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#Post#: 90880--------------------------------------------------
Council Kiosk User Interface Issues - do I have a hope in hell?
DIR By: advicewelcome
Date: September 21, 2025, 9:39 pm
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Hi, welcome knowing if should just pay the £25 before 2nd
October, or should I go through the appeal process with a hope
of wining?...
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BACKGROUND INFO:
1) I received a fine on the car window from the local council
for parking in a council-run facility. I attempted to obtain a
ticket, but the full registration number was not entered or
printed correctly, which resulted in a fine being issued:
HTML https://i.postimg.cc/Whrd12TW/20250827-PCN1c-all-blank.jpg
HTML https://i.postimg.cc/VJW5XDSX/20250827-PCN1c-all-blank2.jpg
2) I submitted an informal challenge to the fine on the basis of
the following...
“I am writing to challenge PCN OHXXXXXXXX issued at Tudor Grange
car park for some, but not limited to, the reasons indicated
below:
A valid ticket was attained by he driver (evidence of token
attached), but due to visual impairment, disability and the poor
visibility of the machine interface and processing, the car reg
was not registered correctly on the token. I believe this
constitutes a minor error, considering the parking was within
the time frame, a ticket attempt occurred - and that the
council importantly has a duty under the Equality Act 2010 to
make reasonable adjustments for disabled users. TPT decisions
often cite proportionality, fairness, and legitimate
expectation—especially when the user made a genuine effort to
comply. I respectfully request cancellation of the PCN on
grounds of payment made, accessibility barriers, and procedural
fairness. Welcome your contact to confirmation of this and
response should be via email also to ensure it is received, as
not permanently at that address. Thanks."
3) I was given this informal response:
HTML https://i.postimg.cc/TKVQgMqQ/Letter1-blank.jpg
HTML https://i.postimg.cc/cKdhc9FW/Letter2.jpg
It seems ridiculous for them to fine when an attempt was made
for the ticket. The kiosk are very difficult to operate: The
machines have response delay, the screens are very hard to see
(particularly in bright sunlight or when it’s raining), I am
unsure whether these machines meet accessibility and legal
compliance requirements?
HTML https://i.postimg.cc/185Fvfkg/IMG-20250824-180513-DRO.jpg
HTML https://i.postimg.cc/KkL31LMW/IMG-20250824-180519-DRO.jpg
HTML https://i.postimg.cc/cKP81TrY/IMG-20250824-180525-DRO.jpg
HTML https://i.postimg.cc/TK7DFTxt/IMG-20250824-180936-DRO.jpg
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I have gathered some general information about accessibility
standards and requirements for such machines (provided below) in
case it nudges any thoughts?...
⚖️ Legal Context
In the UK, local councils must ensure parking infrastructure is
compliant with:
1. Equality Act 2010
◦ Requires “reasonable adjustments” so that people
with disabilities are not placed at a substantial disadvantage
compared to non-disabled users.
◦ This applies to physical access (height, reach,
tactile buttons) and information access (readability of screens,
instructions, contrast, visibility).
2. Public Sector Equality Duty (PSED)
◦ Councils like Solihull have a duty to anticipate
and address barriers faced by disabled people.<br>
◦ They must show they considered accessibility in
procurement and deployment of machines.<br>
3. BS EN 301 549 (Accessibility requirements for ICT
products and services)<br>
◦ A European/UK standard, often applied to public
machines. Requires features like audio feedback, tactile
controls, screen readability, and compatibility with assistive
devices.<br>
4. Traffic Management Act 2004<br>
◦ Covers enforcement of parking rules — councils
must ensure that pay-and-display systems are fair, transparent,
and reasonably usable.<br>
⚠️ Observed User Interface / Accessibility Issues:
• Small buttons: The keypad buttons are small and flat,
which is difficult for people with reduced dexterity (e.g.
arthritis, tremors).<br>
• Screen readability: The LCD screen has low contrast and
glare, making it hard to read in bright light or for people with
sight impairment.<br>
• No audio/tactile feedback: Appears to be visual-only, so
people with limited vision would struggle.<br>
• High reliance on fine motor skills: Typing in full
registration number with small round buttons is a barrier.<br>
• Payment limitations: Coins only (no card/contactless, no
app QR link visible) — disadvantages people who cannot handle
coins easily.<br>
• Height & angle: Depending on installation, may not be
wheelchair-accessible if keypad/screen is too high.<br>
✅ What Councils Should Ensure
To be compliant and fair, councils like Solihull should check
machines against:<
Accessible design guidance (BS 8300, inclusive design in the
built environment).
Alternative payment methods: App, phone call, card/contactless.
Screen accessibility: High-contrast, large text, good visibility
in sunlight.
Tactile & audio support: Raised lettering on keys, audio
prompts, or headphone socket.
Reachability: Installed at a height usable for wheelchair users.
Reasonable adjustments: For those unable to use the machine,
ensure there are alternative methods (e.g. pay by phone, permit
schemes, disabled exemptions).
🔎 Bottom line:
These machines are likely legal but may not meet accessibility
requirements under the Equality Act 2010 and PSED if they are
the only way to register for free parking.<br>
Councils must show they considered disabled users’ needs. A
“sighted people only” design could be challenged as indirect
discrimination.<br>
At minimum, Solihull Council should provide alternative methods
(phone/app/online registration) to ensure inclusion.
#Post#: 90886--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: stamfordman
Date: September 22, 2025, 3:26 am
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You've blanked the details so we can't check if councils pics
available.
What digit did you get wrong?
The terms board just says you must clearly display a parking
ticket, which you did, so to enforce this they are reliant on
the machine instructions which say enter the full VRM, and that
failure to buy a valid ticket for the duration may result in a
PCN, which implies the key is cover for the stay and there is
nothing that says a VRM error is not valid.
This is backed up by the order, which says:
The Driver of a vehicle using a pay and display Parking Place
shall upon leaving the
vehicle in the Parking Place, and on payment of a charge,
purchase a Pay and Display
Ticket at the level of charge and for the period required in
accordance with the
instructions on the machine and the scale of charges specified
in the Schedule.
HTML https://tro.trafficpenaltytribunal.gov.uk/TRO/Solihull/OH05.pdf
There is no reference to having to get the VRM right and there
is no dispute you had cover for the right time in the right car
park.
I would go on the main terms board does not state what can give
rise to a PCN and like some other councils they have junked
their duty to act fairly for a one off error that has no impact
on them.
#Post#: 90896--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: H C Andersen
Date: September 22, 2025, 4:15 am
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All photos are illegible on my ipad.
#Post#: 90900--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: stamfordman
Date: September 22, 2025, 4:25 am
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HTML https://i.ibb.co/GQpDNr2Q/IMG-20250824-180525-DRO.jpg
HTML https://i.ibb.co/hRKbfYNZ/IMG-20250824-180936-DRO.jpg
HTML https://i.ibb.co/k6M2SYpT/Letter1-blank.jpg
HTML https://i.ibb.co/Vczgc8h5/Letter2.jpg
HTML https://i.ibb.co/KzzNhbDY/20250827-PCN1c-all-blank.jpg
#Post#: 90910--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: H C Andersen
Date: September 22, 2025, 5:33 am
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[member=2249]stamfordman[/member], many thanks.
OP, have you posted the back of your PCN and the P&D ticket
itself?
You refer to disability, pl expand on this as it directly
affects you.
What's the VRM and are you the registered keeper with current
DVLA details?
#Post#: 90913--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: stamfordman
Date: September 22, 2025, 5:49 am
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HTML https://i.ibb.co/YF5wJdDZ/20250827-PCN1c-all-blank2.jpg
#Post#: 90945--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: advicewelcome
Date: September 22, 2025, 9:21 am
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Sorry not got the hang of pic posting on this site
This is link to the PCN front and back:
HTML https://postimg.cc/gallery/5XygtLY
HTML https://postimg.cc/gallery/5XygtLY
Letters from council link:
HTML https://postimg.cc/gallery/s7hRcD9
HTML https://postimg.cc/gallery/s7hRcD9
This is the Kiosk & Signage pics:
HTML https://postimg.cc/gallery/C0tqhBk
HTML https://postimg.cc/gallery/C0tqhBk
Pic of the actual token:
HTML https://postimg.cc/94HYVjTp
HTML https://postimg.cc/94HYVjTp
Pic of ticket attached to car:
HTML https://postimg.cc/F1CgP6rT
HTML https://postimg.cc/F1CgP6rT
As per token, I entered "YY" instead of a normal car reg of "YXX
XXX"
Driver is reg keeper at DVLA.
Can't see that blasted screen and impossible to press those
buttons.
HTML https://www.flowbird.com/our-solutions/parking-solutions/on-street/
HTML https://www.flowbird.com/our-solutions/parking-solutions/on-street/
...These people make them so not sure if they are compliant to
any public standards.
Welcome if have "winable" grounds for appeal, and what I would
need to do? Is the £25 bait, and will they offer that again?
#Post#: 92263--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: advicewelcome
Date: September 30, 2025, 8:32 pm
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Hi,
I think I may be able to send an email to the Solihull Parking
email and to the Councillor in charge of Parking - would the
below work? And if not, it can be used at the TPT?
What do you think its chances of its success at TPT? 50% chance
of winning, 70%, 10%?
Will help me estimate if its worth the time to submit or pay the
£25.
******************
Subject: Formal Appeal Against PCN OHXXXXXXXX – Tudor Grange
Leisure Centre, 24/08/2025
To Whom It May Concern,
I am writing to ascertain assistance in regard to Penalty Charge
Notice OHXXXXXXXX, issued on 24/08/2025 at Tudor Grange Leisure
Centre Car Park. I respectfully request cancellation of the PCN
on the grounds of factual compliance, procedural unfairness, and
breach of statutory duties under the Equality Act 2010 and the
Traffic Management Act 2004.
---------------------------------------------------------
1. Factual Background
- A valid Pay & Display ticket was obtained at 16:03 on
24/08/2025, covering parking until 18:00.
- The ticket was clearly displayed on the dashboard, as
evidenced in the attached photograph.
- Due to visual impairment and poor machine interface design,
the vehicle registration mark (VRM) was entered incorrectly.
- The Civil Enforcement Officer issued the PCN at 17:08, despite
the vehicle being covered for the full duration and parked in a
marked bay.
---------------------------------------------------------
2. Compliance with the Traffic Regulation Order (TRO OH05)
The relevant clauses of the Solihull TRO OH05 state:
- Clause 6(1):
“The Driver of a vehicle using a pay and display Parking Place
shall upon leaving the vehicle in the Parking Place, and on
payment of a charge, purchase a Pay and Display Ticket at the
level of charge and for the period required in accordance with
the instructions on the machine…”
- Clause 6(2):
“The Driver shall display the Pay and Display Ticket issued in
respect of the vehicle in a conspicuous position on the
dashboard or fascia of the vehicle so that the ticket is clearly
visible from the outside of the vehicle.”
- Clause 6(3):
“A Pay and Display Ticket shall be valid only for the vehicle
in respect of which it was issued and for the Parking Place in
which it was issued.”
I complied with all three clauses:
- The correct charge was paid.
- The ticket was displayed conspicuously.
- The ticket was issued for the correct location and used by the
driver of the vehicle in question.
The TRO does not explicitly require perfect VRM entry for a
ticket to be valid. Enforcement based solely on machine
instructions—without clear incorporation into the TRO—is legally
unsound and ultra vires.
---------------------------------------------------------
3. Equality Act 2010 – Reasonable Adjustments
Under Sections 20 and 29 of the Equality Act 2010, Solihull
Council has a duty to make reasonable adjustments for disabled
service users.
- The machine interface was inaccessible when there are visually
impairment and challenging light conditions.
- The failure to accommodate this barrier, and the refusal to
cancel the PCN despite being informed, constitutes indirect
discrimination.
- The Council must consider the Public Sector Equality Duty
(Section 149) to eliminate discrimination and advance equality
of opportunity.
---------------------------------------------------------
4. Statutory Guidance – Discretion and Fairness
Under the Statutory Guidance to Local Authorities on Civil
Parking Enforcement (TMA 2004, Section 87):
--- Quote ---
> “An authority has a discretionary power to cancel a PCN at any
point throughout the process. It can do this even when an
undoubted contravention has occurred if the authority deems it
to be appropriate in the circumstances of the case.”
--- End Quote ---
--- Quote ---
> “Under general principles of public law, authorities have a
duty to act fairly and proportionately and are encouraged to
exercise discretion sensibly and reasonably and with due regard
to the public interest. Failure to act in accordance with the
general principles of public law may lead to a claim for a
decision to be judicially reviewed.”
--- End Quote ---
In this case, the contravention—if any—was minor, unintentional,
and caused by accessibility barriers. The vehicle was parked
lawfully, paid for, and caused no harm. The Council’s refusal to
exercise discretion is disproportionate and contrary to public
law principles.
Furthermore, the guidance states:
--- Quote ---
> “Authorities should formulate (with advice from their legal
department) and then publish their policies on the exercise of
discretion. They should apply these policies flexibly and judge
each case on its merits. An enforcement authority should be
ready to depart from its policies if the particular
circumstances of the case warrant it.”
--- End Quote ---
--- Quote ---
> “The enforcement authority should have clear policies,
instructions and training available on how to exercise such
authority. These policies should form the basis for staff
training and should be published.”
--- End Quote ---
To date, Solihull Council has not previously published any such
discretionary policy, nor provided evidence that staff are
trained to apply discretion fairly and flexibly. This omission
undermines transparency, accountability, and the Council’s legal
obligations under the guidance.
---------------------------------------------------------
5. Remedy Sought
I respectfully request that the PCN be cancelled on the grounds
that:
- The parking was paid for and covered the relevant time.
- The error was minor and caused by accessibility barriers.
- The TRO does not support enforcement for VRM entry errors.
- The Council has a statutory duty to act fairly and make
reasonable adjustments.
- The Council has failed to publish or apply a discretionary
policy as required under statutory guidance.
Should this appeal be rejected, I intend to escalate the matter
to the Traffic Penalty Tribunal and, if necessary, raise a
formal complaint regarding breach of the Equality Act and
failure to act proportionately.
Thank you for your attention to this matter.
Yours faithfully,
[Name]
[Email Address]
[Vehicle Registration]
[PCN Reference]
******************
#Post#: 92286--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: H C Andersen
Date: October 1, 2025, 4:23 am
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Why are you preparing formal reps, you don't have a NTO!
#Post#: 92293--------------------------------------------------
Re: Council Kiosk User Interface Issues - do I have a hope in
hell?
DIR By: advicewelcome
Date: October 1, 2025, 5:10 am
---------------------------------------------------------
--- Quote from: H C Andersen link ---
>
> Why are you preparing formal reps, you don't have a NTO!
>
--- End Quote ---
1) I am trying to eval the chance of formal reps being
successful before the 14 days option to pay £25 expires. If
there is low'ish chance of success I need to ditch this now -
its also too easy to loose paperwork or miss a letter deadline.
2) Also seeing if I can use this content - or something similar
- to make direct contact with parking dept or parking councillor
to ask for intervention in the process (within the 14 day
window) - think they have done that previously, but not sure
wuld do it in this case.
The first (1) reason is the main one - does that make sense? Is
it a comprehensive reply and what's the chances of success - 50%
or less?
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