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       #Post#: 82659--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: John U.K.
       Date: July 25, 2025, 7:37 am
       ---------------------------------------------------------
       To be clear, this is a representation to the Council against the
       PCN, and not an appeal to the Adjudicator.
       I am not sure about the penultimate paragraph. Perhaps
       @Bustagate will review it for you.
       I have copied your draft here for ease of suggesting edits.
       --- Quote ---
       >
       > (You need a heading)
       >
       > [center]Re: PCN HZ93517337 Reg.Mark HN21XOH[/center]
       >
       > [justify]I make these representations against the above PCN
       and also ask they be caonsidered as supplementary
       representations against PCN HZ93433791[/justify]
       >
       > Having [s]since received a second PCN (HZ93517337), I realise
       the first time I noticed the new signage was on 06/07 rather
       than 01/07, hence my driving down Rivercourt Road twice in the
       same week – something that I of course would not have done
       otherwise.[/s] (I don't feel this para helps)
       >
       > These PCNs relate to alleged contraventions on 1st and 6th
       July respectively, the latter being before the first PCN was
       received.
       >
       > I drove down along the A4 again on 20/07 and for the first
       time, I noticed both two advance variable message signs – pretty
       difficult to read in daylight – and three inadequately sized,
       decidedly unclear portable signs on the roadside. I do not
       believe These portable signs were even not there at the time of
       the alleged contravention. Their being a recent addition shows
       the Council recognise the earlier signage arrangements were
       inadequate.
       >
       > I was, as goes without saying, consciously looking out for any
       indication of this new restriction on 20/07, and don’t recall
       seeing any of this the dot matrix signs on either prior
       occasion, but obviously the A4 requires complete attention at
       all times given how busy it is, especially taking into account
       the many vehicles merging from Weltje Road and the BP petrol
       station, and so on.
       >
       > The only sign indicating that a permit is required to use the
       exit is located after the point of restriction as specified in
       the relevant Traffic Management Order (TMO). This undermines the
       enforceability of the restriction, as drivers are not given
       sufficient advance warning. Furthermore, the variable message
       signs currently in place do not conform to the requirements of
       the Traffic Signs Regulations and General Directions (TSRGD) as
       they are dot-matrix displays. Additionally, on closer
       inspection, they read: ‘NO THROUGH ROUTE TO KING STREET VIA
       RIVERCOURT RD’. Again, no mention of the need for a permit, plus
       this requires a degree of local knowledge which many will not
       possess and is thus misleading.
       >
       >
       > In addition, a tree is was obscuring the many signs and road
       markings on the entrance to Rivercourt Road itself (a composite
       ‘Controlled Zone’ sign with extra text; two one-way street
       signs; a speed limit sign; a cycle and pedestrian sign; a road
       name sign; the signs restricting access to permit holders,
       mentioned for the first time -see attached image), [i](use the
       image from Reply #2 on this thread) [/i].making it practically
       impossible to see them without having already made the turning.
       Having been travelling at 40mph, this signage is absolutely
       excessive, and very difficult to read and safely process in such
       a short space of time. As I’ve previously suggested in my reps
       against the 1st PCN (?), to then reverse is also entirely out of
       the question as it would create a clear road safety hazard.
       Again, and to reiterate, I’m really unsure as to what else I
       could’ve done here as proceeding was the only safe and
       responsible course of action, and I do not believe that I had
       reasonable opportunity to see, interpret, and respond to the new
       restriction in time.
       >
       > Once committed to the slip road, I had no legal or safe way to
       reverse or turn around: reversing back onto the A4 – a 40mph,
       three-lane carriageway – would have violated Highway Code Rules
       200 and 201, and posed a serious safety risk; the ‘new turning
       bay’, referenced in the Notice of Rejection, is not viable in
       real-world driving conditions, as the layout makes reversing or
       turning impractical and hazardous; the give way lines are
       extremely close to the junction, and could result in a vehicle
       being stranded partially on the
       > A4; solid white lines funnel exiting traffic forward and
       physically discourage any turning back, clearly indicating that
       the road is designed to force vehicles forward. All of this
       falls far short of the standard required for proper and
       enforceable traffic control.
       > The junction’s layout left me no safe, legal alternative but
       to continue onto Rivercourt Road.
       >
       > The manoeuvre I performed was an ordinary, lawful one, made
       hazardous only by poor signage, confusing road layout, and
       environmental conditions. As established in James v Cavey [1967]
       2 QB 676, the fact that signage is prescribed or authorised does
       not guarantee that it sufficiently communicates the effect of a
       traffic order. If signage fails to provide clear and adequate
       information to the road user, no offence is committed. That
       principle applies
       > directly in this case.
       >
       > Finally, the alleged contravention occurred on the slip road
       exiting the Great West Road (A4), before I reached the ‘RED
       ROUTE // CLEARWAY // Exit’ sign marking the boundary between
       TfL’s slip road and Hammersmith and Fulham’s Rivercourt Road.
       The signage marking the restriction boundary appears after the
       point at which I exited, placing the alleged contravention
       outside the effective enforcement zone.
       >
       > In light of the above, I respectfully request that this appeal
       be allowed my representations be accepted and both PCNs be
       cancelled. The combination of unclear and poorly positioned
       signage, complex and overwhelming sign clutter, the absence of
       advance warning, and the lack of a safe alternative route meant
       that compliance with the restriction was not reasonably possible
       under the circumstances. I would also respectfully ask the
       Adjudicator to urge the Council to further review the signage
       layout and placement at this junction in the interest of
       fairness and public safety
       >
       >
       --- End Quote ---
       #Post#: 82670--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: stereodista
       Date: July 25, 2025, 8:35 am
       ---------------------------------------------------------
       Thanks so much for your help, John. Have submitted a revised
       edit to H&F. Fingers crossed.
       #Post#: 86924--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: Bustagate
       Date: August 23, 2025, 10:48 am
       ---------------------------------------------------------
       re Reply#1: I've had confirmation from TfL that H&F did not
       serve notice on them about the proposed changes to Rivercourt
       Road. It's here
  HTML https://www.whatdotheyknow.com/request/junction_of_great_west_road_with#incoming-3090738.
       The relevant passage is:
       --- Quote ---
       >
       > You asked
       > ...
       > 3. details of notice and correspondence between H&F and TfL
       relating to their TMO 2037, in particular under section 121B of
       Road Traffic Regulation Act 1984;
       >
       > Our Streets Asset Operations team did not receive any notice
       or correspondence from the London Borough of Hammersmith and
       Fulham relating to their TMO 2037.
       >
       --- End Quote ---
       Note that s.121B of RTRA 1984 is far stronger than r.6 LATOR
       1996:
       --- Quote ---
       >
       > (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
       > . . .
       > 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; and
       > . . .
       >
       > (3)The second requirement is that—
       > [indent](a) the proposal has been approved
       > [indent](i) in the case of a GLA road, by Transport for
       London;
       > . . .[/indent]
       > (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.[/indent]
       >
       > (4) Before deciding whether to give any consent for the
       purposes of subsection (3)(d) above, the Greater London
       Authority may cause a public inquiry to be held.
       >
       > (5) If Transport for London has reason to believe—
       > [indent](a) that a London borough council is proposing to
       exercise a power under this Act in a way which will affect, or
       be likely to affect,
       > [indent](i) a GLA road,[/indent]
       > . .
       > (b) that notice of the proposal is required to be, but has not
       been, given in accordance with subsection (2) above,[/indent]
       > Transport for London may give a direction to the council
       requiring it not to proceed with the proposal until the
       requirements of subsections (2) and (3) above have been
       satisfied.
       >
       > (6) If a London borough council exercises any power in
       contravention of this section, Transport for London may take
       such steps as it considers appropriate to reverse or modify the
       effect of the exercise of that power.
       >
       > (7) For the purposes of subsection (6) above, Transport for
       London shall have power to exercise any power of the London
       borough council on behalf of that council.
       >
       > (8 ) Any reasonable expenses incurred by Transport for London
       in taking any steps under subsection (6) above shall be
       recoverable by Transport for London from the London borough
       council concerned as a civil debt.
       >
       --- End Quote ---
       After repeated prodding, TfL came up with a plan from their
       Property Asset Register
  HTML https://www.whatdotheyknow.com/request/junction_of_great_west_road_with/response/3090663/attach/4/image002.png<br
       />which shows which land TfL controls and which it owns. This
       shows that the "RED ROUTE // CLEARWAY // End" sign is actually
       on H&F's land and that the boundary of the TfL-controlled land
       is just a straight line along the northern edge of the combined
       cycle/footway.
       TfL don't actually own the land of the former Rivercourt Road
       where the A4 crosses it. I surmise that neither does H&F. This
       is because compulsory purchase powers can only be exercised
       against the owners of a plot of land. The householders on either
       side of Rivercourt Road had their land acquired, but it will be
       lost in the mists of time who actually possessed title to the
       land which formed the roads. As councils have powers to make and
       maintain highways, they don't need ownership of the land to do
       what they want. The same appears to have happened with Weltje
       Road and part of Hampshire Hog Lane (the curious dog-leg in the
       A4 to the east of Rivercourt Road).
       With regard to the sandwich-board signs, H&F's plans for these
       showed them 2.4m tall, which would have made them readable by
       passing motorists. The signs themselves (inevitably) don't
       comply with TSRGD 2016; but then H&F's highway engineers seem to
       have great difficulty understanding that they can't just produce
       signs as they see fit.
       #Post#: 86926--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: stereodista
       Date: August 23, 2025, 10:54 am
       ---------------------------------------------------------
       In idiot terms (me being the idiot in question!) is this good
       news? I’ve still to hear back from them, but am not particularly
       worried at this stage. Having driven the A4 repeatedly since,
       it’s so obviously a botched job.
       #Post#: 86928--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: Bustagate
       Date: August 23, 2025, 11:10 am
       ---------------------------------------------------------
       I don't think it makes any difference to you. It's just
       something which people such as @Incandescent have been wondering
       about and which (somewhat to my surprise) TfL were actually
       prepared to state: that H&F did not follow the law when they
       made the changes to Rivercourt Road. TfL could take action
       against H&F but don't appear to be interested in doing so.
       The problem is that while an action for judicial review of H&F's
       actions might well succeed, that costs much  more than any
       number of PCN fines AND there's the risk that you don't succeed
       and then have to pay H&F's costs in defending the action. Hence
       it's only for people with really deep pockets, such as
       businesses which risk going bankrupt because they've lost so
       much trade (as happened with the West Dulwich LTN).[table]
       [tr]
       [td][/td]
       [/tr]
       [/table]
       #Post#: 86930--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: John U.K.
       Date: August 23, 2025, 11:39 am
       ---------------------------------------------------------
       --- Quote ---
       > TfL don't actually own the land of the former Rivercourt Road
       where the A4 crosses it. I surmise that neither does H&F. This
       is because compulsory purchase powers can only be exercised
       against the owners of a plot of land. The householders on either
       side of Rivercourt Road had their land acquired, but it will be
       lost in the mists of time who actually possessed title to the
       land which formed the roads.
       --- End Quote ---
       @Bustagate
       Does not the body making and enforcing the CPO acquire the title
       to the land?  If so the public notices of the CPO proposals
       should still be in the relevant  London Gazette and the local
       press (West London Observer, inter alia, at that time). This
       section of the Great West Road opened 1956, so CPO must be some
       years before that.
       #Post#: 86932--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: John U.K.
       Date: August 23, 2025, 12:05 pm
       ---------------------------------------------------------
       --- Quote from: stereodista link ---
       >
       > In idiot terms (me being the idiot in question!) is this good
       news? I’ve still to hear back from them, but am not particularly
       worried at this stage. Having driven the A4 repeatedly since,
       it’s so obviously a botched job.
       >
       --- End Quote ---
       In the latest success post here H&F didn't even threaten
       Tribunal before cancelling - see this thread
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/lbhf-52m-prohibition-on-certain-vehicles-rivercourt-road-turning-from-great-west/msg86423/#msg86423
       and also
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/pcn-hammersmith-and-fulham-contravention-52m-rmv-rivercourt-rd/msg84708/#msg84708
       #Post#: 86938--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: stereodista
       Date: August 23, 2025, 1:38 pm
       ---------------------------------------------------------
       Understood. Thank you!
       #Post#: 94806--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: stereodista
       Date: October 20, 2025, 8:02 am
       ---------------------------------------------------------
       So I’ve just received two letters from H&F, one confirming the
       first PCN has been cancelled and the other rejecting the
       representation. Their decision: ‘I have considered what you have
       said and all the available evidence, but I do not agree that we
       should cancel your liability for this PCN.’ No idea how/ why one
       is any different from the other, but should I appeal to the
       adjudicator at this stage? Thanks for any further help!
       #Post#: 94808--------------------------------------------------
       Re: Rivercourt Road PCN x2
   DIR By: John U.K.
       Date: October 20, 2025, 8:11 am
       ---------------------------------------------------------
       Please post copies of the letters, redacting only yr name &
       address.
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