Thank you guys for helping me out. Here's my draft ........
I make the following representation in relation to PCN XXXXXXX
Although footway parking is banned throughout London, a highways authority has a power to lift the ban and permit footway parking. This has been done in Cromwell Street by inference of the Council. The highways authority has provided parking bays along the length of Cromwell Street which indicate that vehicles are permitted to park partially on the footpath; where the intention is that motorists may only park with two wheels on the footpath within marked bays. This is normally conveyed by signs conforming to diagram on Grove Road in conjunction with the text "in marked bays". There is no signage present which conforms to Grove Raod and reads “in marked bays” only. All that is conveyed to motorists is that the footway parking ban has been lifted from Cromwell Street and as a result, the alleged contravention did not occur. If you do not agree, please provide a copy of the resolution passed under section 15(4) of the Greater London Council (General Powers) Act 1974 showing the exact extent of the footway parking exemption.
Furthermore, I was parked on the kerb, a strengthened area of footway and regular paving slabs which is evidenced in the Council’s photographs provided. The whole length of the road comprises a strengthened footway part of which is unrestricted and part restricted. The unrestricted parts have markings which span the carriageway and footway, apparently indicating areas where cars with residence permit may park at all times with 2 wheels on the footway. Absence of the sign with restriction for pavement parking does not mean it is restricted whereas partial bay parking along the same stretch of the road in Cromwell Street pavement is allowed for.
Given the uniformity of footway construction, and as earlier stated that the highways authority has power to lift the footway parking ban, footway parking may be permitted on strengthened parts of the footway to allow cars to pass freely along without restriction. Cromwell Street is a narrow road and cars are permitted to park part-way on the strengthened part of the footway for this reason. There has been no obstruction or contravention. There was a single yellow line where parking is permitted outside of restricted times and did not apply in this situation. If the Council argues that parking on the footway is only permissible within the marked areas, then they must produce evidence in the form of photos of the required traffic signs and a council resolution giving effect to the same. Absent these, then the Council's policy, if indeed it is a published policy as opposed to an ad hoc enforcement practice, cannot support the issuing of my PCN which must be cancelled.
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