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       #Post#: 44328--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: stamfordman
       Date: November 7, 2024, 3:44 am
       ---------------------------------------------------------
       Issuing multiple PCNs like this is vindictive against a resident
       and they also had the remedy to impound where storage charges
       are cheaper than PCNs.
       Southwark will probably say they have no policy on issuing lower
       level code 19s but they are signed up to London Councils
       guidance like all in London.
       Some councils also give grace periods for permit expiry let
       alone the lower level penalty.
       I would say you could challenge all at formal stage on this
       basis but see what others say.
       One point - I presume this is an electronic/virtual permit -
       this should show up on the CEO's system.
       #Post#: 44332--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: McDon34
       Date: November 7, 2024, 4:08 am
       ---------------------------------------------------------
       Hello,
       Thank you.
       Yes it is a virtual permit.
       #Post#: 44354--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: JoCo
       Date: November 7, 2024, 5:55 am
       ---------------------------------------------------------
       --- Quote from: stamfordman link ---
       >
       >
       > Some councils also give grace periods for permit expiry let
       alone the lower level penalty.
       >
       >
       >
       --- End Quote ---
       FWIW Greenwich have a grace period of 1 week.  Not seen this
       written anywhere (policy etc), but I asked a CEO.
       Surprised Continuous contravention not been mentioned.
       See London Tribunals case 2110166557 which seems similar.
       The authority's case is that the Appellant's vehicle was parked
       in a residents' parking place or zone displaying an invalid
       permit when in Lausanne Road on 4, 5, 6, 7, 8, 11, 12, 13, 15,
       18, 19 and 21 January 2011 at 09.00.
       The Appellant's case is that the permit had not been renewed
       because they had not received a renewal notice from the
       authority. The Appellant and his wife were on holiday from 31
       December 2010 until 23 January 2011 during which period the
       Penalty Charge Notices were incurred.
       I have considered the evidence and I find that the Appellant's
       vehicle was parked in a residents parking place displaying an
       invalid permit when in Lausanne Road on 4 January 2011. It is
       the Appellant's responsibility to renew their permit and they
       are not entitled to rely on the courtesy renewal letter, which
       may not have been received.
       However, I find that the Appellant's vehicle committed one
       contravention of parking in a residents' permit bay without
       clearly displaying a valid permit when in Lausanne Road on 4, 5,
       6, 7, 8, 11, 12, 13, 15, 18, 19 and 21 January 2011.
       I find that one continuous contravention has occurred; the
       vehicle remains at the same location throughout the period these
       Penalty Charge Notices were issued. Further, I have taken into
       account that the residents' bay is operational from 8am to
       6.30pm Monday to Saturday and I find that the situation would be
       the same if the residents' bay was operational 24 hours a day 7
       days a week.
       There is no rule of law or regulation that entitles an authority
       to issue a penalty charge notice every 24 hours or as in some of
       these Penalty Charge Notices less than 24 hours. An enforcement
       authority has other powers at its disposal for a continuous
       contravention, such as removal.
       For the reasons given this appeal is allowed.
       
       
       #Post#: 44356--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: stamfordman
       Date: November 7, 2024, 6:07 am
       ---------------------------------------------------------
       That was the view some time ago by one adjudicator and strictly
       this isn't a continuous contravention as it would be on a double
       yellow line or on footway etc.
       I can't see any Southwark policy specific to permit expiry so if
       this were to go the tribunal of course continuous contravention
       would be added into the grounds as would code 19, failure to
       impound.
       #Post#: 44376--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: H C Andersen
       Date: November 7, 2024, 6:46 am
       ---------------------------------------------------------
       The PCNs issued on 2/11, 4/11, 10/11 have been cancelled. (these
       should be October as has been observed)
       Pl post at least one of these letters(if all the same) otherwise
       each one which has a different reason.
       They finally saw it on the day before I came back but I was
       already in the air at that stage so they weren't able to do
       anything about it.
       I read 'I' was in the air as 'it'(as in car) hence my confusion
       :)
       OP, you're waiting for the next notice, Notice to Owner, before
       you get a further opportunity to make reps, assuming you're the
       registered keeper with a current DVLA V5C address.
       #Post#: 44498--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: McDon34
       Date: November 8, 2024, 2:10 am
       ---------------------------------------------------------
       Hi,
       I have attached the letter for the cancelled ones. It was the
       same for each.
       Ah! Sorry! Yes, I was in an aeroplane when my flatmates
       discovered the fines.
       Yes, I need the notice to owner to arrive and I am the owner and
       the registration is current.
       Thank you.
       Holly
       [attachment deleted by admin]
       #Post#: 44502--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: stamfordman
       Date: November 8, 2024, 3:16 am
       ---------------------------------------------------------
       This document from Southwark includes the code 19 guidance in
       its notes on code 12:
       [i]If a previously valid permit has expired then code 19 should
       be issued.[/I]
  HTML https://moderngov.southwark.gov.uk/documents/s115707/Appendix%202%20-%20Parking%20contraventions.pdf
       #Post#: 44585--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: H C Andersen
       Date: November 8, 2024, 8:00 am
       ---------------------------------------------------------
       10 PCNs.
       4 cancelled, apparently for being issued within 24 hours of
       prior PCN.
       But there aren't 4 that I can see!
       1 Oct.... :8.46
       2 Oct      10.44
       3 Oct      8.44
       4 Oct      13.05
       7 ""      9.03
       8 ""      8.53
       9 ""      8.33
       10""      9.26
       11""      12.30
       14""      9.24
       I make it the 3rd and 10th only. You posted 2nd, 4th 10th?
       Anyway:
       For what remains, IMO:
       Penalty exceeded the amount applicable....circumstances of the
       case.
       Permit expired 30 Sept.
       All PCNs issued within a 14-day period of expiry i.e. no later
       that 14th Oct.
       Council's evidence shows that car was in same situation when
       each PCN was issued and you assert that it had been stationary
       since 30 Sept.
       There are 3 distinct circumstances which mean that all extant
       PCNs must be cancelled:
       1. Continuous contravention
       Only a single penalty could be demanded by virtue of the vehicle
       being continuously in contravention, this being PCN ***** issued
       on 1 Oct. All others are being demanded for a contravention
       which has already been penalised.
       2. Unlawful penalty charge
       All penalty charges are excessive. The authority's power to
       demand a penalty arises solely pursuant to London Councils
       published schedule authorised by the Mayor of London. However,
       this same schedule mandates the lower level penalty when 'Parked
       in a residents' or shared use parking place or zone with an
       invalid virtual permit or displaying an invalid physical permit
       or voucher or pay and display ticket, or after the expiry of
       paid for time' commonly referred to as 'code 19'.
       That the previous permit expired on 30 Sept. is a matter of
       record, therefore the authority's only defence against these
       grounds is that in their opinion and in each case the term
       'invalid permit' does not apply. Given that the use of code 19
       is mandated by the Mayor of London and prima facie applies to
       each PCN then it is the authority's burden to explain by
       reference to council policies why they have disregarded the
       mandated penalty level in these cases.
       3. Cumulative penalties are excessive and unlawful
       The Secretary of State's Statutory Guidance makes clear that in
       situations such as this case the authority should remove the
       vehicle and not issue PCNs ad infinitum. Whether the vehicle was
       in contravention or not is not the issue as regards these
       grounds(and I should be grateful if the authority's response
       would not labour this point), it is whether the authority acted
       fairly and lawfully in demanding penalties for each restricted
       day and not removing the vehicle at the earliest opportunity.
       Some thoughts, OP.
       #Post#: 44865--------------------------------------------------
       Re: Southwark residents permit expired
   DIR By: McDon34
       Date: November 10, 2024, 5:25 am
       ---------------------------------------------------------
       Hello,
       Sorry, there are so many of them I keep getting muddled. I will
       absolutely ensure I am not muddled when the time comes to
       submit.
       Thank you so much HC Andersen and stamfordman. That is much more
       cohesive and clear than I could have achieved by myself so thank
       you very much.
       I will await my notice to owner and construct my letter around
       that. If you don't mind I will post again at that point to make
       sure I have not misinterpreted anything.
       Thanks again!
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