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       #Post#: 73079--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Appeal draft 
   DIR By: AnnePN
       Date: May 24, 2025, 9:22 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > I am the owner of the blue badge driving my daughters’ vehicle
       >
       > Pl explain.
       >
       > Only the person named on the NTO and Notice of Rejection may
       appeal in their own right. This is the registered keeper in this
       case.
       >
       --- End Quote ---
       My apologies, the appeal has been started again from my daughter
       as follows.
       Contravention did not occur;
       Contravention...
       In order for a council to meet its legal burden it must:
       Have made an order one of whose provisions requires the display
       of a 'parking disc' in a specified position, and
       Conveyed this requirement in the 'traffic sign' situated within
       or in the vicinity of the parking place.
       'Traffic signs' must by law be either:
       Of a form prescribed under regulations, or
       As authorised or directed by the Secretary of State.
       The traffic sign in question is of the prescribed form which
       does NOT include a requirement to display a clock.
       The parking place may be time limited by order, but the
       authority have to find smarter and LEGAL means to discover how
       long a vehicle has been parked and not crudely import the
       requirement which exists only on yellow lines.
       Procedural error.
       As regards Procedure error, Notice of Rejection  fails as
       follows:
       To advise me of my rights of appeal;
       To advise me correctly of the adjudicator's power to award
       costs;
       The vehicle was parked in a disabled bay and a valid Blue Badge
       placed on the dashboard together with a clock which is clearly
       displayed from the windscreen as shown in CEO's photographs.
       The holder of the blue badge was parked for less than 15 minutes
       from 9.12am to 9.22  They had an appointment at 9am at Boots
       opticians in the Hildreds Centre Skegness, the journey to the
       appointment was delayed because they called at an egg
       distribution centre to collect eggs for the local food bank on
       the way to Skegness and there was a problem there.  They arrived
       on Lumley Road Skegness at 9.12, parked in the disabled parking
       bay and displayed the blue badge and clock.  they were unable to
       see the optician and were given another appointment for Saturday
       8 March (photos of text confirmation of appointment's attached)
       They returned to the vehicle to see the CEO placing the PCN on
       the car, they couldn’t understand why they were getting the PCN
       the CEO pointed out that the time on the clock was 10 am and it
       was only 9.22. He had only observed the vehicle for  1 minute
       before he issued the PCN  the driver arrived as the CEO was
       placing the paperwork in the sticky envelope.  It would appear
       that they did not display the parking clock with the arrival
       time of 9.15am correctly as they were in a rush to attend the
       appointment they may have caught the clock and accidentally
       moved the time that was showing. However, according to the
       Disabled Person’s (Badges for Motor Vehicles) (England)
       Regulations 2000, using a clock is not a requirement when
       parking in a disabled bay.
       I am making representations against this PCN on the grounds that
       the penalty exceeds the amount applicable in the circumstances
       of the case. My detailed reasons are set out below, but before
       going into these I would add by way of background that the car
       was parked in the bay, displayed a blue badge and was stationary
       for less than 30 minutes. They displayed the parking clock out
       of habit rather than by virtue of any legal obligation.  The
       other parking bays on Lumley Road have free parking with a limit
       of 30 minutes or unlimited for Blue Badge holders.
       I understand that the County Council's traffic order requires a
       parking disc to be displayed in this bay in addition to a blue
       badge being displayed in the prescribed manner. However, the
       contravention grounds state that I was parked without displaying
       a disabled badge in the prescribed manner and do not refer to
       the parking disc despite this being the only issue between us.
       What the authority are attempting to do is to broaden the
       specified contravention grounds which refer only to a Blue Badge
       to include a parking disc.
       This is not lawful because the grounds include two terms defined
       in legislation, namely disabled badge holder and badge displayed
       in the prescribed manner, and amending these for the council's
       own purposes is not permitted. That the TRO requires a parking
       clock is not at issue, the council's problem is how they may
       enforce this within the limits set by legislation and the
       Secretary of State's Statutory Guidance, and using this
       contravention description is not an option.
       In addition, there is no requirement to display a parking clock
       stated on the traffic sign and this is because the sign used is
       of the form specified by Ministers in the Traffic Signs etc.
       Regulations and therefore compliant with the council's LATOR
       duties. However, for the same reasons as above it does not lie
       with the council to use this sign to convey a different  bespoke
       restriction i.e. that because you have placed a time limit on
       use of the bay this necessarily conveys an additional,
       non-prescribed, meaning namely that a parking clock must be
       displayed in the same manner as applies to yellow line waiting
       restrictions.
       I have included attachments to two cases of a similar nature
       namely Mr William Watson - v - St Helens Council and Miss
       Michelle Dhillon - v - Leicester City Council.
       There is also an Equality Act issue that the Council has a duty
       to consider. Regular limited waiting bays don't require the
       display of a parking disc clock. By making disabled people set
       and display a clock is treating them different to able bodied
       people who park in a regular limited waiting bay and it creates
       a situation where disabled people have a higher chance of making
       an error such as the clock falling off or being set incorrectly.
       Timings should be based on CEO observations the same as a
       regular limited waiting bay. There is no need to give the
       disabled the extra burden of setting and displaying a clock. I
       believe that the Council is unlawfully treating disabled people
       differently from able bodied people and I ask you to reconsider
       your approach to disabled badge holders only limited waiting
       parking places.
       Attachments
       Blue badge
       Boots text of initial appointment
       Boots text of rearranged appointment with date and time
       Mr William Watson - v - St Helens Council
       Miss Michelle Dhillon - v - Leicester City Council.
       #Post#: 73093--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: H C Andersen
       Date: May 24, 2025, 11:25 am
       ---------------------------------------------------------
       Is the Notice of Rejection addressed to your daughter?
       The draft is repetitive (because suggested input has been taken
       verbatim, even to the point of including what were intended only
       as editorial comments, for example - but the authority have to
       find smarter and LEGAL means to discover how long a vehicle has
       been parked and not crudely import the requirement which exists
       only on yellow lines) and needs to be consolidated.
       The Procedural Impropriety issues need to be fleshed out which
       isn't a problem.
       Let's call the draft rough and refine it, there's plenty of
       time.
       Get the appeal registered by the entitled person first.
       #Post#: 73097--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: AnnePN
       Date: May 24, 2025, 12:02 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Is the Notice of Rejection addressed to your daughter?
       >
       >
       > The draft is repetitive (because suggested input has been
       taken verbatim, even to the point of including what were
       intended only as editorial comments, for example - but the
       authority have to find smarter and LEGAL means to discover how
       long a vehicle has been parked and not crudely import the
       requirement which exists only on yellow lines) and needs to be
       consolidated.
       >
       > The Procedural Impropriety issues need to be fleshed out which
       isn't a problem.
       >
       > Let's call the draft rough and refine it, there's plenty of
       time.
       >
       > Get the appeal registered by the entitled person first.
       >
       --- End Quote ---
       Appeal lodged by my daughter
       Case number QJ00023-2505 Acknowledgement
       Explanation
       Contravention did not occur;
       In order for a council to meet its legal burden it must: Have
       made an order one of whose provisions requires the display of a
       'parking disc' in a specified position, and Conveyed this
       requirement in the 'traffic sign' situated within or in the
       vicinity of the parking place. 'Traffic signs' must by law be
       either: Of a form prescribed under regulations, or As authorised
       or directed by the Secretary of State. The traffic sign in
       question is of the prescribed form which does NOT include a
       requirement to display a clock. The parking place may be time
       limited by order, but the requirement to display a clock exists
       in law only when parked on yellow lines.
       As regards Procedure error, Notice of Rejection fails as
       follows:
       To advise me of my rights of appeal; To advise me correctly of
       the adjudicator's power to award costs;
       Read less
       #Post#: 73651--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: AnnePN
       Date: May 28, 2025, 12:57 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Is the Notice of Rejection addressed to your daughter?
       >
       >
       > The draft is repetitive (because suggested input has been
       taken verbatim, even to the point of including what were
       intended only as editorial comments, for example - but the
       authority have to find smarter and LEGAL means to discover how
       long a vehicle has been parked and not crudely import the
       requirement which exists only on yellow lines) and needs to be
       consolidated.
       >
       > The Procedural Impropriety issues need to be fleshed out which
       isn't a problem.
       >
       > Let's call the draft rough and refine it, there's plenty of
       time.
       >
       > Get the appeal registered by the entitled person first.
       >
       --- End Quote ---
       Your appeal to the Traffic Penalty Tribunal has now been
       registered and the Authority that issued the Penalty Charge
       Notice(s) has confirmed details of the case.
       
       What happens now?
       
       The Authority will decide whether or not to contest your appeal
       within 14 days.
       
       If the Authority decides not to contest your appeal, you will be
       notified that your appeal has been allowed and will have nothing
       to pay.
       
       If the Authority decides to contest your appeal, it will upload
       any evidence it has to support its case against you to your
       online case file.
       
       The Traffic Penalty Tribunal will then ask you to log-in to view
       and (if you choose) respond to the Authority’s evidence, before
       indicating whether:
       
       you would like your case to be passed straight to an independent
       Traffic Penalty Tribunal Adjudicator for a decision
       OR
       you would like a hearing with an Adjudicator to explain your
       case further, either by telephone or video. The Authority may
       also be present during this hearing.
       Please note: If you do not choose either of the above options
       when prompted, an Adjudicator will go ahead and decide the case
       without a hearing.
       
       How can I keep track of what is happening with my case?
       You can log-in at any point to view your online case file.
       
       Use the URL below to log-in to your case now:
       
  HTML https://foam.trafficpenaltytribunal.xxxxxxxxxxxxxxxxxxxxxxxxxx
       Please note: If the above text does not appear as a link, copy
       and paste it into your web browser to view it
       
       If you have any queries, please do not hesitate to contact our
       Customer Liaison team by message or Live Chat within your online
       case file, or by using the number below.
       Traffic Penalty Tribunal
       Freephone: 0800 160
       ==========================
       I have not uploaded any evidence only the following
       Grounds of Appeal:
       The alleged parking contravention did not occur.
       The authority made a procedural error.
       Explanation:
       Contravention did not occur;
       In order for a council to meet its legal burden it must:
       Have made an order one of whose provisions requires the display
       of a 'parking disc' in a specified position, and
       Conveyed this requirement in the 'traffic sign' situated within
       or in the vicinity of the parking place.
       'Traffic signs' must by law be either:
       Of a form prescribed under regulations, or
       As authorised or directed by the Secretary of State.
       The traffic sign in question is of the prescribed form which
       does NOT include a requirement to display a clock.
       The parking place may be time limited by order, but the
       requirement to display a clock exists in law only when parked on
       yellow lines.
       As regards Procedure error, Notice of Rejection fails as
       follows:
       To advise me of my rights of appeal;
       To advise me correctly of the adjudicator's power to award
       costs;
       So do I need to put some evidence together now for LCC to
       consider?
       Thanks for your help so far
       #Post#: 73690--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: Grant Urismo
       Date: May 28, 2025, 4:56 pm
       ---------------------------------------------------------
       See what others say, but I'd advise waiting for the council to
       upload their evidence as there's a good chance they will
       actually now read their own TRO, realise they will lose and
       decide not to contest.
       If they do decide to continue and upload evidence, it will
       include the TRO that they think applies and you'll be better
       placed to flesh out your case once you've seen that.
       #Post#: 75809--------------------------------------------------
       APPEAL + Authority evidence recwvied LCC PCN (40) Not displaying
       badge in a valid manner Lumley Road Skegne
   DIR By: AnnePN
       Date: June 10, 2025, 10:11 am
       ---------------------------------------------------------
       Next Steps
       View the evidence below
       You are able to add comments should you wish.
       Select your decision option
       If you do not select either option by 17/06/2025 your case will
       go to the adjudicator to decide.
       LCC has uploaded their evidence which in addition to the other
       items already seen has three additional items  their TRO
       location of vehicle and a TRO/Schedule
  HTML https://tro.trafficpenaltytribunal.gov.uk/TRO/Lincolnshire/QJ01.pdf
  HTML https://tro.trafficpenaltytribunal.gov.uk/TRO/Lincolnshire/QJ01.pdf
  HTML https://tpt-production-eu-west-2.s3-eu-west-2.amazonaws.com/production/uploads/attachment/source/d11e1bb3-2f7c-4608-a3c4-e61b216e9d48/SKEGNESS%20-%20TF565630.pdf?X-Amz-Expires=600&X-Amz-Date=20250610T144823Z&X-Amz-Algorithm=AWS4-HMAC-SHA256&X-Amz-Credential=AKIASYVCW657A65E72EO/20250610/eu-west-2/s3/aws4_request&X-Amz-SignedHeaders=host&X-Amz-Signature=de5d975b964754bcaf34015d261fe23e52550e24d091a9930c49d126c174cd70[/url
       [url=
  HTML https://imgur.com/a/vkFMaqe]https://imgur.com/a/vkFMaqe
  HTML https://tpt-production-eu-west-2.s3-eu-west-2.amazonaws.com/production/uploads/attachment/source/d11e1bb3-2f7c-4608-a3c4-e61b216e9d48/SKEGNESS%20-%20TF565630.pdf?X-Amz-Expires=600&X-Amz-Date=20250610T144823Z&X-Amz-Algorithm=AWS4-HMAC-SHA256&X-Amz-Credential=AKIASYVCW657A65E72EO/20250610/eu-west-2/s3/aws4_request&X-Amz-SignedHeaders=host&X-Amz-Signature=de5d975b964754bcaf34015d261fe23e52550e24d091a9930c49d126c174cd70
       I look forward to advice as to the way forward with this PCN
       please
       #Post#: 75876--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: H C Andersen
       Date: June 10, 2025, 1:24 pm
       ---------------------------------------------------------
       I refer the adjudicator to section 107 of the authority's
       Traffic Order, the effect of which is to draw attention to the
       regulatory burden placed upon the traffic authority by the Local
       Authorities’ Traffic Orders (Procedure) (England and Wales)
       Regulations 1996, as follows:
       Set out 107 (a) and (b).
       As I understand the authority's position, they assert that I
       contravened the Order provision in Section 6 regarding a
       requirement to display 'a parking disc on the vehicle in the
       relevant position'. I assert that the traffic sign displayed -
       see *** in the authority's evidence- conveys no such
       requirement, thus placing the council in contravention of its
       own Order. In this regard, I refer the adjudicator to the Sign
       Tables at Parts 4 and 5 of Schedule 4 to the Traffic Signs etc.
       Regs which, I submit, place no such requirement upon Disabled
       Badge holders to display a 'parking disc' when parked in a
       parking place.
       In short:
       I accept that parking in the bay was time-limited;
       I was not parked beyond the time allowed - indeed, this has not
       been alleged by the authority;
       The authority may enforce the provision in their Order but not
       by ascribing an unregulated meaning to a prescribed traffic
       sign, but by actual observation - which did not occur in this
       case.
       #Post#: 75947--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: AnnePN
       Date: June 11, 2025, 1:46 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > I refer the adjudicator to section 107 of the authority's
       Traffic Order, the effect of which is to draw attention to the
       regulatory burden placed upon the traffic authority by the Local
       Authorities’ Traffic Orders (Procedure) (England and Wales)
       Regulations 1996, as follows:
       >
       > Set out 107 (a) and (b).
       >
       > As I understand the authority's position, they assert that I
       contravened the Order provision in Section 6 regarding a
       requirement to display 'a parking disc on the vehicle in the
       relevant position'. I assert that the traffic sign displayed -
       see *** in the authority's evidence- conveys no such
       requirement, thus placing the council in contravention of its
       own Order. In this regard, I refer the adjudicator to the Sign
       Tables at Parts 4 and 5 of Schedule 4 to the Traffic Signs etc.
       Regs which, I submit, place no such requirement upon Disabled
       Badge holders to display a 'parking disc' when parked in a
       parking place.
       >
       > In short:
       > I accept that parking in the bay was time-limited;
       > I was not parked beyond the time allowed - indeed, this has
       not been alleged by the authority;
       > The authority may enforce the provision in their Order but not
       by ascribing an unregulated meaning to a prescribed traffic
       sign, but by actual observation - which did not occur in this
       case.
       >
       --- End Quote ---
       Thank you
       Sorry my links seem to have gone wrong here is a link to Imgur
       showing road sign plus maps included in LCC evidence
  HTML https://imgur.com/a/NH8D4sK
  HTML https://imgur.com/a/NH8D4sK
       Schedule 4 to the Traffic Signs please refer to t Parts 4 and 5
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/4
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/4
       #Post#: 75949--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: H C Andersen
       Date: June 11, 2025, 2:04 am
       ---------------------------------------------------------
       The adjudicator knows the Traffic Signs etc. Regs, the reference
       is there just for completeness. IMO, you don't need to cut and
       paste into your appeal nor provide a link, just refer.
       #Post#: 75953--------------------------------------------------
       Re: Lincolnshire County council PCN (40) Not displaying badge in
       a valid manner Lumley Road Skegne
   DIR By: AnnePN
       Date: June 11, 2025, 2:38 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > The adjudicator knows the Traffic Signs etc. Regs, the
       reference is there just for completeness. IMO, you don't need to
       cut and paste into your appeal nor provide a link, just refer.
       >
       --- End Quote ---
       Thank you for your help, shall I post my evidence now to
       expedite matters?
       *****************************************************
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