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       #Post#: 100780--------------------------------------------------
       Brent, Not parked within bay markings (24), Cumberland Avenue
       cpz. Yellow line not visible due to water and leaves.
   DIR By: pepipoo_is_gone
       Date: December 2, 2025, 5:08 pm
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       -  Code 24 Not parked within bay markings
       -  The back wheels were indeed slightly outside the bay.
       -  The bay has a sign next to it saying it's Free Parking.
       -  There was no indication of the single yellow line at the end
       of the bay as it was (and still is) completely covered by water
       and leaves (the bit the back wheels are near).
       -  Picture of PCN link
  HTML https://drive.google.com/file/d/1Ut8WmYU0VboU-oQsDm6dLQeSl4piKJV-/view?usp=drive_link<br
       />
       -  Picture showing that the single yellow line next to back
       wheels is not visible at all link
  HTML https://drive.google.com/file/d/1tar8eB_f_EmmlrRwCuAuhPcVgdoHpBCR/view?usp=sharing<br
       />
       Is there a case here? Many thanks in advance.
       #Post#: 100782--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: fraser.mitchell
       Date: December 2, 2025, 5:28 pm
       ---------------------------------------------------------
       You may have a case, but the bay marking is clear, and the
       puddle can be seen in the photo, but how long is the puddle ? If
       the yellow line can be seen after a couple of yards, then no
       adjudicator is going to accept that you couldn't see the yellow
       line. Remember, you have to risk the full PCN penalty at
       adjudication.  Any reps you submit will be rejected by the
       council. However, wait for others to comment as they may
       disagree with me.
       #Post#: 100784--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: pepipoo_is_gone
       Date: December 2, 2025, 5:43 pm
       ---------------------------------------------------------
       There was no line visible as far as that shown pavement
       stretched. But after a few yards the pavement turns into a
       dropped kerb entryway for a building, next to which part of the
       yellow line is visible. There's no indication that yellow line
       stretches past that dropped kerb all the way to the pavement in
       question. See video
  HTML https://drive.google.com/file/d/1pY_WMUsDGsSSx7sB_BIXpbnOuC4nianL/view?usp=drive_link.
       <br>
       <br>
       Also curious if the yellow line thing is a red herring
       altogether? Since the contravention is to do with the bay
       marking, I wonder what the Brent TMO regarding bays is. This
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/bromley-pcn-is-this-not-parking-correctly-within-the-markings-of-the-bay/msg78329/#msg78329<br
       />example from Bromley gets off due to peculiar wording in the
       TMO
       requiring the bay itself to have a parking meter next to it, not
       sure if that's the case for Brent too.
       #Post#: 100798--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: fraser.mitchell
       Date: December 3, 2025, 4:12 am
       ---------------------------------------------------------
       Yes, you're right, thinking about it, because the PCN is for
       parking outside the bay markings, not for being on the yellow
       line,  but as this is a marked bay, but not subdivided into
       individual bays, my opinion is an appeal to London Tribunals
       would fail. But as I said, wait for others to input (hopefully
       !). However, don't miss the deadline for paying or submitting
       representations.
       So to my fellows out there - am I right or wrong ?
       #Post#: 100836--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: stamfordman
       Date: December 3, 2025, 6:51 am
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       Where wheels are on a yellow kine they are supposed to issue the
       higher level penalty.
       The bay markings are clear from the roadway but we usually see
       this contravention in single pay bays.
       The traffic order needs to be consulted.
  HTML https://i.ibb.co/xtdbxMKg/Screenshot-2025-12-03-at-12-44-46.png
  HTML https://i.ibb.co/Lz1MhPFq/Screenshot-2025-12-03-at-12-44-37.png
  HTML https://i.ibb.co/ZRKVQTHm/Screenshot-2025-12-03-at-12-44-16.png
       #Post#: 100845--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: pepipoo_is_gone
       Date: December 3, 2025, 7:18 am
       ---------------------------------------------------------
       Are you suggesting the defence should be the other way round?
       That the higher penalty should've been issued - therefore the
       PCN is invalid? There should be a yellow line under the leaves
       if I'm not mistaken (I can go take a picture later if it helps).
       #Post#: 100848--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: stamfordman
       Date: December 3, 2025, 7:23 am
       ---------------------------------------------------------
       No, I'm just pointing out that London Councils guidance is to
       select the higher penalty if there's a choice, not that the
       lower level one you have is wrong although we should check the
       traffic order.
       #Post#: 100851--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: pepipoo_is_gone
       Date: December 3, 2025, 7:28 am
       ---------------------------------------------------------
       Ah okay. Thank you. Any suggestion on how to find this Traffic
       Order? I've tried the council website but without much luck.
       #Post#: 100889--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: H C Andersen
       Date: December 3, 2025, 9:57 am
       ---------------------------------------------------------
       If you're struggling to find a defence, and IMO you are, then
       you might consider:
       Penalty exceeded the amount applicable in the circumstances of
       the case.
       You were parked mostly within a 24/7 free parking place;
       You were parked beyond the bay markings by a complete axle;
       You were parked on a simple SYL(whether in force at that time
       no-one's commented as far as I can see);
       Exemptions to parking within a bay contrary to its restrictions
       include boarding/alighting and loading;
       Exemptions to parking on a simple SYL are boarding/alighting and
       loading.
       A CEO should test whether an exemption applies before deciding
       that a contravention has occurred and this takes time.
       The PCN shows that the CEO observed for nil minutes and issued
       an 'instant' PCN.
       The council is required to act proportionately and fairly. IMO,
       the CEO has not by issuing an instant PCN when they should have
       observed for as long as necessary to determine that a
       contravention occurred.
       The council's position is undermined IMO because, as observed by
       other posters, the contravention is at the lower penalty, in
       effect disregarding the SYL because you were parked mostly in a
       free parking space. But this benefit did not extend to the
       observation required for parking place-related contraventions.
       IMO, the option to issue an instant PCN was not open to the CEO,
       they should have observed first.
       See what others think.
       #Post#: 101309--------------------------------------------------
       Re: Brent, Not parked within bay markings (24), Cumberland
       Avenue cpz. Yellow line not visible due to water and leaves.
   DIR By: pepipoo_is_gone
       Date: December 6, 2025, 2:54 pm
       ---------------------------------------------------------
       TY for the great suggestion. Would appreciate if people could
       help give the below draft a once-over? Many thanks.
       ---------------------------------------------------------
       Dear Sir or Madam,
       I am writing to challenge PCN [number]. I’m sincerely sorry that
       my parking has caused concern, I always try to park properly and
       within the rules and it wasn’t my intention to cause an issue.
       When I parked the night before, the end of the bay was very
       difficult to judge since that whole section of road was covered
       by standing water and leaves. The conditions were of course
       worse during the night and rain, but even in the CEO's evidence
       photos from the next morning you can still see standing water
       covering the kerb-side markings for several feet behind the
       vehicle, which reflects how unclear the area had been.
       I also noticed that the PCN was issued instantly with no
       observation time recorded. As set out in Brent’s published
       parking policy, a CEO is expected to allow a minimum observation
       period in situations where a statutory exemption to the
       contravention such as loading might apply. With no observation
       time recorded at all, it appears this assessment was not carried
       out.
       Given the visibility conditions the night I parked and the lack
       of any observation to confirm that no exemption applied, I would
       be very grateful if the council could cancel the PCN as a matter
       of fairness and discretion.
       Thank you for taking the time to consider my challenge.
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