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       #Post#: 69941--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Hippocrates
       Date: May 4, 2025, 6:56 am
       ---------------------------------------------------------
       It is a comparable point with their rather dated images which
       are always taken in daylight. What were the dates of their
       pictures in your case? They may well rectify this issue.
       #Post#: 69949--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Bustagate
       Date: May 4, 2025, 8:45 am
       ---------------------------------------------------------
       Here's an updated version of Reply #17.
       2. Traffic Orders on Camrose Avenue
       2.1 Introduction
       Attached is an annotated aerial view of the site,
       CamroseAerialRinged.jpg. It will help if you have this open in
       another window as you read this section.
       There are two traffic orders in force on Camrose Avenue:
       - The Harrow (Prescribed Route) (Width Restriction) Traffic
       Order 2007 as amended
       - The Harrow (Bus Priority) Traffic Order 2016 as amended
       Copies of these TMOs are attached. I show that the
       width-restriction TMO applies not only to the width-restricted
       areas of road but also to the areas of road in each direction
       between the traffic island and the nearside kerb (the
       “Prohibited lengths”). The width-restriction TMO applies its own
       restrictions to these areas of road and, through clever
       drafting, also allows vehicles to use these areas of road if
       they are permitted to do so by any other TMO.
       I then examine the history of the TMOs on Camrose Avenue,
       starting with the 1976 one. I show what happened in 1999 when
       Harrow consolidated its moving-vehicle TMOs into:
       - The Harrow (Prescribed Route) (Width Restriction) Traffic
       Order 1999
       - The Harrow (Bus Priority) Traffic Order 1999
       I show that the provisions of the 1976 TMO were translated
       correctly to the width-restriction TMO but not to the
       bus-priority TMO. It applied the bus-priority restrictions to
       the areas of road which were subject to the width restrictions.
       The provisions in each TMO for Camrose Avenue have been repeated
       each time a TMO has been repealed and replaced, so the mistake
       made in 1999 remains today.
       The consequence is that the areas of road in each direction
       between the traffic island and the nearside kerb are subject
       only to the restrictions specified in the width-restriction TMO
       as applying to the “Prohibited lengths”. These exclude all
       vehicles except the emergency services and vehicles on Harrow
       Council business.
       It follows that the contravention which the Council has alleged
       did not occur.
       2.2 The Harrow (Prescribed Route) (Width Restriction) Traffic
       Order 2007
       The Harrow (Prescribed Route) (Width Restriction) Traffic Order
       2007 specifies all the width restrictions on roads in Harrow. At
       most sites there aren’t also bus restrictions, so the
       width-restriction TMO defines what happens to the parts of the
       carriageway which aren’t subject to a width restriction. These
       are defined as "Prohibited lengths". For most width
       restrictions, all vehicles are banned from them (hence
       “Prohibited lengths”).
       A uniform structure has been used for the width restriction TMO,
       so, although Camrose Avenue's bus restrictions are specified in
       the bus-priority TMOs, the width-restriction TMO also defines
       "Prohibited lengths" on Camrose Avenue. These are the sections
       of carriageway in each direction between the traffic island and
       the nearside kerb.
       The "Prohibited lengths" are subject to these rules:
       --- Quote ---
       >
       > 2. No person shall cause any vehicle to proceed in a
       [Prohibited length] of carriageway
       > . . .
       > 4. Nothing in Articles 2 and 3 of this Order shall apply to :-
       > (a) any vehicle being used for ambulance, fire brigade or
       police purposes;
       > (b) anything done with the permission or at the direction of a
       police constable in uniform;
       > (c) any person who causes any vehicle to proceed in accordance
       with any restriction or requirement indicated by traffic signs
       placed pursuant to section 66 or section 67 of the Road Traffic
       Regulation Act 1984;
       > (d) any vehicle specified in column 6 of the Schedule to this
       Order;
       > (e) to any vehicle being lawfully used in connection with the
       maintenance of public services maintained by the London Borough
       of Harrow. [LBH 2012/30]
       --- End Quote ---
       Note in particular 4(c): this clause allows the
       width-restriction TMO to coexist with the bus-priority TMO.
       Section 66 of the Road Traffic Regulation Act 1984 allows
       highway authorities to place signs which show the effect of
       TMOs. So if a sign (such as a blue roundel) has been placed on a
       "Prohibited length" which allows certain classes of vehicle to
       pass, the width-restriction TMO also allows them to pass.
       Clause 4(e) means that vehicles being used to provide Harrow
       Council services can use the “Prohibited lengths”. Where a
       bus-priority TMO overlaps with the width-restriction TMO,
       vehicles providing Council services are added to those permitted
       by the bus-priority TMO.
       2.3 Original TMO for Camrose Avenue
       The restrictions on Camrose Avenue were set out coherently in
       The Harrow (Prescribed Routes) (No. 2) Traffic Order 1976 (the
       italics have been added, as they are in all the quotes in
       section 2):
       --- Quote ---
       >
       > 3. No person shall cause any vehicle to proceed in the
       carriageway on the south-eastern side of the north-easternmost
       island site or in the carriageway on the north-west side of the
       south-westernmost island site.
       >
       > 4. No person shall cause any vehicle the overall width of
       which together with the load (if any) carried thereon exceeds 6
       feet 6 inches to enter the carriageway on the north-west side of
       the north-easternmost island site or the carriageway on the
       south-east side of the south-westernmost island site.
       >
       > 5. Nothing in Article 3 of this order shall apply
       > (a) in relation to a stage carriage or an express carriage on
       a scheduled service; or
       > (b) in relation to a vehicle being used for police, fire
       brigade or ambulance purposes; or
       > (c) to anything done with the permission or at the direction
       of a police constable in uniform.
       --- End Quote ---
       This refers to two island sites: north-easternmost and
       south-westernmost. As a glance at the aerial view of the site
       shows, these are accurate geographic descriptions of the traffic
       islands. I have ringed them in yellow and red respectively. They
       divide the flow of westbound and eastbound traffic respectively.
       For brevity, I shall refer to them as the westbound island and
       the eastbound island.
       This traffic order defines the restricted parts of the
       carriageway as:
       3. bus-restriction:
       [indent]south-eastern side of the westbound island [/indent]
       [indent]north-west side of the eastbound island [/indent]
       4. width-restriction:
       [indent]north-west side of the westbound island [/indent]
       [indent]south-east side of the eastbound island[/indent]
       It does not specify the direction of travel through any of the
       restrictions, nor does it mention the snake-like kerbed
       structure which separates eastbound from westbound traffic. It
       is a model of accuracy and concision.
       2.4 Consolidation of TMOs
       In 1999 Harrow consolidated traffic orders relating to width
       restrictions, bus lanes and other bus restrictions into two
       orders:
       - The Harrow (Prescribed Route) (Width Restriction) Traffic
       Order 1999
       - The Harrow (Bus Priority) Traffic Order 1999
       Since 1999 there have been various amendments to each of these
       TMOs, with periodic repeals and replacements. These have not
       affected the definitions of the restricted areas of carriageway
       but they have changed the classes of vehicle permitted through
       the bus restrictions.
       2.5 Consolidated Width-restriction TMO 1999
       For the width restrictions, the consolidated width-restriction
       TMO followed the 1976 TMO in referring to "the north-eastern
       island" and "the south-western island". For the "Prohibited
       lengths", it instead used the cardinal points of the compass
       (eastern and western). It got these right, so "north-eastern"
       became "eastern" and "south-western" became "western".
       The TMO defined both sets of restrictions as being between an
       island and some other structure. For the width restrictions this
       was "the central median strip". For the bus priorities this was
       the northern or southern kerb-line.
       Whereas the 1976 TMO had not specified the direction of travel,
       the consolidated width-restriction TMO did.  Depending on your
       point of view, this either provided an aid to interpretation or
       created an opportunity for mistakes through overspecification.
       None was made.
       2.6 Consolidated Bus-priority TMO 1999
       There were two schedules to the consolidated bus-priority TMO:
       - Schedule 1: Bus Lanes
       - Schedule 2: Bus-only routes
       Camrose Avenue was Item 1 in Schedule 2.
       The definitions of the areas of road were:
       --- Quote ---
       >
       > Westbound: the carriageway to the south of the southern
       traffic island immediately to the west of its junction with Dale
       Avenue;
       > Eastbound: the carriageway to the north of the northern
       traffic island immediately to the west of its junction with Dale
       Avenue.
       --- End Quote ---
       When the width-restriction TMO shifted from ordinal to cardinal
       compass points, it did so correctly:
       - Westbound: north-eastern  ---> eastern
       - Eastbound: south-western  ---> western
       The bus-priority TMO chose the other cardinal points and got it
       wrong:
       - Westbound: north-eastern  --/-> southern
       - Eastbound: south-western  --/-> northern
       The descriptions of the areas of road ("south of the xxx traffic
       island"; "north of the yyy traffic island") would be correct if
       xxx had been northern and yyy had been southern. But they were
       not. The traffic islands were reversed, so the areas specified
       were those which are subject to the width restrictions.
       2.7 Lack of Rigorous Checking in the Bus-priority TMO
       The width-restriction TMO shows evidence of a high standard of
       work. Although it's odd that it uses ordinal points of the
       compass for the width restrictions and cardinal points for the
       "Prohibited lengths", the shifts are correct and everything
       works. Also notable is the way that the TMO was structured so
       that vehicles could use its “Prohibited lengths” if they are
       permitted to do so by a sign placed in accordance with another
       TMO.
       Leaving aside its provisions for Camrose Avenue, Schedule 2 of
       the bus-priority TMO shows other signs of a lack of rigorous
       checking. In its 2007 incarnation, it defines the following area
       of road on Headstone Lane (the indenting has been added to aid
       comprehension:)
       --- Quote ---
       >
       > the carriageway which lies between
       > [indent]the island site situated  between
       > [indent]a point 6.00 metres north-east of the extended
       north-eastern kerb-line of Melbourne Avenue and
       > a point 9.00 metres north-east of that
       point.[/indent][/indent]
       --- End Quote ---
       While the second “between” is followed by two objects separated
       by an “and”, the first is followed by a single object. It makes
       no sense.
       In 2021 the TMO was amended to change the definition of the
       bus-priority area of Christchurch Avenue. It became (with added
       indentation)
       --- Quote ---
       >
       > Christchurch Avenue
       > [indent]from its junction with Masons Avenue
       > [indent]and a point opposite
       > [indent]the north-eastern most point of
       > [indent]the island site between
       > [indent]No. 13 Byron Road and
       > No. 139A Masons
       Avenue;[/indent][/indent][/indent][/indent][/indent]
       --- End Quote ---
       There is an island site between No. 13 Byron Road and No. 139A
       Masons Avenue and it does have a north-easternmost point, so
       this definition amounts to
       --- Quote ---
       >
       > Christchurch Avenue
       > [indent]from its junction with Masons Avenue
       > [indent]and a point opposite
       > [indent][a well-defined point on an island
       site][/indent][/indent][/indent]
       --- End Quote ---
       This evidence suggests that not only can mistakes be made and
       persist in the bus-priority TMO, new ones can be added.
       2.8 Harrow's Explanation
       The definition of the bus-priority areas came up in the hearing
       of appeal 2250053451 on 28 April 2025. Mr Adekusibe of Harrow
       sought to explain the definitions by saying that "southern
       traffic island" and "northern traffic island" needed to be
       understood by reference to their appearance to motorists
       approaching them in the specified direction. Thus to westbound
       motorists, the "southern traffic island" was the traffic island
       nearest to the westbound nearside kerb, while to eastbound
       motorists the "northern traffic island" was the traffic island
       nearest to the eastbound nearside kerb.
       There are some obvious problems with this:
       - it is based on the perception when approaching the
       restrictions that there are two traffic islands ahead.
       Certainly, there are two kerbed structures with bollards and
       signs on posts. But if there really were two traffic islands in
       each direction, there would be four traffic islands in total.
       There are not. There are three kerbed structures: two traffic
       islands and the snake-like structure which is formally known
       (and referred to as such in the width-restriction TMO) as the
       central median strip.
       - the other uses of compass points in the bus-priority TMO make
       sense with their normal meaning
       - the uses of compass points in the width-restriction TMO
       written at the same time (1999) make sense with their normal
       meaning
       - TMOs are formal legal documents written using a formal
       register. They define things precisely and use the correct legal
       terms. This is shown in the use by the contemporaneous
       width-restriction TMO of the term "central median strip". If the
       words “northern“ and “southern” were being used with meanings
       other than the natural ones, this would be stated explicitly.
       It seems possible that officers in Harrow, puzzled by the
       definitions of the areas of Camrose Avenue defined as
       bus-priority, have constructed the interpretation advanced by Mr
       Adekusibe to reassure themselves that the TMO is valid. Those
       definitions have been used for so long (since 1999) and nobody
       has ever challenged them successfully, so they must be right.
       The evidence suggests otherwise. The law works from the TMO
       forwards to the signage, not back from the signage to the TMO.
       2.9 Consequences
       The areas of Camrose Avenue on which the bus-priority TMO
       imposes restrictions are those which are subject to the width
       restriction. As the PCN alleges that the contravention was using
       a route restricted to buses, cycles and taxis only, which is the
       set of vehicles permitted by the bus-priority TMO, it follows
       that there was no contravention.
       If it is held that the bus-priority TMO does apply between the
       traffic islands and the nearside kerbs, the allegation is still
       not correct because the TMO is overlain by the width-restriction
       TMO. This adds to the permitted vehicles:
       --- Quote ---
       >
       > any vehicle being lawfully used in connection with the
       maintenance of public services maintained by the London Borough
       of Harrow
       --- End Quote ---
       Taxis were added to the bus-priority TMO by The Harrow (Bus
       Priority) (Amendment No. 2) Traffic Order 2018. Suppose that,
       instead of amending the order, this had been written as a
       separate TMO permitting taxis to use the same area of road. Then
       it would be oppressive to issue PCNs against taxis for violating
       the bus-priority TMO while ignoring the taxi-permitting TMO.
       That is why the change was made as an amendment. Normal practice
       is to have a single TMO which sets out all the classes of
       vehicle which are permitted.
       But on Camrose Avenue there are two overlapping TMOs. They are
       nested, with the bus-priority TMO being tighter than the
       width-restricted TMO. Each is subject to Regulation 18 of LATOR
       1996
  HTML https://www.legislation.gov.uk/uksi/1996/2489/regulation/18,<br
       />which requires the placing of signage to indicate the effect
       of
       the order. The bus-priority TMO requires the blue roundel to
       diagram 953 as it is displayed. The width-restriction TMO
       requires that sign with the plate "and authorised vehicles". It
       is that combination of signs which should be displayed as it
       shows the combined effect of the TMOs.
       It follows that if the bus-priority TMO applies between the
       traffic islands and the nearside kerbs, the sign which is
       displayed is wrong and that the contravention which should have
       been alleged was using a route restricted to buses, cycles,
       taxis and authorised vehicles. It was not.
       [attachment deleted by admin]
       #Post#: 69952--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Bustagate
       Date: May 4, 2025, 9:39 am
       ---------------------------------------------------------
       A comment on tactics: the arguments which I am putting forward
       are long and complex. It isn't fair to spring them on people. I
       suggest that they are best deployed as representations, i.e.
       when responding to Harrow after receiving the PCN:
       --- Quote ---
       >
       > I contend that no contravention took place for the reasons set
       out in the attached document. I reserve the right to add further
       reasons.
       --- End Quote ---
       I shan't be surprised if Harrow continue with their standard
       procedure, which is to reject the representations. If they do
       so, you then submit the appeal, saying that Harrow have rejected
       your detailed representations without explanation and that in
       addition to the grounds in your representations, you are adding
       that they failed properly to consider your representations,
       contrary to sub-paragraph (7)(a) of paragraph 1 of Schedule 1 of
       the London Local Authorities and Transport for London Act 2003
  HTML https://www.legislation.gov.uk/ukla/2003/3/schedule/1/paragraph/1/enacted.<br
       />
       If you have any other grounds for appeal, add them to the
       representations and the appeal. This approach ensures that
       Harrow have had full opportunity to respond to the arguments
       before any hearing and that an Adjudicator doesn't need to
       adjourn the hearing to ask Harrow for a detailed response.
       I recognise that this advice is the opposite of that normally
       advanced, which is not to reveal your hand until the other side
       has shown his. Quite apart from matters of fairness, it is
       prompted by London Tribunals' Practice Direction 2024 No. 2
  HTML https://www.londontribunals.gov.uk/sites/default/files/Practice%20Direction%2002-2024%20on%20behalf%20of%20ETA%2029%20July%202024.pdf,<br
       />which limits the material which can be added at the appeal
       stage.
       #Post#: 69962--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: ivanleo
       Date: May 4, 2025, 10:28 am
       ---------------------------------------------------------
       --- Quote from: Bustagate link ---
       >
       > I recognise that this advice is the opposite of that normally
       advanced, which is not to reveal your hand until the other side
       has shown his. Quite apart from matters of fairness, it is
       prompted by London Tribunals' Practice Direction 2024 No. 2
  HTML https://www.londontribunals.gov.uk/sites/default/files/Practice%20Direction%2002-2024%20on%20behalf%20of%20ETA%2029%20July%202024.pdf,<br
       />which limits the material which can be added at the appeal
       stage.
       >
       --- End Quote ---
       It doesn't, in the notice of appeal you can add whatever you
       want. It purports to limit what can be added after the notice of
       appeal stage, but most adjudicators ignore it anyway.
       #Post#: 69968--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: H C Andersen
       Date: May 4, 2025, 10:44 am
       ---------------------------------------------------------
       Adjudicators don't like ambushes!
       Having said this, apart from anything else what an owner puts in
       their reps is circumscribed by the legislation under which a
       penalty is being demanded e.g. a postal PCN gives little time
       and opportunity to discover anything but superficial facts and
       an owner won't see the traffic order until it's been submitted
       to the adjudicator etc.
       As regards the OP's appeal in this case - An alternative view:
       As cp has commented, there is nothing in the decision which
       supports the OP's contention regarding what is referred to as
       the 'signage issue'.
       IMO, the OP has obfuscated the key legal point - despite this
       being made clear in the Beatson judgment - namely that the legal
       duty of the council is set out in s18 of LATOR which bears being
       quoted:
       Traffic signs
       18.—(1) Where an order relating to any road has been made, the
       order making authority shall take such steps as are necessary to
       secure—
       (a)before the order comes into force, the placing on or near the
       road of such traffic signs in such positions as the order making
       authority may consider requisite for securing that adequate
       information as to the effect of the order is made available to
       persons using the road;
       (b)the maintenance of such signs for so long as the order
       remains in force;
       - my emphasis.
       And what is considered adequate is not prescribed under TSRGD or
       TSM or DfT guidance but turns on the facts in each case.
       IMO, what is clear from the Beatson judgment (and not just this
       judgment) is that:
       1. placing of TSRGD-compliant signs does not of itself ensure
       that adequate information as to the effect etc.. is conveyed.
       In addition, IMO the judgment (and the OP) raises questions
       about whether the wording of LATOR means that the placing of
       signs which are not prescribed or authorised in the form and
       manner in which they're being used can form part of considering
       whether the duty has been discharged and also whether the use of
       prescribed but non-regulatory signs may be taken into
       consideration. In this respect, IMO the OP has been misled as
       regards the distinction between prescribed regulatory and
       non-regulatory signs(their reference to the 'deflection arrows'
       being a case in point because these are prescribed under
       Schedule 11, albeit not regulatory).It appears to me from
       numerous adjudication decisions that non-regulatory 'traffic
       signs' may be taken into account in determining LATOR
       compliance.
       IMO, the OP's submissions were overly long and unnecessarily
       convoluted given that the simple and essential questions had not
       been made clear at the beginning. I would not advocate their use
       en bloc by others.
       Do the following scope the issues?
       What 'traffic signs' were in place? (under which heading the
       issues of TSRGD compliance in all its forms e.g. type, size,
       illumination etc. could fall), and,
       Were these adequate and therefore did the council meet their
       LATOR duty?
       #Post#: 69969--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Bustagate
       Date: May 4, 2025, 10:56 am
       ---------------------------------------------------------
       Re: Reply #23
       But what exactly is a Notice of Appeal? How much material can be
       included and when does it become "additional representations"? I
       consider it better to play safe and put complex boilerplate in
       the representations.
       What is there to lose? I suppose there's a chance that Harrow
       might accept the representations, so the matter won't get to an
       adjudicator, but the recipient of the PCN won't have to pay
       anything and will have no further hoops to jump through.
       #Post#: 69970--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: ivanleo
       Date: May 4, 2025, 11:04 am
       ---------------------------------------------------------
       --- Quote from: Bustagate link ---
       >
       > Re: Reply #23
       >
       > But what exactly is a Notice of Appeal?
       >
       --- End Quote ---
       It's the box on the tribunal website where it asks you to
       explain why you are appealing. Alternatively you can just make a
       document called "Notice of Appeal" and upload it to the tribunal
       website.
       Of course if you can get the council to cancel at the
       representations stage that is always best, the problem we have
       found in the past is that they don't bother reading anything
       that's more than half a page. Frankly in many cases they just
       look at their own evidence and don't bother considering anything
       you've said, because they take the view that if they've
       determined that a contravention occurred, that's all that
       matters.
       #Post#: 69974--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Bustagate
       Date: May 4, 2025, 12:09 pm
       ---------------------------------------------------------
       Re: Reply #24
       1. As has been noted, the decision in the appeal did not refer
       to the signage issue. That doesn't mean that it wasn't raised or
       that Beatson's judgment didn't figure prominently. It means that
       the adjudicator allowed the appeal and selected as the reason
       for allowing it one which was specific to the case and which
       could not help other appeals.
       2. While Regulation 18 of LATOR places a duty on a highway
       authority, that duty cannot be enforced through an appeal
       against a PCN. There is another duty which s.122 of Road Traffic
       Regulation Act 1984 places on highway authorities which is
       arguably more important:
       --- Quote ---
       > It shall be the duty of every ... local authority ... to
       secure the expeditious, convenient and safe movement of
       vehicular ... traffic ... on ... the highway
       --- End Quote ---
       My final submission to the appeal said this:
       --- Quote ---
       >
       > Without advance notice, drivers would come upon hazards and
       restrictions unexpectedly. They would then have to brake
       suddenly and swerve, change lane or turn round. Accidents would
       be far more common. This is why highway authorities place
       warning signs 45m before the hazard and why, for some
       restrictions, there is well-defined advance signage.
       >
       > For nearside with-flow bus lanes, that advance signage
       includes the lead-in taper and diagram 958 30m before the start
       of the taper. What Harrow created on Camrose Avenue in 1974 was,
       in effect, a nearside with-flow bus lane.
       --- End Quote ---
       3. I'm disturbed by your use of the term "TSRGD-compliant"
       signs. I'm aware that various judgments have used the term
       "substantially compliant" with regard to traffic signs. The ones
       from EWHC (I don't think I've seen any from AC or UKSC), which
       are precedents, seem to me to have been concerned with sets of
       traffic signs which work together, e.g. parking restrictions.
       Here it does indeed seem absurd that you should be able to
       ignore a sign staring you in the face because somewhere else
       there's a sign missing.
       But when it comes to individual signs, if a sign has not been
       placed as prescribed by TSRGD (and it can legitimately have been
       placed under a previous version) then, unless DfT has authorised
       it specially, it's been placed ultra vires and, by the tenets of
       administrative law, is void. That means that the adjudicator
       must exclude that sign from his assessment of the adequacy of
       the signage. He can still consider it in terms of legitimising
       an action by the motorist (theory of the second actor), but not
       to the potential benefit of the highway authority which placed
       it unlawfully.
       That is why I have been keen to knock the curved arrows out of
       contention: without them (and also the BUS GATE road markings,
       which have not been placed as prescribed), there's nothing
       between Shaldon Road and the white hatching in front of the
       traffic island. That absence of signage is Beatson's judgment
       writ large.
       4. I do consider that non-regulatory signs are to be taken into
       account in assessing the adequacy of the signage. For a
       with-flow bus lane, the diagram 958 and the lead-in taper are
       both informatory and neither is mandated by TSRGD 2016. It would
       help greatly if the advance notice signs which currently show
       only the width restriction also showed the bus restriction. So
       would a lane gain sign after Shaldon Road which showed that the
       inside lane was about to become bus-only and that the outside
       lane had a width restriction.
       5. What I'm trying to do now is to help other people who get
       PCNs on Camrose Avenue by developing boilerplate which they can
       use in their representations. I've been surprised by what I've
       found in the TMOs, which leads me to think that Harrow are
       vulnerable to the complete collapse of their highest-grossing
       TMO.
       Headstone Lane is vulnerable for the same reason and I have a
       separate line of attack on Charlton Road (based on Regulation
       18(2) of LATOR and Traffic Advisory Leaflet 3/13). On this last
       point, Cambridgeshire County Council have acknowledged that
       related signage which they use is wrong and will correct it.
       #Post#: 69978--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: H C Andersen
       Date: May 4, 2025, 12:39 pm
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       2. While Regulation 18 of LATOR places a duty on a highway
       authority, that duty cannot be enforced through an appeal
       against a PCN. There is another duty which s.122 of Road Traffic
       Regulation Act 1984 places on highway authorities which is
       arguably more important:
       What??
       If an adjudicator determines that LATOR has not been complied
       with then it is open to them to allow an appeal on the grounds
       that 'contravention did not occur'.
       As for ...But when it comes to individual signs, if a sign has
       not been placed as prescribed by TSRGD (and it can legitimately
       have been placed under a previous version) then, unless DfT has
       authorised it specially, it's been placed ultra vires and, by
       the tenets of administrative law, is void.
       Really?
       #Post#: 69981--------------------------------------------------
       Re: Harrow Camrose Avenue Appeal 2250053451
   DIR By: Hippocrates
       Date: May 4, 2025, 2:28 pm
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       I don't care much for the DFT authorisation at Shepherds Bush
       Road Southbound  Offside Bus Lane which runs counter to the TSM
       Chapter Three.
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