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       #Post#: 72458--------------------------------------------------
       Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: tonychess
       Date: May 20, 2025, 3:18 pm
       ---------------------------------------------------------
       Copy of the PCN here
  HTML https://postimg.cc/p9jSdGyc
       I have already appealed which they have rejected. I now have a
       tribunal date set for July 15th. Any help on this much
       appreciated.
       My proposed representation now:
       1: Inadequate/no signage: No warning to driver about prohibition
       preventing an
       otherwise perfectly legal manoeuvre.
       2: Highway safety: No way of safety exiting situation.
       3: Complex signage: Too many signs to read whilst vehicle is in
       a dangerous position to
       others. Once you reach the junction of Rivercourt rd there are
       no less than 11 separate
       signs. It is simply NOT possible to read all 11 signs whilst
       travelling at 40mph and coming off a
       dual carriageway. Indeed from the video H and F supplied of the
       incident you can see
       another car turning just behind me at speed. Thank goodness I
       did not stop to read 11
       signs and cause an accident! Signs include but are not limited
       to:”
       A Controlled Zone sign(which relates to parking). This is
       composite(has wording other
       than just the prescribed minimum of Controlled Zone)
       One-way street sign times 2
       A speed limit sign;
       A restricted access for vehicles over a prescribed weight sign
       with several very detailed
       associated plates;
       A no entry for vehicular traffic sign, with associated plate.
       And it appears a Red Route Clearway ends sign.
       A road name sign
       The actual sign relating to residents access is not actually
       located before the turning but
       rather on the other side of the road.
       4: Reversing back onto A4 is prohibited by Highway Code Rule 200
       and 201 On exiting
       the A4 (very busy 40 mph limit three line carriageway) onto
       Rivercourt Road I was
       immediately faced with a give way line and a barrage of signs.
       The “new turning bay” as
       shown in the notice of rejection is farcical. I would like to
       use pictures that H and F have
       sent in the notice of rejection as part of my evidence.
       The give way lines are so close to the junction and  near the A4
       main road and could
       possibility block another car exiting and force it to stop on
       the fast moving busy A4
       (please see video from H and F of vehicle movements behind me)
       To add complexity to
       the solution I was funnelled by two solid white lines, I think
       to prevent a car from turning
       around back on to the A4, I could reverse back onto the A4 but
       that is prevented by
       Highway Code 200 & 201 (either actions would not be sensible).
       So in conclusion, once
       I was committed to performing a perfectly legal everyday
       manoeuvre, I was compelled
       by the design of the junction to continue along Rivercourt Road
       #Post#: 72461--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles
   DIR By: tonychess
       Date: May 20, 2025, 3:46 pm
       ---------------------------------------------------------
       And two images hammersmith and Fulham sent me...
  HTML https://postimg.cc/9RvC0m53
       and
  HTML https://postimg.cc/4n9XM9VX<br
       />which I feel show a great representation of the number of
       signs
       at the junction as well as the ridiculous turning circle to try
       and get back onto the dual carriageway.
       #Post#: 72465--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles
   DIR By: fraser.mitchell
       Date: May 20, 2025, 4:02 pm
       ---------------------------------------------------------
       Please read this and update your thread accordingly: -
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/
       For a start you haven't given us a clue as to where this
       contravention took place, (although we all suspect it is
       Rivercourt Road, leading off the Great West Road.
       This now notorious restriction was implemented extremely badly
       by H & F. I suspect they broke every rule in the book on this
       one. However, as we all know, there are no powers to force them
       to amend it so they just carry on earning money from it.
       The main point is the restriction applies at the entrance to the
       street, off a 40 mph heavily trafficked dual carriageway, with
       no advance warning of what lies ahead. If they moved the
       restriction about 20 metres into the street, there is adequate
       room for a motorist to see the signs, turn round and join the
       main road again. I am not sure if H& F have let any cases get to
       London Tribunals, so have a search on their Statutory Register
       under the street name.
       #Post#: 72468--------------------------------------------------
       Re: Hammersmith and Fulham. Rivercourt Road Code 52M failing to
       comply with a prohibition on certain types of vehicles
   DIR By: tonychess
       Date: May 20, 2025, 4:15 pm
       ---------------------------------------------------------
       Thank you. I have edited the Subject title to indeed include
       Rivercourt Road. Well, I have a date for the tribunal so looks
       like I might be the guinea pig on this one!
       #Post#: 72469--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: fraser.mitchell
       Date: May 20, 2025, 4:25 pm
       ---------------------------------------------------------
       Can you please post-up their rejection letter and you reps text.
       Better if you'd come on here earlier before submitting reps, but
       we are where we are.
       #Post#: 72539--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: Bustagate
       Date: May 21, 2025, 7:10 am
       ---------------------------------------------------------
       Advance Signage and the Beatson Judgment
       I suggest that your main line of argument should be from
       paragraph 65 of Beatson J's judgment in R (Oxfordshire County
       Council) v. The Bus Lane Adjudicator
  HTML https://www.bailii.org/ew/cases/EWHC/Admin/2010/894.html
       [2010]
       EWHC 894 (Admin):
       --- Quote ---
       >
       > 65. The Defendant's submission that the fact that signs are
       prescribed or authorised does not mean they are sufficient for
       securing adequate information as to the effect of an order is
       made available to road users is clearly correct. If the signs do
       not in fact provide adequate information no offence is
       committed; see James v Cavey [1967] 2 QB 676.
       >
       --- End Quote ---
       That judgment was in the High Court, so is binding on lower
       tribunals. It was for the same road sign: diagram 619 ("flying
       motorcycle") but with different associated plates. In that case
       there were advance warning signs 450, 180 and 20 yards before
       the diagram 619. Beatson J assessed those signs as providing
       sufficient notice, having established that they could be seen by
       a motorist approaching them (i.e. they weren't obscured).
       In this case it appears that Hammersmith and Fulham have not got
       TfL to place appropriate advance signage on the A4. That would
       be a No Left Turn (diagram 613) immediately before the junction
       with the plate "Except buses taxis cycles and authorised
       vehicles". In order to ensure that traffic flow on the A4 isn't
       disrupted, a further map-type sign might be placed 50m before
       this.
       Relationship between H&F and TfL
       It's worth noting that s.121B of Road Traffic Regulation Act
       1984
  HTML https://www.legislation.gov.uk/ukpga/1984/27/section/121B<br
       />provides:
       --- Quote ---
       >
       > 121B  London borough council exercising powers so as to affect
       another traffic authority’s roads.
       >
       > (1) No London borough council shall exercise any power under
       this Act in a way which will affect, or be likely to affect,—
       > (a) a GLA road, or
       > (aa) a strategic road ...
       > unless the requirements of subsections (2) and (3) below have
       been satisfied.
       >
       > (2) The first requirement is that the council has given notice
       of the proposal to exercise the power in the way in question—
       > (a) to Transport for London...
       >
       > (3) The second requirement is that—
       > (a) the proposal has been approved
       > (i) in the case of a GLA road, by Transport for London;
       > (ii) in the case of a strategic road, by Transport for London
       ...
       > (b) the period of one month beginning with the date on which
       Transport for London and, where applicable, the council received
       notice of the proposal has expired without Transport for London
       or the council having objected to the proposal; or
       > (c) any objection made by Transport for London or the council
       has been withdrawn; or
       > (d) where an objection has been made by Transport for London
       or a London borough council and not withdrawn, the Greater
       London Authority has given its consent to the proposal after
       consideration of the objection.
       >
       --- End Quote ---
       It would be worth finding out whether H&F have complied with
       this. If they haven't, the entire scheme is probably unlawful.
       Requirement to Give Way 8m after leaving A4
       As the supposed contravention occurs when you pass the "flying
       motorcycle" signs, their distance from the A4 is largely
       irrelevant. What I find disturbing, however, is that at the same
       point as those signs there are Give Way road markings (diagram
       1003A). This is a mere 8m from the A4. That road marking
       requires you to give way to any vehicle which is on Rivercourt
       Road beyond it. That could very well be a vehicle which is using
       the "turning bay" to turn round, having come south along
       Rivercourt Road from King Street and now needs to return north
       because exit onto the A4 is prohibited (thanks to TfL).
       What this means is that any vehicle turning off the A4 onto
       Rivercourt Road has a mere 8m to come to a halt. I'd like to see
       a school bus for Latymer Upper do that: they're more than 8m
       long, so would need to stop with their rear ends obstructing the
       A4. That doesn't sound a great idea. It's why I rather suspect
       that H&F haven't notified TfL and obtained their consent to this
       scheme. Cars which had been slowing down to turn left might just
       be able to stop, but it would be a hard-on emergency stop: the
       braking distance from 30 mph (i.e. allowing for having slowed to
       take the corner and then excluding thinking distance) is 13.5m.
       Duty to secure the expeditious, convenient and safe movement of
       ... traffic
       I do wonder whether H&F carried out a safety analysis of this
       scheme. The scheme looks to me to be a violation of H&F's duty
       under s.122 of Road Traffic Regulation Act 1984
  HTML https://www.legislation.gov.uk/ukpga/1984/27/section/122:
       --- Quote ---
       >
       > It shall be the duty of every ... local authority upon whom
       functions are conferred by or under this Act, ... to secure the
       expeditious, convenient and safe movement of vehicular and other
       traffic (including pedestrians) and the provision of suitable
       and adequate parking facilities on and off the highway....
       >
       --- End Quote ---
       If H&F are in breach of this duty, they may have been acting
       ultra vires in implementing it. That would mean that the scheme
       was void, i.e. legally does not exist and therefore cannot be
       enforced. While adjudicators start from a presumption of
       regularity, i.e. that official acts have been undertaken
       properly, it is possible to rebut that presumption if the
       evidence is strong enough. In this case that distance of 8m
       looks strong enough as the stopping and braking distances are
       well-known formulae which have been in The Highway Code for
       decades. I shall be making FoI requests to H&F and TfL to try to
       elicit further evidence.
       #Post#: 72757--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: tonychess
       Date: May 22, 2025, 8:22 am
       ---------------------------------------------------------
       So, I have received an email from H and F today canceling the
       tribunal!
  HTML https://postimg.cc/1gs6JPcF
  HTML https://postimg.cc/34Ht7PTC
  HTML https://postimg.cc/1fzJ9GLT
  HTML https://postimg.cc/jwX4T2vt
       I find it quite annoying that they would decline my initial
       appeal and schedule a tribunal date- for me to then upload my
       appeal as per my initial post and then to cancel the tribunal. I
       was *almost* looking forward to it.  A more sceptical person
       might presume H and F didn't want to set a precedent at tribunal
       for others to follow!
       Or maybe they are reading this thread and you all scared them
       off!
       #Post#: 72778--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: John U.K.
       Date: May 22, 2025, 9:39 am
       ---------------------------------------------------------
       How many appeals regarding this junction must H&F decline to
       contest at the last minute before the Cost clause ( see below)
       of the Schedule to
       The Civil Enforcement of Road Traffic Contraventions
       (Representations and Appeals) (England) Regulations 2022
  HTML https://www.legislation.gov.uk/uksi/2022/576/schedule/1
       is invoked?
       --- Quote ---
       >
       > Costs
       >
       > 13.—(1) An adjudicator must not normally make an order
       awarding costs and expenses.
       >
       > (2) But, subject to sub-paragraph (3), an adjudicator may make
       an order awarding costs and expenses—
       >
       > (a)against a party (including an appellant who has withdrawn
       an appeal or an enforcement authority which has consented to an
       appeal being allowed), if the adjudicator considers that—
       >
       > (i)the party has acted frivolously or vexatiously, or
       >
       > (ii)the party’s conduct in making, pursuing or resisting an
       appeal was wholly unreasonable;
       >
       > (b)against an enforcement authority, where the adjudicator
       considers that the disputed decision was wholly unreasonable.
       >
       > (3) An order must not be made against a party unless that
       party has been given an opportunity to make representations
       against the making of the order.
       >
       > (4) An order must require the party against whom it is made to
       pay to the other party a specified sum in respect of the costs
       and expenses incurred by that other party in connection with the
       proceedings.
       --- End Quote ---
       I also seem to recall reading that where  an EA had DNC'd the
       appellant had a rght to insist that an appeal sill be heard, but
       it may have been my dreaming or wishful thinking.
       #Post#: 72811--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: Bustagate
       Date: May 22, 2025, 11:37 am
       ---------------------------------------------------------
       Clearly they're running scared of appearing before an
       adjudicator and are just collecting £65 from those who pay up
       because challenging it takes time and effort.
       Those "advance signs" don't pass muster: neither
       RESTRICTED ACCESS TO RIVERCOURT ROAD 330 YARDS AHEAD
       nor
       LOCAL ACCESS ONLY 70 YARDS AHEAD
       conveys anything like the minimum appropriate signage: a
       750mm-diameter No Left Turn sign (diagram 613) with the plate
       "Except buses, taxis, cycles and authorised vehicles"
       #Post#: 72819--------------------------------------------------
       Re: Hammersmith and Fulham. Code 52M failing to comply with a
       prohibition on certain types of vehicles. Rivercourt Road
   DIR By: Bustagate
       Date: May 22, 2025, 12:13 pm
       ---------------------------------------------------------
       I have looked into the TMO
  HTML https://www.whatdotheyknow.com/request/freedom_of_information_request_r_419/response/2866782/attach/3/2%20Rivercourt%20Road%20TMO.pdf?cookie_passthrough=1.<br
       />It's interesting. The critical element is the Schedule, which
       is
       attached below. It defines the section of Rivercourt Road which
       is restricted as
       --- Quote ---
       >
       > between Great West Road and a point and a point 8.30 meters
       south of the southern building wall of No.17 Rivercourt Road
       >
       --- End Quote ---
       A Question
       Where is the junction between Great West Road and Rivercourt
       Road?
       If you're a diehard motorist, the answer will be the dashed
       lines where the side road splits from the carriageway of the A4.
       That's not my answer, and I don't think it's TfL's answer. A
       highway extends from the curtilage on one side of the highway to
       the curtilage on the other side. Between those curtilages there
       may be a carriageway (two for the Great West Road, none for a
       footpath or bridleway), one or more footways and verges, and
       also "waste", which is land outside all those already named. All
       of those are highway land and the highway encompasses them all.
       Attached are Google Street View images looking westwards of the
       junction between Great West Road and Rivercourt Road. Note the
       sign ringed in yellow on RivercourtRoadClearway1.jpg, which can
       be read more clearly on RivercourtRoadClearway2.jpg. That sign
       and post have been placed close to the boundary wall of what
       used to be 20, Rivercourt Road (see the map
       RivercourtRoad1957red.jpg) but which is now part of the campus
       of Latymer Upper School.
       The sign reads "RED ROUTE // CLEARWAY // End". It marks the
       boundary of the curtilage of the Red Route which, in this case
       is the Great West Road. There is no corresponding sign on the
       east side of Rivercourt Road, so it's impossible to tell where
       TfL consider the curtilage lies there. I have marked in red on
       the map RivercourtRoad1957red.jpg where I surmise the curtilage
       to lie.
       What can be said with confidence is that the Great West Road
       includes the verge and the footway (which is also a cycleway),
       and that east of Rivercourt Road these abut railings about 8.3m
       south of the boundary wall of 17, Rivercourt Road. The
       complexity of the boundary between Great West Road and
       Rivercourt Road would explain why previous TMOs for Rivercourt
       Road have defined their southern boundary by reference to some
       supposedly well-defined point on Rivercourt Road.
       Analysis of the Schedule
       Now let's return to the Schedule of the TMO. Leaving aside the
       repetition of "and a point", the section of Rivercourt Road on
       which it defines a south-to-north one-way restriction is from
       the Great West Road to a point 8.30m south of the southern
       building wall of 17, Rivercourt Road.
       The "RED ROUTE // CLEARWAY // End" sign appears to lie about 5m
       south of the southern boundary wall of number 17. This must be
       the boundary where Great West Road meets Rivercourt Road. It is
       the southern end of the south-to-north restriction on Rivercourt
       Road. That makes sense as Hammersmith & Fulham's jurisdiction
       runs north from here. So far, so good.
       Now for the end of the restriction: this lies "8.30m south of
       the southern building wall of 17, Rivercourt Road". While it's
       not clear what "southern building wall" means, Give Way road
       markings (diagram 1003A) have been placed about 3m south of the
       "RED ROUTE // CLEARWAY // End" sign, i.e. 8m south of the
       southern boundary wall of number 17. These road markings are
       clearly intended to mark the end of the one-way northbound
       section of Rivercourt Road.
       We can infer that Hammersmith & Fulham's intention was to impose
       a one-way northbound restriction on that element of carriageway
       which leads from the carriageway of the Great West Road towards
       Rivercourt Road. What they have actually done has been to pass a
       resolution to impose a TMO which defines a one-way
       south-to-north restriction that actually runs north-to-south
       across part of an east-west highway in another authority (TfL)'s
       jurisdiction. It follows that the TMO is ultra vires and
       therefore void.
       Perhaps this is the reason why H&F are so reluctant to let any
       appeal reach an adjudicator. They know that the whole thing is a
       complete nonsense and are just collecting as many £65's as they
       can.
       I've made some FoI requests to H&F and TfL and shall be
       interested to see their replies.
       [attachment deleted by admin]
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