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       #Post#: 51769--------------------------------------------------
       PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: alphabetazebra
       Date: January 3, 2025, 11:11 am
       ---------------------------------------------------------
       Hello all,
       I recently received a PCN dated 18/12/2024 for a contravention
       that allegedly occurred on 8/12/2024. I would appreciate any
       advice or guidance you can offer on whether there is a basis to
       challenge this PCN, based on the circumstances I outline below.
       Summary:
       On 8/12/2024, my vehicle was captured on CCTV temporarily
       stopped in a bay marked with white dotted lines. My vehicle was
       fully within the marked bay while stopped. Beyond the bay are
       double red lines. There is a 'Red Route' sign-post on the
       pavement next to the bay (facing oncoming traffic), indicating
       certain restrictions. A photo I took of the signage is below.
       Google maps link to the location of the bay:
  HTML https://maps.app.goo.gl/4rvae6sCYw8szpZT7
       
       The PCN posted to me includes two photos: one of my vehicle
       (silver Mazda - KL05 KWD) in the bay at time 10:36:37; another
       of a different vehicle (dark grey - not mine) at 10:35:53.
       Although not appearing on the PCN posted to me, on the TfL
       website, there is a third photo showing: my vehicle (silver
       Mazda - KL05 KWD) in the bay at time 10:38:46.
       Current status:
       Since receiving the PCN the only action I have taken so far is:
       I called TfL by phone on 27/12/2024 to request the full evidence
       package. The PCN is shown on the TfL site as currently 'on hold:
       SUS20 - enquiry received'. I am still waiting to receive the
       evidence package.
       My layman's remarks:
       1. Has TfL alleged the correct offence? Offence 46 is described
       as 'stopped where prohibited (on a red route or clearway)'.
       However, my vehicle is in a white-dashed marked bay that 'breaks
       up' the double red lines that lie beyond it, so it is not clear
       to me whether a white bay that sits 'in between' two parts of a
       red route can constitute the offence of being stopped 'on a red
       route'. If this is a valid challenge, is there any specific
       wording I should employ in making it?
       2. I note some some similarity in my case to the previous case
       linked here:
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/pcn-(46-red-route)-tfl-opp-cobalt-sq-south-lambeth-road-sw8/msg40652/#msg40652<br
       />
       In that case, member H C Andersen observed that the signage
       "comprises only two panels and the lower, second, panel does not
       accord with regulatory requirements." Indeed, I can see that the
       signage is non-compliant in several respects (not least the
       absence of the "clearway" graphic in the top panel and the
       absence of "No Stopping" wording in the second panel), when
       compared to the requirements in:
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/6/made
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/18/made
       H C Andersen also observed "And even if it [was compliant], what
       does set down or pick up mean in the context of private vehicles
       on a Red Route and regulatory wording?". Indeed, there is no
       provision in the legislation for these terms from what I can
       see.
       And, again, more practically, the signage does not actually say
       or indicate "No Stopping" anywhere, and is situated alongside a
       bay that does not contain (double) red lines, so I unable to see
       how this signage can be construed as a 'stopping restriction' at
       all (irrespective of any conditions shown in the signage).
       In the photo I took after the event (imgur below), the signage
       still contains these defects. I assume this remains a valid (and
       strong) challenge, is there any specific wording I should employ
       in making it, or is it enough just to state both (1) its
       non-compliance with the legislative requirements above and (2)
       lack of clarity in relation to "set down ... pick up" and (3)
       lack of any indication of any restriction against stopping in
       the bay?
       3. I note the PCN posted to me does not appear to make out the
       offence, as there is only one photo in which my vehicle can be
       identified. Is this a basis of challenge, or (even if the
       signage could somehow be construed to by clear) is the alleged
       offence based on all the evidence held by TfL (i.e. the 'third
       photo' on the TfL website and the evidence package, once
       received).
       Imgur images below:
       - PCN (6 pages)
       - street view location of sign-post/bay and approx location of
       my vehicle
       - photo of sign-post (taken after event by me)
  HTML https://imgur.com/a/pcn-18-12-2024-xNMcp5b
       - all pages of PCN
  HTML https://i.imgur.com/iIAEHFd.jpeg
  HTML https://i.imgur.com/gthlDcQ.jpeg
  HTML https://i.imgur.com/HIc6oFa.jpeg
       Thank you all very much in advance!
       [member=1]cp8759[/member]
       #Post#: 51787--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: ivanleo
       Date: January 3, 2025, 1:07 pm
       ---------------------------------------------------------
       [member=3890]alphabetazebra[/member] at this stage there is no
       "evidence package", what you want is the CCTV footage. Once a
       request has been made an entry will appear on the TFL website
       saying "DTES footage request", that entry does not appear yet so
       I think you need to call again and ask for the CCTV to be sent
       to you.
       The allegation is correct, stopping is prohibited on the whole
       of the red route and the red route includes all red and white
       bays along its length, the bays indicate an exception to the
       no-stopping prohibition.
       How long did you stop for, and were you picking someone up or
       dropping someone off?
       #Post#: 51793--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: H C Andersen
       Date: January 3, 2025, 2:54 pm
       ---------------------------------------------------------
       IMO,
       If the bay indicates an 'exception' then it is obliged to
       display a sign in conformity with the TSRGD or a Secretary of
       State's Authorisation if it's to meet the authority's LATOR
       burden.
       As far as TSRGD is concerned, the sign is non-compliant.
       It does not refer to 'Except' neither does it use terms which
       are prescribed or permitted expressions of Time, Distance or
       Parking Restrictions.
       IMO, the starus of the bay is at best ambiguous.
       #Post#: 53175--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: alphabetazebra
       Date: January 13, 2025, 11:01 am
       ---------------------------------------------------------
       Many thanks for the replies.
       [member=1]cp8759[/member]
       --- Quote from: cp8759 link ---
       >
       > [member=3890]alphabetazebra[/member] at this stage there is no
       "evidence package", what you want is the CCTV footage. Once a
       request has been made an entry will appear on the TFL website
       saying "DTES footage request", that entry does not appear yet so
       I think you need to call again and ask for the CCTV to be sent
       to you.
       >
       --- End Quote ---
       Got it - in fact TfL had processed my original request for
       footage (but did not enter it on their system as "DTES" for some
       reason). In any event, I received the CCTV footage by post on 6
       January. I have uploaded it to a (public) Google Drive here
       (approx 4 mins duration):
  HTML https://drive.google.com/file/d/1kdhfwTo_-MBSmHW84gXQztgptMG2hea8/view?usp=drivesdk
       --- Quote from: cp8759 link ---
       >
       > How long did you stop for, and were you picking someone up or
       dropping someone off?
       >
       --- End Quote ---
       I would estimate I stopped for about 15-20 minutes. I was
       dropping off my 9-year-old son at Vauxhall station in time for a
       10:45am meet-up at the station. The CCTV captures my car at
       10:35am-10:39am, but I am pretty sure I would still have been in
       the car at this time, and would have exited the car at around
       10:40am to drop him off (i.e. I was waiting in the car until the
       appropriate time).
       [member=428]H C Andersen[/member]
       --- Quote from: H C Andersen link ---
       >
       > IMO,
       >
       > If the bay indicates an 'exception' then it is obliged to
       display a sign in conformity with the TSRGD or a Secretary of
       State's Authorisation if it's to meet the authority's LATOR
       burden.
       >
       > As far as TSRGD is concerned, the sign is non-compliant.
       >
       > It does not refer to 'Except' neither does it use terms which
       are prescribed or permitted expressions of Time, Distance or
       Parking Restrictions.
       >
       > IMO, the starus of the bay is at best ambiguous.
       >
       --- End Quote ---
       Thank you - understood.
       What would you suggest as next steps? Is this now a case of me
       drafting Representations to challenge on the grounds of
       "contravention did not occur" for you to review, if you would be
       so kind?
       Do you know what deadline I should now be working to? (I cannot
       tell from the "PCN details" shown on the TFL Challenge a PCN
       website for this specific PCN.)
       #Post#: 53186--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: H C Andersen
       Date: January 13, 2025, 11:46 am
       ---------------------------------------------------------
       Unless TfL have specified an extended deadline for reps then you
       must submit these no later than 16th Jan. As per the PCN, 'no
       later than the end of the period of 28 days beginning with the
       date of[ deemed] service' which was 20th Dec.
       I presume these can be made online - see the PCN for details.
       Penalty exceeded .....circumstances of the case
       As far as I can see, your reps are based on TfL not using a
       prescribed or authorised traffic sign to indicate the
       restriction which applied and for which they believe that a
       penalty is due, therefore rendering the demand unenforceable and
       in excess of that which these circumstances support.
       Specifically:
       I invite TfL to look at the traffic sign situated o/s SKVP Food
       which is immediately adjacent to the location of my alleged
       contravention. Quite properly this comprises 3 panels: Red
       Route; No Stopping at Any Time; Except Taxis. I then invite you
       to look at the traffic sign which purportedly regulates my
       location which comprises 2 panels: Red Route; 'P' 2 minutes,
       Pick up and set down only.
       This sign does not specify the hours of operation of the Red
       Route neither does it use the prescribed term 'except' nor does
       it comprise 3 panels. The only area of conformity with
       regulations is 'Red Route'.
       Unless the authority can produce an authorisation from the
       Secretary of State to use what is otherwise a manifestly
       non-compliant sign [as regards the Traffic Signs etc.
       Regulations] then the PCN must be cancelled.
       Wait for other views.
       #Post#: 53187--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: ivanleo
       Date: January 13, 2025, 11:46 am
       ---------------------------------------------------------
       [member=3890]alphabetazebra[/member] I would submit a one line
       representation saying that the alleged contravention did not
       occur. TFL will reject anything you say, so there's no point in
       saying anything else.
       Send the representation via
  HTML https://tfl.gov.uk/modes/driving/challenge-a-pcn
       and take a
       screenshot of the confirmation page.
       #Post#: 53440--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: alphabetazebra
       Date: January 15, 2025, 6:36 am
       ---------------------------------------------------------
       Thanks again.
       I have just submitted the challenge ("contravention did not
       occur" one-liner).
       Screenshot:
       [img width=1100
       height=459]
  HTML https://i.imgur.com/IlYJ17x.png?1[/img]
       I will revert when TFL respond.
       #Post#: 55717--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: alphabetazebra
       Date: January 29, 2025, 6:54 am
       ---------------------------------------------------------
       [member=1]cp8759[/member]
       As expected, I have now received from TFL a Notice of Rejection
       (27/1/2025). Google drive link:
  HTML https://drive.google.com/file/d/1dvMxTdgbObF_W3g_dJr4sRsbVvtyzBUD/view?usp=drivesdk<br
       />
       As I would like to pursue the matter further, I believe the next
       step is for me to complete the form to appeal to the Environment
       and Traffic Adjudicator. My proposal to to request a 'personal'
       hearing (in London/ Chancery Exchange EC4A). In the appeal form,
       presumably I should set out (in section 6) the details of why I
       believe the alleged contravention did not occur - principally
       that as far as TSRGD is concerned, the sign is non-compliant.
       Any instructions on drafting this would be appreciated (although
       I am equally happy to try my hand at it).
       All guidance gratefully received!
       Many thanks.
       #Post#: 55786--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: ivanleo
       Date: January 29, 2025, 3:43 pm
       ---------------------------------------------------------
       [member=3890]alphabetazebra[/member] well it seems the NoR is
       still flawed, I'll drop you a PM in case you'd like me to
       represent you.
       #Post#: 73338--------------------------------------------------
       Re: PCN (46 - Stopped on Red Route) - TFL: Opp. Cobalt SQ, South
       Lambeth Road SW8 [18/12/2024]
   DIR By: ivanleo
       Date: May 26, 2025, 4:47 pm
       ---------------------------------------------------------
       Outcome
  HTML https://drive.google.com/file/d/14pan-YneaxMeVNGvFg8Ml-q4fFAan6S3/view.
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