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       #Post#: 49855--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: El-Roi
       Date: December 14, 2024, 7:16 pm
       ---------------------------------------------------------
       [member=428]H C Andersen[/member]
       [member=2249]stamfordman[/member]
       Below is the appeal that was sent
       Appeal against PCN MW912094257 Issued 24th November 2024 -
       Clover Street Chatham ME4 4DE
       I am challenging the PCN on the grounds that I was engaged in
       the exempt activity of unloading.
       On the day in question I was delivering bulky food items to the
       Emmaus Church Centre on Clover
       Street ME4 4DE Chatham and therefore there was no contravention.
       Specifically, I was delivering food which would be distributed
       to homeless people through a scheme administered and led by the
       church. I was acting in a personal capacity and it was my first
       delivery.
       I was taking a number of bulky food items for homeless people to
       the Emmaus Church Centre and needed to park by the entrance to
       do so. Some of the delivery was hot food and in consequence; I
       had to contact specific volunteers within the building so that
       this could be transferred to their own insulated containers.
       I needed to go to the centre and back to the car twice to unload
       all the food items.
       I assume this were on either side of the PCN being issued -
       there was a PCN on my vehicle when I finally returned to my
       vehicle after my last trip from the ECC  but was blown away in
       the extreme weather. In any event, this doesn't bear upon my
       circumstances or representations.
       Please note that this food delivery donation will be a
       semi-regular activity depending upon availability. I will be
       making future trips to delivery our personal food donation to
       The Emmaus Church Centre (TECC).
       See attached links confirming the good cause carried out by the
       ECC in which I was part of and making a delivery.
  HTML https://emmaus.org.uk/about-us/
       - Emmaus supports more than 850
       people who have experienced homelessness. We provide a home,
       training and work opportunities as part of a
  HTML https://www.helpingthehomeless.org.uk/medway
       I was delivering; a vehicle was essential; I parked as near to
       the church as possible and the activity took only as long as
       necessary in the circumstances to carry out this good cause; and
       trust you'll agree the exemption applies. Consequently, the
       exemption of delivering applies and the PCN should be cancelled.
       I look forward to the early cancellation of this PCN.
       Yours faithfully
       #Post#: 49857--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: Enceladus
       Date: December 14, 2024, 8:37 pm
       ---------------------------------------------------------
       "The entry signs in Clover Street clearly state that this is a
       'Restricted Zone at any Time' and 'No Loading' on Monday to
       Saturday 10:00am to 5pm. Non loading vehicles are not permitted
       to park in this area at anytime. As your vehicle was parked in
       Clover Street on 24/11/2024, your vehicle was correctly issued a
       Penalty Charge Notice."
       Am I reading the rejection notice correctly? Are the Council
       trying to claim that Loading is allowed outside the restricted
       hours but Unloading is never allowed?
       #Post#: 49859--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: John U.K.
       Date: December 15, 2024, 2:33 am
       ---------------------------------------------------------
       Not sure  they understand that 24/11/2024 was a Sunday?
       I don't often say you should carry on, but here I most
       definitely would continue .
       They keep talking about 'mitigation' and 'discretion' - as HCA
       said, you had a statutory exemption. Muppets  >:(
       See what others say.
       Next stage: NtO - your sister must authorise you to reply, or
       she replies in her name.
       #Post#: 49860--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: H C Andersen
       Date: December 15, 2024, 2:35 am
       ---------------------------------------------------------
       Although you have stated that you were taking a number of bulky
       food items for homeless people to the Emmaus Church Centre and
       needed to park by the entrance to do so as some of the delivery
       was hot food and in consequence; I had to contact specific
       volunteers within the building so that this could be transferred
       to their own insulated containers, I am unfortunately unable to
       accept this as mitigating circumstances because your vehicle was
       parked in a 'Restricted Zone At Any Time' area. Your vehicle was
       not exempt, therefore a Penalty Charge Notice was enforced by
       Medway Council.
       What an a**e. Disgraceful and brings the council into disrepute.
       Carry on and let your sister make reps against the NTO.
       Now that we know their, shall we say, ignorance of the law we
       can tailor the formal reps accordingly.
       The actual contravention as stated on the PCN:
       Parked in a restricted street during prescribed hours
       Which means in law that there weren't any active 'mo loading'
       restrictions at the time because if there were then the
       mandatory contravention grounds would be.
       02 - Parked or loading/unloading in a restricted street where
       waiting and loading/unloading restrictions are in force.
       And because delivering* is an exemption from a no waiting
       restriction (NOT mitigation but an exemption) then your argument
       must be considered.
       But it wasn't, it was regarded as mitigation and to make things
       worse for the council the wrong legal test was applied anyway!
       *- delivering, collecting, unloading, loading are synonymous
       expressions regarding this activity e.g. how could you load
       something that hasn't been collected and if you unloaded without
       delivering then the pavement would be knee-deep in goods!
       It is irrelevant for your purposes whether the 'no waiting'
       restriction was conveyed by yellow lines with a traffic sign,
       yellow lines in a controlled zone or even no yellow lines in a
       Restricted Parking zone, the restriction is the same: no
       waiting. And unloading/delivering is permitted and an exempt
       activity, not some wishy-washy mitigation.
       #Post#: 49880--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: stamfordman
       Date: December 15, 2024, 6:43 am
       ---------------------------------------------------------
       Medway 1 Homeless 0
       But it's only half-time and manager team talk says it's a game
       of two halves.
       #Post#: 50029--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: Enceladus
       Date: December 15, 2024, 7:31 pm
       ---------------------------------------------------------
       Next time you visit the Church, might it be possible to ask
       someone in the food for homeless team or the priest or pastor to
       write a note thanking you or at least acknowledging your
       donation of food at approx 16:19 on Sunday 24th Nov 2024?
       Including food that had to be decanted into the Church's food
       containers.
       Whilst it might not be strictly necessary for a formal challenge
       against the NTO, when it arrives, or a subsequent appeal to the
       Adjudicator such a note or receipt might make it a little
       easier.
       They just don't seem to accept or understand that because you
       were unloading, the food into the Church from your car, you were
       engaged in an activity which is permitted on a Sunday (or any
       other time outside the controlled hours on Mon to Sat). Possibly
       because you used a car and not a van.
       #Post#: 51068--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: El-Roi
       Date: December 26, 2024, 4:53 pm
       ---------------------------------------------------------
       --- Quote from: Enceladus link ---
       >
       > Next time you visit the Church, might it be possible to ask
       someone in the food for homeless team or the priest or pastor to
       write a note thanking you or at least acknowledging your
       donation of food at approx 16:19 on Sunday 24th Nov 2024?
       Including food that had to be decanted into the Church's food
       containers.
       >
       > Whilst it might not be strictly necessary for a formal
       challenge against the NTO, when it arrives, or a subsequent
       appeal to the Adjudicator such a note or receipt might make it a
       little easier.
       >
       > They just don't seem to accept or understand that because you
       were unloading, the food into the Church from your car, you were
       engaged in an activity which is permitted on a Sunday (or any
       other time outside the controlled hours on Mon to Sat). Possibly
       because you used a car and not a van.
       >
       --- End Quote ---
       "Non loading vehicles are not permitted to park in this area at
       anytime        She seems to be inferring that the type of
       vehicle might also be a contributing factor i.e. - A car as
       opposed to a van. They fail to take into consideration the sign
       that Sunday is exempt. It is like they cannot interpret / see
       the sign correctly. Or the week is Monday to Saturday and Sunday
       doesn't exist.
       2As per Medway Council’s Parking Enforcement Policy, in a Zero
       Tolerance area, no observation period is required however I can
       confirm that the Civil Enforcement Officer witnessed no activity
       around the vehicle therefore the ticket was issued correctly. If
       you are loading bulky items you will not stand by your car and
       it will magically get to where it is to be delivered.
       To be honest not sure if I will go there again because of this
       PCN and the rejection. this might turn out to be a very
       expensive donation. That was my first trip / donation. I don't
       know the people who are in charge that will be in a position to
       do a letter and they might be reluctant that I have only been
       there once and asking them a favour to write a letter is
       embarrassing. Also they might not want to put anything down on
       paper. I don't know what their policy is.
       It means anytime I go there to deliver food I am going to get a
       PCN and the council will not understand if it is outside the
       restriction hours or not or whether it is Sunday. I don't have
       that type of money in addition to the time and money spent
       making the donation. It's really sad.
       What are my chance of success without a letter /note from the
       centre?
       I just need to know as the 14 days discount period is up
       tomorrow before midnight or the day after.
       #Post#: 51070--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: fraser.mitchell
       Date: December 26, 2024, 5:35 pm
       ---------------------------------------------------------
       Reading this thread it is clear that your case for cancellation
       of the PCN is very strong.
       You need to be aware that councils ruthlessly game the system to
       maximise the cash flow. One of the ways they do this is to
       refuse virtually all informal reps, knowing that if they do
       this, over 95% of people then cough-up the money.
       Representations against Notices to Owner, the next stage, are
       looked at a bit more closely because at this stage the discount
       option has gone, and they know that if they refuse these, the
       appellant will take them to adjudication, because the penalty
       remains the same and there are no additional costs. Many
       councils even re-offer the discount at the NtO stage, but never
       publish this. A council has costs for an adjudication, being the
       fee, and also the task of preparing an evidence pack for the
       adjudication. The appellant has no fee to pay, just the PCN
       penalty if the case is lost.
       Of course it is the vehicle owner as per the V5 Registration
       Certificate for the car that has responsibility for paying or
       appealing a PCN, so whether to proceed further now is their
       decision.
       #Post#: 51094--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: Enceladus
       Date: December 27, 2024, 9:55 am
       ---------------------------------------------------------
       --- Quote from: El-Roi link ---
       >
       > '''''''''''''''''''''
       > "Non loading vehicles are not permitted to park in this area
       at anytime        She seems to be inferring that the type of
       vehicle might also be a contributing factor i.e. - A car as
       opposed to a van. They fail to take into consideration the sign
       that Sunday is exempt. It is like they cannot interpret / see
       the sign correctly. Or the week is Monday to Saturday and Sunday
       doesn't exist.
       > 2As per Medway Council’s Parking Enforcement Policy, in a Zero
       Tolerance area, no observation period is required however I can
       confirm that the Civil Enforcement Officer witnessed no activity
       around the vehicle therefore the ticket was issued correctly. If
       you are loading bulky items you will not stand by your car and
       it will magically get to where it is to be delivered.
       >
       > To be honest not sure if I will go there again because of this
       PCN and the rejection. this might turn out to be a very
       expensive donation. That was my first trip / donation. I don't
       know the people who are in charge that will be in a position to
       do a letter and they might be reluctant that I have only been
       there once and asking them a favour to write a letter is
       embarrassing. Also they might not want to put anything down on
       paper. I don't know what their policy is.
       >
       > It means anytime I go there to deliver food I am going to get
       a PCN and the council will not understand if it is outside the
       restriction hours or not or whether it is Sunday. I don't have
       that type of money in addition to the time and money spent
       making the donation. It's really sad.
       >
       >
       > What are my chance of success without a letter /note from the
       centre?
       >
       > I just need to know as the 14 days discount period is up
       tomorrow before midnight or the day after.
       >
       --- End Quote ---
       "Non loading vehicles are not permitted to park in this area at
       anytime". That's the prohibition conveyed by the Double Yellow
       Lines painted on the carriageway. The DYLs apply 24x365.
       However stopping solely to load or unload is permitted outside
       of the restricted hours of Monday to Saturday 10:00am to 5pm and
       permitted all day on Sunday as stated on the time-plate on the
       sign. The 'No Loading' restriction is only part time.
       I agree, the Notice of Rejection does read as if only purpose
       built vans are allowed to load/unload. Or they are just ignoring
       the fact it was a Sunday.
       You were stopped to unload a food delivery on a Sunday, a
       delivery that had additionally to be decanted into the thermos
       containers used by the church's kitchen, so provided that's all
       you were doing then it was permitted.
       So I would fight this all the way as it is plainly unjust and
       justice should prevail.
       It's not entirely necessary to get something in writing from the
       church. However doing so might strengthen your hand and make
       things easier with the Adjudicator. The Adjudicator will make a
       judgement based on the balance of probability. You being a
       credible witness should be enough.
       If you prevail with the Adjudicator then you will have to pay
       zero. If the Adjudicator doesn't buy your story then the bill
       will be £70. BTW I don't agree with the double or quits, my
       opinion is that the penalty should be consistent and national,
       but such is what Parliament decided.
       #Post#: 51204--------------------------------------------------
       Re: CODE 01 Medway Clover Street Chatham Delivering food for the
       Homeless
   DIR By: stamfordman
       Date: December 28, 2024, 11:12 am
       ---------------------------------------------------------
       I would certainly go on with this. The exemption is there for
       this kind of situation. And they wouldn't want a story about a
       heartless authority penalising a person delivering food to the
       homeless to appear in the local paper...
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