. I await your draft. I am going
       to make a video about this location as it is becoming too
       infamous. Their hearings will be at the end of October after I
       have meditated under my Plane Tree.
       >
       --- End Quote ---
       Sorry for the delay with this. It's been a busy few days and I
       wanted the proper amount of time to put this together.
       Please find it below. Hopefully it's ok!
       ----
       Dear Lewisham Council
       I make these formal representations against PCN: ZY09702771
       Preamble:
       On Saturday 7th September I needed to drive my 1 year old son
       from my home in Mottingham to my father’s house in Catford.
       Normally I would either drive via Grove Park or go via the A205.
       However, on that day, a decision was made to close off the
       bridge at St Mildreds Road, result in horrendous traffic. And
       so, with a restless baby in the back seat, I did my best to
       navigate the blockages. What should have been a 10-minute
       journey, became an hour and a half nightmare.
       Regarding the journey in question, having finally made it past
       the worst of the traffic only to discover that the passing under
       the bridge was closed (there was no prior warning about this), I
       decided to try driving down Manor Lane, hoping that I could
       cross via Hither Green and then make my way back up. It has been
       many years since I have driven through that particular area as
       I’d had no need to. I was aware that there was a width
       restriction road somewhere along the route, but had no reason to
       believe that it would affect my car.
       I progressed onto Leahurst Road, approached the point of the
       alleged contravention and then turned left onto Ennersdale Road.
       At the top of Ennersdale Road I discovered that the road was
       closed off to all motor vehicles and there was no way to
       progress onto Hither Green, so I was forced to turn back and
       retrace my journey through the disgraceful traffic caused by
       road closures and lack of adequate signage.
       Regarding the point of alleged contravention, I did not see any
       signage or prior warnings to indicate that there was a motor
       restricted road on Leahurst Road/Ennersdale Road. I was
       concentrating on how the road took a sharp left following a
       narrowing with a pedestrian island with another road straight
       ahead and a clear no entry sign.
       I then received a PCN and had to return to the site in order to
       ascertain what had triggered this. I noted that there is only a
       small sign placed directly on the corner of the shop, up high -
       when driving, you are not looking at that area - you are
       navigating the tight corner- pedestrian island and oncoming
       traffic. Furthermore, the sign could easily appear to relate to
       the very clearly marked no entry road that is directly across on
       the continuation of Leahurst Road and not the left turn onto
       Ennersdale Road.
       I also noted, that once a vehicle has progressed  to the point
       that the sign can be clearly seen, read and understood, it is
       then blocked from turning and avoiding the closure due to the
       narrow pedestrian island. If there are any vehicles following
       closely behind or oncoming on the other side of the road (as
       there were when I was driving), stopping and trying to reverse
       or turn away would surely result in an accident. Thus, a
       driver’s only sensible option at that point would be to progress
       past the sign onto Ennersdale Road and then turn around at the
       first safe opportunity.
       As such – This is not a clearly signed restriction – the sign is
       placed in an obscure location after passing the narrowing of the
       road and leaves nowhere to turn off if you do observe it in
       time. The sign is also confusing as it could relate to Leahurt
       Road directly in front which is a no access road. A driver
       should not be expected to spend time trying to decipher a road
       sign whilst also needing to make quick decisions and careful
       manoeuvrers due to changes in a road’s layout.
       Specific grounds:
       The section of TSRGD that applies to this restriction is
       Schedule 3 Parts 1-5: “Upright signs that indicate regulatory
       requirements for moving traffic”. The sign that denotes the
       restriction at issue is at item 12 of the table at Schedule 3
       Part 2 viz. “Motor vehicles prohibited”. The table further
       indicates provisions and general directions applicable to the
       sign. Item 12 is subject to General Direction 1 in Schedule 3
       General Directions.
       Schedule 3 General Direction 1 stipulates:
       “1.- (1). The sign must only be placed to indicate the effect of
       an Act, order, regulation, bylaw, resolution or notice which
       prohibits or restricts the use of the road by traffic.
       (2) When the sign is placed to indicate the point at which a
       restriction, requirement or
       prohibition begins or ends, it must be placed as near as
       practicable to that point.”
       The TSRGD 2016 further stipulates size, colour, sign design and
       illumination.  Further The Traffic Signs Manual in its
       Introduction to Chapter 1 outlines how the manual should be used
       and interpreted:
       9.1.  para 1.1.1 –“Whilst the Manual can assist with complying
       with the mandatory requirements, it cannot provide a definitive
       legal interpretation, nor can it override them. This remains the
       prerogative of courts or parking adjudicators in relation to the
       appearance and use of specific traffic signs, road markings etc.
       at specific locations”.
       Para. 1.2.1 states “In the Manual, the word “must” is used to
       indicate a legal requirement of the Traffic Signs Regulations
       and General Directions (or other legislation) that must be
       complied with.  The word “should” indicates a course of action
       that is recommended and represents good practice. The word “may”
       generally indicates a permissible action, or an option that
       requires consideration depending on the circumstances.”
       In the following representations, I cite sections of the TSM One
       (16) and Three  to illustrate the responsibilities of Traffic
       Authorities when positioning a sign of this type.
       Insufficient signage
       I say that the signage is insufficient because:
       The placement of the terminal sign does not allow the driver to
       understand the message quickly and easily at the point that is
       needed. It provides the message too late for the safe
       performance of any necessary manoeuvre given the road layout. I
       rely on para. 1.3.2 in Chapter One of the TSM and not the use of
       the word “must” indicating a legal requirement (18): “1.3.2. In
       order to achieve safe and efficient operation of a highway
       network, it is essential that all signing provided is necessary,
       clear and unambiguous, and gives its message to road users at
       the appropriate time. The message must be quickly and easily
       understood at the point it is needed; neither too soon that the
       information might be forgotten, nor too late for the safe
       performance of any necessary manoeuvre.”
       Schedule 3, General Direction 1 in the TSRGD (2016) states that
       such signs should be placed “as near as practicable” to the
       point at which the restriction begins, suggesting that
       discretion can be used in placing the sign. It would be
       practicable to place the sign in advance of the traffic island
       in order for drivers to manoeuvre to comply.
       In the following appeals, the adjudica
       tors have found the signage placement to be insufficient:
       224022084; 2230544814; 2240024490; 2240047190; 2240003548.
       Road geometry
       This road geometry immediately in advance of this sign presents
       the driver with multiple other matters to safely navigate,
       drawing their attention and reducing the time available to
       consider the single terminal sign announcing this restriction. I
       rely upon Chapter One TSM, para. 4.3.3: “In deciding the
       appropriate provision of terminal signs, the following factors
       should be taken into account:
       • Turning angles
       • Road geometry including vertical alignment
       • One way traffic conditions
       • Sign mounting height”
       In this case, the road geometry includes:
       • The traffic island and accompanying signage indicating road
       layout and direction of traffic. This appears as a traffic
       calming measure and the bollard sign indicates that traffic
       should keep left. This is at odds with the restriction to motor
       vehicles proceeding.
       • The junction with Orchid Close and potential traffic turning
       onto Leahurst Road.
       • The junction with Longhurst Road and potential traffic onto
       Leahurst Road.
       • Parked traffic along the length of Leahurst Road on either
       side presenting the vehicle the potential for car doors, pets or
       pedestrians to enter the carriageway without being easily
       discerned in advance.
       • The driver’s attention is drawn by these aspects of road
       geometry in advance of the restriction, limiting the driver’s
       capacity to discern the sole terminal sign as they approach the
       restriction ahead.
       • The adjudicators have considered a number of these aspects and
       others in cases: 2240059713; 224005978A; 2240076778; 2240047190;
       2240003548.
       Single Terminal Sign
       Other location use two terminal signs viz. Dallinger Road and
       Holme Lacy Road. The restrictions are identical. Two terminal
       signs would better draw the attention of westbound drivers on
       Leahurst Road and better signal the restriction, which is
       unexpected given the unimpeded nature of the carriageway, the
       traffic island signage which indicates to keep left, and the
       appearance of the island being a traffic calming measure. When
       choosing one terminal sign, authorities are required to ensure
       it does not give rise to issues relating to enforcement.  I cite
       from TSM Chapter One:
       • “2.4.1. Terminal signs indicating the start of a restriction,
       requirement, prohibition or speed limit should not necessarily
       be duplicated on each side of the carriageway…..but care should
       be taken to ensure that, where a single sign is used, it is
       clearly visible to all relevant road users, and does not give
       rise to issues relating to road safety or enforcement. There
       remains a duty on traffic authorities to place such signs as
       they consider will give adequate guidance of a regulatory
       measure.”
       • By using only one terminal sign and placing it at the end of
       the traffic island, adequate guidance of a regulatory measure is
       not given to drivers and thus gives rise to issues relating to
       enforcement.
       • Consistency of sign appearance and uniformity are covered in
       TSM Chapter One at para. 2.2.1: “Consistency of sign appearance
       and use are essential for road safety….Warning signs sited at
       different distances from the associated hazards in different
       localities, for instance, could mislead road users who venture
       outside their local area. To obtain the fullest benefits of
       uniformity, therefore, there should not only be uniformity of
       signs but also uniformity in their use, in their siting and
       their illumination.”
       • The said principle must surely apply within one authority. By
       using two terminal signs at some locations to denote the same
       restriction but only one in this location, consistency is
       certainly not achieved. Furthermore, there is no consistency
       between the warning signage on Leahurst Road and that provided
       in Longhurst Road, the latter being larger and clearer. The
       adjudicator has found the single terminal sign to be
       insufficient in cases: 2240162596; 2240024490 and 223053111A.
       Single Terminal Sign and Junction
       The TSM Chapter Three gives further guidance on the placement of
       upright signs giving effect to TMOs and turning at road
       junctions at 1.8.6.: “There are likely to be some situations
       where two signs will still be preferable…Drivers should not be
       placed in the situation where they might not see the sign before
       starting to turn at a road junction.”
       Insufficient Advance Warning Sign on Leahurst Road
       Whilst it is accepted that this is discretionary, the sign in
       Leahurst Road has been found wanting and it is small and placed
       on the offside only.  Further, it runs the risk of larger
       vehicles travelling in the opposite direction obscuring it.
       Referring to TSM Chapter One, para. 5.2.3: “Road users are
       accustomed to signs being on the near side of the road and such
       positioning should be the general practice. However, siting on
       the off side is appropriate in certain circumstances – for
       example where there are difficulties in siting on the near side,
       or where a direction sign is located opposite or in the entrance
       toa side road. Worthwhile economies might be gained at some
       locations, such as at T-junctions, where one structure carrying
       direction signs facing both ways will suffice instead of a sign
       on the near side for each approach. At sharp left-hand bends,
       siting on the off side might not only be appropriate but
       preferable, although consideration must be given to the risk of
       the sign being obscured by oncoming vehicles or leading drivers
       to pass on the right-hand side.”
       There is no apparent reason for using just one sign. Further,
       the adjudicator has found it insufficient in cases: 223053111A;
       223054814; 2240059713; 224005978A; 2240076778 and 2240047190.
       In addition: 2240102845; 223041997A and 2240003548.
       Re advanced warning signs in Leahurst Road and Longhurst Road
       1. You have produced a Regulatory sign smaller than the minimal
       recommendation of 450mm
       subsequently reducing the sign’s legibility. The circumference
       of the sign measures 310mm which
       is 31% smaller than the recommended 450mm.
       I refer to  TSRGD guidelines Chapter 3 (Schedule 3, Part 2).
       2. You have placed a Regulatory sign upon a blue backing board
       and you have added a white
       border to that backing board. In doing so, you have detracted
       from the signs recognisable
       silhouette.
       See TSRGD guidelines, Chapter 3, Introduction, 1.11 Backing
       boards.
       In particular, 1.11.1.
       ….A backing board must not itself be provided with a border, nor
       give the impression of
       being an additional border. Where it seems that a sign is not
       being noticed by drivers,
       it should be checked to ensure that it is well sited, not
       obscured by vegetation or other
       obstructions, and is of the appropriate size and in good
       condition...
       and 1.11.3.
       1.11.3. There are potential disadvantages to the use of backing
       boards. The larger overall
       size of the assembly can sometimes obstruct sight lines. A
       backing board can deprive
       non rectangular signs of a primary recognition aid: their
       distinctive silhouette. Yellow
       backing boards can be especially environmentally intrusive, and
       their over use could
       eventually devalue their attention attracting benefits. A less
       garish way of increasing a
       sign’s conspicuity is simply to provide a standard sign of
       larger size. Not only will this be
       more noticeable than a smaller sign, but it will also improve
       legibility and hence reading
       distance, which a yellow backing board cannot.
       3. You have mounted the sign in Lonhgurst Road at a height
       outside of the TSRGD recommendations.
       The base of the backing board of Sign 1 is 2.9m from the ground.
       See TSRGD guidelines, Chapter 1, Section 5, Positioning of
       Signs, 5.4 Mounting heights
       5.4.1. Signs should be mounted such that the lower edge of the
       sign is generally
       between 900 mm and 1500 mm above the highest point of the
       adjacent carriageway.
       Signs mounted at the lower end of this range benefit from
       receiving the most illumination
       from vehicle headlamps, but they are also prone to soiling due
       to spray from passing vehicles.
       Mounting heights at the higher end of the range should be used
       where this or obscuration by
       other vehicles is likely to be a problem. Speed limit signs and
       other safety-critical signs will not
       normally be mounted lower than 1500 mm above the carriageway.
       The base of the blue backing board mounted to the lamppost is
       2.90m off the ground meaning
       the Regulatory sign itself is even higher. This is above eye
       line in a moving vehicle. This is the
       only warning sign that would give the driver the option to avoid
       driving into the restricted area by
       turning right into Longhurst Road.
       4. You have mounted the sign along with 3 other signs making 4
       in total when the
       recommendation is 2 maximum.
       See TSRGD guidelines, Chapter 3, Introduction, 1.10 Mounting
       more than one sign on a post
       1.10.1. Research has shown that the greater the number of signs
       which drivers are
       presented with simultaneously, the greater the difficulty they
       are likely to have in
       assimilating the information. This problem in dealing with
       information overload increases
       with age, so that older drivers suffer disproportionately.
       Generally, therefore, not more
       than two signs should be erected on any one post when intended
       to be read from an
       approaching vehicle…
       5. Although not compulsory to use 2 signs, one each side of the
       road, you have chosen not to
       install dedicated housing but instead have utilised an existing
       lamppost on the offside of the
       road, further reducing the sign’s visibility and effectiveness.
       See TSRGD guidelines, Chapter 3, Introduction, 1.8 Siting of
       upright signs
       1.8.5. There is no specific requirement that signs indicating
       the beginning of a restriction
       or prohibition must be placed on each side of the road or on
       each side of the appropriate
       carriageway of a dual carriageway road (see 8.2 in respect of
       speed limit signs). This
       relaxation has been made to reduce environmental impact, but
       care should be taken to
       ensure that a single sign is clearly visible to all road users
       and does not give rise to
       issues relating to enforcement or road safety...
       Re terminal sign
       The second sign is situated approx. 3 metres from where the
       prohibition comes into force.
       By the time you are upon this sign there is nowhere else to go
       but to enter into the enforcement
       area. Your camera is set to capture vehicles at that point.
       Additionally, Sign 2 is backed by another sign, at a different
       height, with a grey backing, causing
       further clutter and distraction.
       You have used a yellow backing board for Sign 2 (as well as
       several other signs in the immediate
       area).
       See TSRGD guidelines, Chapter 1, Introduction, Section 7, Sign
       Backgrounds
       7.2 Backing boards
       7.2.2. Yellow backing boards are intrusive; they should be used
       sparingly, and not as a
       matter of course. They can reduce the attention drivers give to
       other, more important,
       signs and over use could eventually devalue their
       attention-attracting benefits.
       See TSRGD guidelines, Chapter 3, Introduction, 1.11 Backing
       boards.
       1.11.3. There are potential disadvantages to the use of backing
       boards. The larger overall
       size of the assembly can sometimes obstruct sight lines. A
       backing board can deprive
       non rectangular signs of a primary recognition aid: their
       distinctive silhouette. Yellow
       backing boards can be especially environmentally intrusive, and
       their over use could
       eventually devalue their attention attracting benefits. A less
       garish way of increasing a
       sign’s conspicuity is simply to provide a standard sign of
       larger size. Not only will this be
       more noticeable than a smaller sign, but it will also improve
       legibility and hence reading
       distance, which a yellow backing board cannot.
       To summarise, the signs you have in place to warn drivers they
       will be entering a prohibited area
       are ineffective.
       The first (Sign 1) is as good as invisible and the second (Sign
       2) is badly situated, poorly mounted
       and lost in a sea of signs.
       As the driver approaches the prohibited area, the most prominant
       sign(s) to oncoming traffic are
       the No Entry signs, positioned in the drivers direct line of
       sight on Eastdown Park. The colour, size
       and shape of the No Entry signs grab the drivers attention.
       The No Entry signs take visual precedence due to their size,
       silhouette, positioning and
       colour. The driver’s focus is on the No Entry signs and not the
       yellow backed board set back
       from the junction.
       Regardless, even if the sign was spotted, by that point there is
       nothing to do but to drive into the
       prohibited area.
       It should be noted that there are an unusually high number of
       road signs in the area. There are
       signs for weight restrictions, parking restrictions, no entry
       signs, cycle signs to name but a few.
       It is unsurprising that drivers become sign fatigued and
       distracted.
       ETA Register of Appeals
       I refer you to two separate cases for this same issue in which
       it was agreed that the signage was inadequate. Demonstrating
       that I am not the only motorist who has had an issue with the
       placement of the signage.
       Register kept under Regulation 20 of the Road Traffic (Parking
       Adjudicators) (London) Regulations 1993, as amended and
       Regulation 17 of the Civil Enforcement of Road Traffic
       Contraventions (Representations and Appeals) (England)
       Regulations 2022.
       Case Details
       Case reference   2240328826
       Appellant   Sharmini Christie
       Authority   London Borough of Lewisham
       VRM   LC20YKE
       PCN Details
       PCN   ZY09452368
       Contravention date   11 Jun 2024
       Contravention time   09:51:00
       Contravention location   Leahurst Road - Westbound
       Penalty amount   GBP 130.00
       Contravention   Fail comply prohibition on certain types vehicle
       Referral date
       Decision Date   03 Sep 2024
       Adjudicator   Andrew Harman
       Appeal decision   Appeal allowed
       Direction  - Cancel the Penalty Charge Notice.
       Reasons
       The appellant represented, by Mr Morgan, appeared before me
       today at Chancery Exchange.
       The council did not attend the hearing
       Two penalty charges formed the subject of this appeal it being
       alleged that this vehicle at Leahurst Road on the dates and at
       the times given failed to comply with a prohibition on certain
       types of vehicle.
       Mr Morgan said that he had uploaded a skeleton argument to the
       case a week ago.
       No such document was before me.
       He raised the issue of signage arguing that it was inadequate.
       The council's one regulatory sign was posted on the left of the
       carriageway as shown on its online footage of the incident and
       in its supporting images. I acknowledged that this sign on the
       council's case was preceded by advance warning signage but this
       single regulatory sign was in my judgment too inconspicuous to
       satisfy the test of sufficiency of signage and I accordingly
       found that these contraventions had not been proved.
       PCN   ZY09462485
       Contravention date   13 Jun 2024
       Contravention time   09:31:00
       Contravention location   Leahurst Road - Westbound
       Penalty amount   GBP 130.00
       Contravention   Fail comply prohibition on certain types vehicle
       Referral date
       Decision Date   03 Sep 2024
       Adjudicator   Andrew Harman
       Appeal decision   Appeal allowed
       Direction - Cancel the Penalty Charge Notice.
       Reasons
       The appellant represented, by Mr Morgan, appeared before me
       today at Chancery Exchange.
       The council did not attend the hearing
       Two penalty charges formed the subject of this appeal it being
       alleged that this vehicle at Leahurst Road on the dates and at
       the times given failed to comply with a prohibition on certain
       types of vehicle.
       Mr Morgan said that he had uploaded a skeleton argument to the
       case a week ago.
       No such document was before me.
       He raised the issue of signage arguing that it was inadequate.
       The council's one regulatory sign was posted on the left of the
       carriageway as shown on its online footage of the incident and
       in its supporting images. I acknowledged that this sign on the
       council's case was preceded by advance warning signage but this
       single regulatory sign was in my judgment too inconspicuous to
       satisfy the test of sufficiency of signage and I accordingly
       found that these contraventions had not been proved.
       The Penalty Charge Notice
       On the website that you have provided in order to view
       photographs and video footage of the alleged contravention, it
       should be noted that the follow notice is displayed on my case
       file “This PCN is now closed. Thank you. This PCN is past the
       stage at which you can challenge it or make representations”.
       The alleged contravention occurred on 7/9/24, the date of the
       PCN was 13/9/24 and the date at which I observed this notice on
       the website was 20/9/24. I still within the 14 day period and
       well within the 28 day period as stipulated by your own PCN.
       Therefore the information on this website is incorrect and
       highly misleading.
       In light of the above, I request a response to all of the points
       raised and I ask for the PCN to be cancelled.
       Reg. keeper
       Address
       #Post#: 37618--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: H C Andersen
       Date: September 20, 2024, 8:12 am
       ---------------------------------------------------------
       Far too long IMO.
       I also think you need to be clear as regards what point you are
       trying to make because you offer different reasons - possibly
       due to its length you lose focus.
       You either saw the sign or you did not.
       I did see the sign:
       But because this was not until after I'd entered the chicane I
       felt that I had no safe road user option other than to carry on.
       I did not see the sign at the time:
       When I visited soon after receiving the PCN the reasons why I
       and, I now know, other motorists have missed the sign is because
       of *****. In my case **** but the attached tribunal cases(take
       them out of the body of your reps please) identify ****
       additional reasons.
       Would be my approach. But IMO you must choose and I suggest
       based upon what you and only you know happened and not to
       opportunistically try and adopt other motorists' arguments. Use
       these as further examples of reasons why the sign is poorly
       placed but write from your knowledge of events.
       Wait for other comments.
       #Post#: 37632--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: Hippocrates
       Date: September 20, 2024, 11:20 am
       ---------------------------------------------------------
       --- Quote from: EllHas link ---
       >
       > [quote author=Hippocrates link=topic=3155.msg37312#msg37312
       date=1726657390]
       > Yes. And his colleague has 10. I await your draft. I am going
       to make a video about this location as it is becoming too
       infamous. Their hearings will be at the end of October after I
       have meditated under my Plane Tree.
       >
       --- End Quote ---
       Sorry for the delay with this. It's been a busy few days and I
       wanted the proper amount of time to put this together.
       Please find it below. Hopefully it's ok!
       ----
       Dear Lewisham Council
       I make these formal representations against PCN: ZY09702771
       Preamble:
       On Saturday 7th September I needed to drive my 1 year old son
       from my home in Mottingham to my father’s house in Catford.
       Normally I would either drive via Grove Park or go via the A205.
       However, on that day, a decision was made to close off the
       bridge at St Mildreds Road, result in horrendous traffic. And
       so, with a restless baby in the back seat, I did my best to
       navigate the blockages. What should have been a 10-minute
       journey, became an hour and a half nightmare.
       Regarding the journey in question, having finally made it past
       the worst of the traffic only to discover that the passing under
       the bridge was closed (there was no prior warning about this), I
       decided to try driving down Manor Lane, hoping that I could
       cross via Hither Green and then make my way back up. It has been
       many years since I have driven through that particular area as
       I’d had no need to. I was aware that there was a width
       restriction road somewhere along the route, but had no reason to
       believe that it would affect my car.
       I progressed onto Leahurst Road, approached the point of the
       alleged contravention and then turned left onto Ennersdale Road.
       At the top of Ennersdale Road I discovered that the road was
       closed off to all motor vehicles and there was no way to
       progress onto Hither Green, so I was forced to turn back and
       retrace my journey through the disgraceful traffic caused by
       road closures and lack of adequate signage.
       Regarding the point of alleged contravention, I did not see any
       signage or prior warnings to indicate that there was a motor
       restricted road on Leahurst Road/Ennersdale Road. I was
       concentrating on how the road took a sharp left following a
       narrowing with a pedestrian island with another road straight
       ahead and a clear no entry sign.
       I then received a PCN and had to return to the site in order to
       ascertain what had triggered this. I noted that there is only a
       small sign placed directly on the corner of the shop, up high -
       when driving, you are not looking at that area - you are
       navigating the tight corner- pedestrian island and oncoming
       traffic. Furthermore, the sign could easily appear to relate to
       the very clearly marked no entry road that is directly across on
       the continuation of Leahurst Road and not the left turn onto
       Ennersdale Road.
       I also noted, that once a vehicle has progressed  to the point
       that the sign can be clearly seen, read and understood, it is
       then blocked from turning and avoiding the closure due to the
       narrow pedestrian island. If there are any vehicles following
       closely behind or oncoming on the other side of the road (as
       there were when I was driving), stopping and trying to reverse
       or turn away would surely result in an accident. Thus, a
       driver’s only sensible option at that point would be to progress
       past the sign onto Ennersdale Road and then turn around at the
       first safe opportunity.
       As such – This is not a clearly signed restriction – the sign is
       placed in an obscure location after passing the narrowing of the
       road and leaves nowhere to turn off if you do observe it in
       time. The sign is also confusing as it could relate to Leahurt
       Road directly in front which is a no access road. A driver
       should not be expected to spend time trying to decipher a road
       sign whilst also needing to make quick decisions and careful
       manoeuvrers due to changes in a road’s layout.
       Specific grounds:
       The section of TSRGD that applies to this restriction is
       Schedule 3 Parts 1-5: “Upright signs that indicate regulatory
       requirements for moving traffic”. The sign that denotes the
       restriction at issue is at item 12 of the table at Schedule 3
       Part 2 viz. “Motor vehicles prohibited”. The table further
       indicates provisions and general directions applicable to the
       sign. Item 12 is subject to General Direction 1 in Schedule 3
       General Directions.
       Schedule 3 General Direction 1 stipulates:
       “1.- (1). The sign must only be placed to indicate the effect of
       an Act, order, regulation, bylaw, resolution or notice which
       prohibits or restricts the use of the road by traffic.
       (2) When the sign is placed to indicate the point at which a
       restriction, requirement or
       prohibition begins or ends, it must be placed as near as
       practicable to that point.”
       The TSRGD 2016 further stipulates size, colour, sign design and
       illumination.  Further The Traffic Signs Manual in its
       Introduction to Chapter 1 outlines how the manual should be used
       and interpreted:
       9.1.  para 1.1.1 –“Whilst the Manual can assist with complying
       with the mandatory requirements, it cannot provide a definitive
       legal interpretation, nor can it override them. This remains the
       prerogative of courts or parking adjudicators in relation to the
       appearance and use of specific traffic signs, road markings etc.
       at specific locations”.
       Para. 1.2.1 states “In the Manual, the word “must” is used to
       indicate a legal requirement of the Traffic Signs Regulations
       and General Directions (or other legislation) that must be
       complied with.  The word “should” indicates a course of action
       that is recommended and represents good practice. The word “may”
       generally indicates a permissible action, or an option that
       requires consideration depending on the circumstances.”
       In the following representations, I cite sections of the TSM One
       (16) and Three  to illustrate the responsibilities of Traffic
       Authorities when positioning a sign of this type.
       Insufficient signage
       I say that the signage is insufficient because:
       The placement of the terminal sign does not allow the driver to
       understand the message quickly and easily at the point that is
       needed. It provides the message too late for the safe
       performance of any necessary manoeuvre given the road layout. I
       rely on para. 1.3.2 in Chapter One of the TSM and not the use of
       the word “must” indicating a legal requirement (18): “1.3.2. In
       order to achieve safe and efficient operation of a highway
       network, it is essential that all signing provided is necessary,
       clear and unambiguous, and gives its message to road users at
       the appropriate time. The message must be quickly and easily
       understood at the point it is needed; neither too soon that the
       information might be forgotten, nor too late for the safe
       performance of any necessary manoeuvre.”
       Schedule 3, General Direction 1 in the TSRGD (2016) states that
       such signs should be placed “as near as practicable” to the
       point at which the restriction begins, suggesting that
       discretion can be used in placing the sign. It would be
       practicable to place the sign in advance of the traffic island
       in order for drivers to manoeuvre to comply.
       In the following appeals, the adjudica
       tors have found the signage placement to be insufficient:
       224022084; 2230544814; 2240024490; 2240047190; 2240003548.
       Road geometry
       This road geometry immediately in advance of this sign presents
       the driver with multiple other matters to safely navigate,
       drawing their attention and reducing the time available to
       consider the single terminal sign announcing this restriction. I
       rely upon Chapter One TSM, para. 4.3.3: “In deciding the
       appropriate provision of terminal signs, the following factors
       should be taken into account:
       • Turning angles
       • Road geometry including vertical alignment
       • One way traffic conditions
       • Sign mounting height”
       In this case, the road geometry includes:
       • The traffic island and accompanying signage indicating road
       layout and direction of traffic. This appears as a traffic
       calming measure and the bollard sign indicates that traffic
       should keep left. This is at odds with the restriction to motor
       vehicles proceeding.
       • The junction with Orchid Close and potential traffic turning
       onto Leahurst Road.
       • The junction with Longhurst Road and potential traffic onto
       Leahurst Road.
       • Parked traffic along the length of Leahurst Road on either
       side presenting the vehicle the potential for car doors, pets or
       pedestrians to enter the carriageway without being easily
       discerned in advance.
       • The driver’s attention is drawn by these aspects of road
       geometry in advance of the restriction, limiting the driver’s
       capacity to discern the sole terminal sign as they approach the
       restriction ahead.
       • The adjudicators have considered a number of these aspects and
       others in cases: 2240059713; 224005978A; 2240076778; 2240047190;
       2240003548.
       Single Terminal Sign
       Other location use two terminal signs viz. Dallinger Road and
       Holme Lacy Road. The restrictions are identical. Two terminal
       signs would better draw the attention of westbound drivers on
       Leahurst Road and better signal the restriction, which is
       unexpected given the unimpeded nature of the carriageway, the
       traffic island signage which indicates to keep left, and the
       appearance of the island being a traffic calming measure. When
       choosing one terminal sign, authorities are required to ensure
       it does not give rise to issues relating to enforcement.  I cite
       from TSM Chapter One:
       • “2.4.1. Terminal signs indicating the start of a restriction,
       requirement, prohibition or speed limit should not necessarily
       be duplicated on each side of the carriageway…..but care should
       be taken to ensure that, where a single sign is used, it is
       clearly visible to all relevant road users, and does not give
       rise to issues relating to road safety or enforcement. There
       remains a duty on traffic authorities to place such signs as
       they consider will give adequate guidance of a regulatory
       measure.”
       • By using only one terminal sign and placing it at the end of
       the traffic island, adequate guidance of a regulatory measure is
       not given to drivers and thus gives rise to issues relating to
       enforcement.
       • Consistency of sign appearance and uniformity are covered in
       TSM Chapter One at para. 2.2.1: “Consistency of sign appearance
       and use are essential for road safety….Warning signs sited at
       different distances from the associated hazards in different
       localities, for instance, could mislead road users who venture
       outside their local area. To obtain the fullest benefits of
       uniformity, therefore, there should not only be uniformity of
       signs but also uniformity in their use, in their siting and
       their illumination.”
       • The said principle must surely apply within one authority. By
       using two terminal signs at some locations to denote the same
       restriction but only one in this location, consistency is
       certainly not achieved. Furthermore, there is no consistency
       between the warning signage on Leahurst Road and that provided
       in Longhurst Road, the latter being larger and clearer. The
       adjudicator has found the single terminal sign to be
       insufficient in cases: 2240162596; 2240024490 and 223053111A.
       Single Terminal Sign and Junction
       The TSM Chapter Three gives further guidance on the placement of
       upright signs giving effect to TMOs and turning at road
       junctions at 1.8.6.: “There are likely to be some situations
       where two signs will still be preferable…Drivers should not be
       placed in the situation where they might not see the sign before
       starting to turn at a road junction.”
       Insufficient Advance Warning Sign on Leahurst Road
       Whilst it is accepted that this is discretionary, the sign in
       Leahurst Road has been found wanting and it is small and placed
       on the offside only.  Further, it runs the risk of larger
       vehicles travelling in the opposite direction obscuring it.
       Referring to TSM Chapter One, para. 5.2.3: “Road users are
       accustomed to signs being on the near side of the road and such
       positioning should be the general practice. However, siting on
       the off side is appropriate in certain circumstances – for
       example where there are difficulties in siting on the near side,
       or where a direction sign is located opposite or in the entrance
       toa side road. Worthwhile economies might be gained at some
       locations, such as at T-junctions, where one structure carrying
       direction signs facing both ways will suffice instead of a sign
       on the near side for each approach. At sharp left-hand bends,
       siting on the off side might not only be appropriate but
       preferable, although consideration must be given to the risk of
       the sign being obscured by oncoming vehicles or leading drivers
       to pass on the right-hand side.”
       There is no apparent reason for using just one sign. Further,
       the adjudicator has found it insufficient in cases: 223053111A;
       223054814; 2240059713; 224005978A; 2240076778 and 2240047190.
       In addition: 2240102845; 223041997A and 2240003548.
       Re advanced warning signs in Leahurst Road and Longhurst Road
       1. You have produced a Regulatory sign smaller than the minimal
       recommendation of 450mm
       subsequently reducing the sign’s legibility. The circumference
       of the sign measures 310mm which
       is 31% smaller than the recommended 450mm.
       I refer to  TSRGD guidelines Chapter 3 (Schedule 3, Part 2).
       2. You have placed a Regulatory sign upon a blue backing board
       and you have added a white
       border to that backing board. In doing so, you have detracted
       from the signs recognisable
       silhouette.
       See TSRGD guidelines, Chapter 3, Introduction, 1.11 Backing
       boards.
       In particular, 1.11.1.
       ….A backing board must not itself be provided with a border, nor
       give the impression of
       being an additional border. Where it seems that a sign is not
       being noticed by drivers,
       it should be checked to ensure that it is well sited, not
       obscured by vegetation or other
       obstructions, and is of the appropriate size and in good
       condition...
       and 1.11.3.
       1.11.3. There are potential disadvantages to the use of backing
       boards. The larger overall
       size of the assembly can sometimes obstruct sight lines. A
       backing board can deprive
       non rectangular signs of a primary recognition aid: their
       distinctive silhouette. Yellow
       backing boards can be especially environmentally intrusive, and
       their over use could
       eventually devalue their attention attracting benefits. A less
       garish way of increasing a
       sign’s conspicuity is simply to provide a standard sign of
       larger size. Not only will this be
       more noticeable than a smaller sign, but it will also improve
       legibility and hence reading
       distance, which a yellow backing board cannot.
       3. You have mounted the sign in Lonhgurst Road at a height
       outside of the TSRGD recommendations.
       The base of the backing board of Sign 1 is 2.9m from the ground.
       See TSRGD guidelines, Chapter 1, Section 5, Positioning of
       Signs, 5.4 Mounting heights
       5.4.1. Signs should be mounted such that the lower edge of the
       sign is generally
       between 900 mm and 1500 mm above the highest point of the
       adjacent carriageway.
       Signs mounted at the lower end of this range benefit from
       receiving the most illumination
       from vehicle headlamps, but they are also prone to soiling due
       to spray from passing vehicles.
       Mounting heights at the higher end of the range should be used
       where this or obscuration by
       other vehicles is likely to be a problem. Speed limit signs and
       other safety-critical signs will not
       normally be mounted lower than 1500 mm above the carriageway.
       The base of the blue backing board mounted to the lamppost is
       2.90m off the ground meaning
       the Regulatory sign itself is even higher. This is above eye
       line in a moving vehicle. This is the
       only warning sign that would give the driver the option to avoid
       driving into the restricted area by
       turning right into Longhurst Road.
       4. You have mounted the sign along with 3 other signs making 4
       in total when the
       recommendation is 2 maximum.
       See TSRGD guidelines, Chapter 3, Introduction, 1.10 Mounting
       more than one sign on a post
       1.10.1. Research has shown that the greater the number of signs
       which drivers are
       presented with simultaneously, the greater the difficulty they
       are likely to have in
       assimilating the information. This problem in dealing with
       information overload increases
       with age, so that older drivers suffer disproportionately.
       Generally, therefore, not more
       than two signs should be erected on any one post when intended
       to be read from an
       approaching vehicle…
       5. Although not compulsory to use 2 signs, one each side of the
       road, you have chosen not to
       install dedicated housing but instead have utilised an existing
       lamppost on the offside of the
       road, further reducing the sign’s visibility and effectiveness.
       See TSRGD guidelines, Chapter 3, Introduction, 1.8 Siting of
       upright signs
       1.8.5. There is no specific requirement that signs indicating
       the beginning of a restriction
       or prohibition must be placed on each side of the road or on
       each side of the appropriate
       carriageway of a dual carriageway road (see 8.2 in respect of
       speed limit signs). This
       relaxation has been made to reduce environmental impact, but
       care should be taken to
       ensure that a single sign is clearly visible to all road users
       and does not give rise to
       issues relating to enforcement or road safety...
       Re terminal sign
       The second sign is situated approx. 3 metres from where the
       prohibition comes into force.
       By the time you are upon this sign there is nowhere else to go
       but to enter into the enforcement
       area. Your camera is set to capture vehicles at that point.
       Additionally, Sign 2 is backed by another sign, at a different
       height, with a grey backing, causing
       further clutter and distraction.
       You have used a yellow backing board for Sign 2 (as well as
       several other signs in the immediate
       area).
       See TSRGD guidelines, Chapter 1, Introduction, Section 7, Sign
       Backgrounds
       7.2 Backing boards
       7.2.2. Yellow backing boards are intrusive; they should be used
       sparingly, and not as a
       matter of course. They can reduce the attention drivers give to
       other, more important,
       signs and over use could eventually devalue their
       attention-attracting benefits.
       See TSRGD guidelines, Chapter 3, Introduction, 1.11 Backing
       boards.
       1.11.3. There are potential disadvantages to the use of backing
       boards. The larger overall
       size of the assembly can sometimes obstruct sight lines. A
       backing board can deprive
       non rectangular signs of a primary recognition aid: their
       distinctive silhouette. Yellow
       backing boards can be especially environmentally intrusive, and
       their over use could
       eventually devalue their attention attracting benefits. A less
       garish way of increasing a
       sign’s conspicuity is simply to provide a standard sign of
       larger size. Not only will this be
       more noticeable than a smaller sign, but it will also improve
       legibility and hence reading
       distance, which a yellow backing board cannot.
       To summarise, the signs you have in place to warn drivers they
       will be entering a prohibited area
       are ineffective.
       The first (Sign 1) is as good as invisible and the second (Sign
       2) is badly situated, poorly mounted
       and lost in a sea of signs.
       As the driver approaches the prohibited area, the most prominant
       sign(s) to oncoming traffic are
       the No Entry signs, positioned in the drivers direct line of
       sight on Eastdown Park. The colour, size
       and shape of the No Entry signs grab the drivers attention.
       The No Entry signs take visual precedence due to their size,
       silhouette, positioning and
       colour. The driver’s focus is on the No Entry signs and not the
       yellow backed board set back
       from the junction.
       Regardless, even if the sign was spotted, by that point there is
       nothing to do but to drive into the
       prohibited area.
       It should be noted that there are an unusually high number of
       road signs in the area. There are
       signs for weight restrictions, parking restrictions, no entry
       signs, cycle signs to name but a few.
       It is unsurprising that drivers become sign fatigued and
       distracted.
       ETA Register of Appeals
       I refer you to two separate cases for this same issue in which
       it was agreed that the signage was inadequate. Demonstrating
       that I am not the only motorist who has had an issue with the
       placement of the signage.
       Register kept under Regulation 20 of the Road Traffic (Parking
       Adjudicators) (London) Regulations 1993, as amended and
       Regulation 17 of the Civil Enforcement of Road Traffic
       Contraventions (Representations and Appeals) (England)
       Regulations 2022.
       Case Details
       Case reference  2240328826
       Appellant  Sharmini Christie
       Authority  London Borough of Lewisham
       VRM  LC20YKE
       PCN Details
       PCN  ZY09452368
       Contravention date  11 Jun 2024
       Contravention time  09:51:00
       Contravention location  Leahurst Road - Westbound
       Penalty amount  GBP 130.00
       Contravention  Fail comply prohibition on certain types vehicle
       Referral date
       Decision Date  03 Sep 2024
       Adjudicator  Andrew Harman
       Appeal decision  Appeal allowed
       Direction  - Cancel the Penalty Charge Notice.
       Reasons
       The appellant represented, by Mr Morgan, appeared before me
       today at Chancery Exchange.
       The council did not attend the hearing
       Two penalty charges formed the subject of this appeal it being
       alleged that this vehicle at Leahurst Road on the dates and at
       the times given failed to comply with a prohibition on certain
       types of vehicle.
       Mr Morgan said that he had uploaded a skeleton argument to the
       case a week ago.
       No such document was before me.
       He raised the issue of signage arguing that it was inadequate.
       The council's one regulatory sign was posted on the left of the
       carriageway as shown on its online footage of the incident and
       in its supporting images. I acknowledged that this sign on the
       council's case was preceded by advance warning signage but this
       single regulatory sign was in my judgment too inconspicuous to
       satisfy the test of sufficiency of signage and I accordingly
       found that these contraventions had not been proved.
       PCN  ZY09462485
       Contravention date  13 Jun 2024
       Contravention time  09:31:00
       Contravention location  Leahurst Road - Westbound
       Penalty amount  GBP 130.00
       Contravention  Fail comply prohibition on certain types vehicle
       Referral date
       Decision Date  03 Sep 2024
       Adjudicator  Andrew Harman
       Appeal decision  Appeal allowed
       Direction - Cancel the Penalty Charge Notice.
       Reasons
       The appellant represented, by Mr Morgan, appeared before me
       today at Chancery Exchange.
       The council did not attend the hearing
       Two penalty charges formed the subject of this appeal it being
       alleged that this vehicle at Leahurst Road on the dates and at
       the times given failed to comply with a prohibition on certain
       types of vehicle.
       Mr Morgan said that he had uploaded a skeleton argument to the
       case a week ago.
       No such document was before me.
       He raised the issue of signage arguing that it was inadequate.
       The council's one regulatory sign was posted on the left of the
       carriageway as shown on its online footage of the incident and
       in its supporting images. I acknowledged that this sign on the
       council's case was preceded by advance warning signage but this
       single regulatory sign was in my judgment too inconspicuous to
       satisfy the test of sufficiency of signage and I accordingly
       found that these contraventions had not been proved.
       The Penalty Charge Notice
       On the website that you have provided in order to view
       photographs and video footage of the alleged contravention, it
       should be noted that the follow notice is displayed on my case
       file “This PCN is now closed. Thank you. This PCN is past the
       stage at which you can challenge it or make representations”.
       The alleged contravention occurred on 7/9/24, the date of the
       PCN was 13/9/24 and the date at which I observed this notice on
       the website was 20/9/24. I still within the 14 day period and
       well within the 28 day period as stipulated by your own PCN.
       Therefore the information on this website is incorrect and
       highly misleading.
       In light of the above, I request a response to all of the points
       raised and I ask for the PCN to be cancelled.
       Reg. keeper
       Address
       [/quote]
       #Post#: 37634--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: EllHas
       Date: September 20, 2024, 11:25 am
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > [quote author=EllHas link=topic=3155.msg37614#msg37614
       date=1726835806]
       > [quote author=Hippocrates link=topic=3155.msg37312#msg37312
       date=1726657390]
       > Yes. And his colleague has 10. I await your draft. I am going
       to make a video about this location as it is becoming too
       infamous. Their hearings will be at the end of October after I
       have meditated under my Plane Tree.
       >
       --- End Quote ---
       Sorry for the delay with this. It's been a busy few days and I
       wanted the proper amount of time to put this together.
       Please find it below. Hopefully it's ok!
       ----
       Dear Lewisham Council
       I make these formal representations against PCN: ZY09702771
       Preamble:
       On Saturday 7th September I needed to drive my 1 year old son
       from my home in Mottingham to my father’s house in Catford.
       Normally I would either drive via Grove Park or go via the A205.
       However, on that day, a decision was made to close off the
       bridge at St Mildreds Road, result in horrendous traffic. And
       so, with a restless baby in the back seat, I did my best to
       navigate the blockages. What should have been a 10-minute
       journey, became an hour and a half nightmare.
       Regarding the journey in question, having finally made it past
       the worst of the traffic only to discover that the passing under
       the bridge was closed (there was no prior warning about this), I
       decided to try driving down Manor Lane, hoping that I could
       cross via Hither Green and then make my way back up. It has been
       many years since I have driven through that particular area as
       I’d had no need to. I was aware that there was a width
       restriction road somewhere along the route, but had no reason to
       believe that it would affect my car.
       I progressed onto Leahurst Road, approached the point of the
       alleged contravention and then turned left onto Ennersdale Road.
       At the top of Ennersdale Road I discovered that the road was
       closed off to all motor vehicles and there was no way to
       progress onto Hither Green, so I was forced to turn back and
       retrace my journey through the disgraceful traffic caused by
       road closures and lack of adequate signage.
       ...
       Address
       [/quote]
       [/quote]
       Thank you very much, I'll remove the bits you suggested. The
       rest of it is ok?
       #Post#: 37635--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: EllHas
       Date: September 20, 2024, 11:26 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Far too long IMO.
       >
       > I also think you need to be clear as regards what point you
       are trying to make because you offer different reasons -
       possibly due to its length you lose focus.
       >
       > You either saw the sign or you did not.
       >
       > I did see the sign:
       > But because this was not until after I'd entered the chicane I
       felt that I had no safe road user option other than to carry on.
       >
       > I did not see the sign at the time:
       > When I visited soon after receiving the PCN the reasons why I
       and, I now know, other motorists have missed the sign is because
       of *****. In my case **** but the attached tribunal cases(take
       them out of the body of your reps please) identify ****
       additional reasons.
       >
       > Would be my approach. But IMO you must choose and I suggest
       based upon what you and only you know happened and not to
       opportunistically try and adopt other motorists' arguments. Use
       these as further examples of reasons why the sign is poorly
       placed but write from your knowledge of events.
       >
       > Wait for other comments.
       >
       --- End Quote ---
       Thank you for your feedback. It's all pretty new to me, so I was
       mainly following what Hippocrates requested me to include. I
       think they've said that it's ok now that they've suggested some
       edits.
       #Post#: 37675--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: Hippocrates
       Date: September 20, 2024, 7:34 pm
       ---------------------------------------------------------
       The longer the better.
       #Post#: 37676--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: EllHas
       Date: September 20, 2024, 8:41 pm
       ---------------------------------------------------------
       Duly noted!
       #Post#: 37679--------------------------------------------------
       Re: PCN - Lewisham Council - Leahurst Road - Contravention 52 m
   DIR By: Hippocrates
       Date: September 21, 2024, 2:45 am
       ---------------------------------------------------------
       --- Quote from: EllHas link ---
       >
       > Duly noted!
       >
       --- End Quote ---
       They should be aware of these submissions as they lost a case
       due to them some months ago. It will also test whether
       AI/Barbour B****y Logic or a human being deals with them.
       *****************************************************
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