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GreenEyes
Hello, guys once again.

I left this one a bit late. For some reason I thought that if I don't appeal it within 28 days they will issue NTO and that's when I will appeal.

Just to double check, I read it yesterday and it appears that there will be no NTO? So I have couple more days to appeal.

The question I wanted to ask is shouldn't the PCN served by post be also named as NTO?




I will be appealing it based on unloading, as can be sort of seen in the picture.

Its a bit complicated this one. As husband stopped there to deliver heavy parcel but went to check if resident was at home first. The resident wasn't home so he simply returned to his vehicle and drove off.. basically no parcel was taken out of boot.., but if they have CCTV they would see that it was a matter of minutes and that husband was not engaged in anything else?




Any technical issues with their PCN?




Thanks very much.




P.S. tow appeal sent so still awaiting reply













DancingDad
You have left it late but are in time...just don't miss it.

According to PCN, loading restrictions were in force. Timed bay ???
GreenEyes
Hi, DancingDad, you are first to the rescue as always smile.gif
umm, looks like timed bay, but cant see times clearly from goggle map, says till 7pm.. will try to check again

So they don't have to say that their PCN is an NTO?

DancingDad
No NTO with a postal PCN
See last line of page 3 of the PCN
GreenEyes
ok, thanks, one point gone .. I am now starting to question the time restrictions, as it is not clear from google map. can only see half. is anyone familiar and maybe able to guess what it might say? half says till 7pm, then till 4pm

Have asked husband to check it on his way home, but that wont be for a couple of hours..
Hippocrates
Show all the PCN. Especially the part re viewing the evidence.
DancingDad
QUOTE (Hippocrates @ Wed, 21 May 2014 - 21:47) *
Show all the PCN. Especially the part re viewing the evidence.


??

Top of page two ?

I was wondering whether its worth asking for the stills as this will at least create some time.
But a bit stumped on this one otherwise.
Hippocrates
QUOTE (DancingDad @ Wed, 21 May 2014 - 22:47) *
QUOTE (Hippocrates @ Wed, 21 May 2014 - 21:47) *
Show all the PCN. Especially the part re viewing the evidence.


??

Top of page two ?

I was wondering whether its worth asking for the stills as this will at least create some time.
But a bit stumped on this one otherwise.

Thanks. PCN non-compliant IMO:

(5) The recipient of a penalty charge notice served by virtue of regulation 10(1)(a) of the General Regulations may, by notice in writing to the enforcement authority, request it—

(a)to make available at one of its offices specified by him, free of charge and at a time during normal office hours so specified, for viewing by him or by his representative, the record of the contravention produced by the approved device pursuant to which the penalty charge was imposed; or

(b)to provide him, free of charge, with such still images from that record as, in the authority’s opinion, establish the contravention.

(6) Where the recipient of the penalty charge notice makes a request under paragraph (5), the enforcement authority shall comply with the request within a reasonable time.


http://www.legislation.gov.uk/uksi/2007/34...gulation/3/made

They have changed the wording but it is still not right! Choose an office and a time and see what they say! They must comply!
DancingDad
Hippo Old Beansprout.
That is stretching it abit.
They ask you request in writing to view at one of their offices. During working hours. And state they will respond within 2 weeks and put the case on hold until viewing is complete.

I reckon any adjudicator is going to find that substantially compliant. I hope you can prove me wrong but ???
Hippocrates
QUOTE (DancingDad @ Wed, 21 May 2014 - 23:02) *
Hippo Old Beansprout.
That is stretching it abit.
They ask you request in writing to view at one of their offices. During working hours. And state they will respond within 2 weeks and put the case on hold until viewing is complete.

I reckon any adjudicator is going to find that substantially compliant. I hope you can prove me wrong but ???


smile.gif The PCN does not inform the recipient of the highlighted parts of the law. I advise the OP gets on with making the request as per the law, not as per the PCN: He stipulates the time and office and they must comply. Respond is meaningless: they could say sorry mate, no can do!

OK then: let a High Court judge decide if respond and comply mean the same thing!

Mandatory info missing from Reg. 10 PCN

The PCN does not contain mandatory information re viewing the evidence. Case Nos.: 2120293222, 2130089798, 2130149029, 2130034162, 2130397290, 2130011644, 2130430807, 2140026692, 2140006797, 2140068320. 213009616A, 2120473279

Possibly:


Register Kept Under Regulation 20 of the Road Traffic (Parking Adjudicators)(London) Regulations 1993, as amended or Paragraph 21 of the Schedule to the Civil Enforcement of Parking Contraventions (England) Representations and Appeals Regulations 2007, as applicable

Case Reference: 2130011644
Declarant: Mr James Reilly
Authority: Newham
VRM: USF8
PCN: PN0643484A
Contravention Date: 03 May 2012
Contravention Time: 07:13
Contravention Location: Barking Road
Penalty Amount: £130.00
Contravention: Footway parking (one - four wheels on footway)
Referral Date: 09 Jan 2013
Adjudicator: Neeti Haria
Appeal Decision: Allowed
Direction: cancel the Penalty Charge Notice and the Notice to Owner.
Reasons: The appellant appeared at the hearing. He admitted the vehicle was parked at the location but he explained that it was an emergency as he has a stoma and the bag had leaked and he needed to change the pouch and his clothes. He has produced evidence in support of the condition and also a letter from the Stoma Care Sister to support the fact that he struggles to cope with changing the pouch. He explained that there are no public toilets locally and it was just after 7am, he stated that they know the owner of the café where they stopped and his son (the driver of the vehicle) holds keys to the café and so was able to open it to access the toilets. He has produced a letter from the café owner in support.

Having heard from the appellant I find him to be honest and credible and it is clear that the appellant is struggling to cope with his condition, he is very distressed at having to admit he struggles to cope

In addition the appellant raised several other issues. He contends that the owner of the café over the last 15 years has regularly put out table and chairs on the area concerned and that it is private land and so contends that the Authority cannot issue a Penalty Charge Notice. He produced a letter from the owner of the café in support.

He also relies on the principle of legitimate expectation and has produced copies of the decisions of other adjudicators in support. The Authority has not addressed this issue.

He also contends that the camera used by the Authority to issue the Penalty Charge Notice is not an approved device and although the Authority has produced a certificate he contends that the certificate does not relate to the camera used to issue the Penalty Charge Notice. He has produced a photograph showing the camera and claims that there is no number on the post to identify the camera and that the camera has subsequently been removed. The Authority has addressed this point and has produced a copy of an email showing the camera has the necessary approval.

The points raised by the appellant at the hearing are new points which the Authority has not had the chance to consider. I adjourned the appeal and requested that the Authority consider the issues raised by the appellant and make submissions on the points. In addition I requested that the Authority consider the exercise of its discretion as it is my opinion that the circumstances amount to compelling mitigation.

The Authority has produced photographs as well as an aerial photograph marked up to show the location where the vehicle was parked compared with the location of St Johns car park where there are public conveniences that they say he could have used. The Authority has reconsidered the exercise of it's discretion and they do not accept the circumstances and although they accept the medical condition, they state they do not accept the circumstances amount to a medical emergency.

The appellant also appeals on the ground of procedural impropriety on the part of the Authority as he claims that the Authority has failed to comply with Regulation 3(5) of the Civil Enforcement of Parking Contraventions (England) Representations and Appeals Regulations 2007 which provides:
(5) The recipient of a penalty charge notice served by virtue of regulation 10(1)(a) of the General Regulations may, by notice in writing to the enforcement authority, request it-
(a)to make available at one of its offices specified by him, free of charge and at a time during normal office hours so specified, for viewing by him or by his representative, the record of the contravention produced by the approved device pursuant to which the penalty charge was imposed; or .
(b)to provide him, free of charge, with such still images from that record as, in the authority's opinion, establish the contravention. .
(6) Where the recipient of the penalty charge notice makes a request under paragraph (5), the enforcement authority shall comply with the request within a reasonable time."

The appellant wrote to the Authority on the 10 June requesting an appointment to view the CCTV footage at the offices of the Authority in Dockside Road. He states that the Authority refused his request and he states that Penalty Charge Notice states the CCTV footage can only be viewed at one office.

I find the failure by the Authority to comply with Regulation 3(5) to be a procedural impropriety on the part of the Authority. The Regulation clearly states the recipient of a Penalty Charge Notice is entitled to have made available the record of the contravention at one of the offices of the Authority specified by the recipient of the Penalty Charge Notice. The limitation of this right to the office stated in the Penalty Charge Notice amounts to a procedural impropriety on the part of the Authority.

Accordingly I allow the appeal.

Since I am able to determine the appeal on the above point it is not necessary or proportionate for me to address the other points raised by the appellant.
GreenEyes
doesn't it say that it can be viewed at normal hours for the office chosen? so why not compliant?

Also, I think its a good idea to request still images by email even just to put a case on hold until they reply? Any thoughts?

Hubby still not home (visiting friend, while I am working hard tongue.gif ) so no update on loading hours, but he insists that loading was allowed at the time he stopped, so cant we just win on that point alone? I already have witness statement from his manager, confirming that he was making delivery.
Hippocrates
Read the law and your PCN! And my emboldened parts. Does it tell you that you can specify the time? Does it tell you they will comply?

If you can answer yes, then I will give up!

Just make the request by e-mail and fast. You specify the time, office and they must comply. See the case. Ask to view the images at an office. I bet they are bluffing re choice! Test it!
DancingDad
If loading is allowed at 17.49 on the day in question, you can win on that alone.

I'm not going to argue with H old beansprout about asking to view at office/time/day of your convenience. Certainly worth testing.

But I still reckon H is wrong on PCN wording. Case cited tried to restrict to one office ON the PCN, then compounded that by refusing office of choice.
Here IMO PCN does comply, just. Whether they will comply to a request does need testing
Hippocrates
Look: it is simple. You always test. DD is an acknowledged top expert re tactics. Look at Gliddon Road case won last week. EA were so full of it as won a case at High Court they forgot to respond in detail to reps! And other things. Councils are human beings after all, so I am told!

My points are not tenuous. I accept they are fine as in delicate. But, one can only make reps and see what they say. Request first of course. If they say no, you have a stronger case. I feel it in my bones they only offer one office.
DancingDad
QUOTE
I feel it in my bones they only offer one office.

one should always follow Hippo's feelings
Hippocrates
QUOTE (DancingDad @ Wed, 21 May 2014 - 23:48) *
QUOTE
I feel it in my bones they only offer one office.

one should always follow Hippo's feelings

I may be wrong, but they have lost cases re wording and I reckon they have only paid lip service to the regulations. Needs testing!

Check their list of municipal offices, choose the nearest one to you like a library, stipulate the time and date and see what they say!
GreenEyes
ok, so I email them specifying date, time and the office and my case will be on hold, until I see the video, right? That's good with me.

Although, few years back I tried to use this point and adjudicator wasn't interested, as well as in another case (newham) I tried using the Secretary of case guidance and that council needs to have regard, when using CCTV when PCN can be enforceable on foot, again adjudicator couldn't care less. This Newham case, DD was actually helping me. I lost through postal and then appealed and had hearing in person and only won on unprovable Argos collection point..

Anyway, I will do that, as it will put the case on hold and if they do reply with different office to the one requested, it will help the case for sure.. I wonder how to find out which one office they do, so I request a different one smile.gif)

quick question, how do I check the list of their offices to view this?
Hippocrates
Check their website for council offices - save for burial places. I refer to one decision!
GreenEyes
ok, I think I found it http://www.towerhamlets.gov.uk/lgsl/951-10...il_offices.aspx
DancingDad
It isn't a case whether CCTV should be used... fact is the things are. Twas always an iffy point.
But council not following regs is a whole different ball game to not having regard to guidance

Send the email but, DO NOT miss deadline unless you have in writing that they have the case on hold..and post that note up so we can see it...just in case.

Hopefully with this one, hubby will be right on loading times.
GreenEyes
should I actually call each one tomorrow and ask if its possible to view it there? smile.gif of course without giving any details

well if hubby is wrong on loading times, I have nothing to appeal with, so will have to rely that they kept their promise and put the case on hold. I can always show adjudicator that I had reason to believe my case was on hold as per their PCN and provide email copy with time it was sent etc.. would that work? so if they don't out the case on hold that would make my case stronger, right?
Hippocrates
No calls. Writing/e-mail only! Read the law!


Dear Sirs

Ref: PCN......VRM...................

I wish to view the video evidence at ....................office and at......................time.

I look forward to your confirmation of the same.

Yours


Give them 7 days.
GreenEyes
I meant call them to find out if any office will actually say that they don't offer such service, so I will then request via email to see it at that office?
Hippocrates
QUOTE (GreenEyes @ Thu, 22 May 2014 - 00:19) *
I meant call them to find out if any office will actually say that they don't offer such service, so I will then request via email to see it at that office?

Just choose your office. Read the law! Keep it simple. Don't give them ways to wriggle out. You choose. No phone calls!
GreenEyes
ok, thanks, will email them early tomorrow
Hippocrates
Nite!
DancingDad
Deadline is 26th May. Next Monday (someone check me pls)
So send email tomorrow and make online challenge Monday at latest unless you have a solid statement from them that case is on hold.

Even if on monday all you send is procedural impropriety. I cannot challenge fully because I have requested to view video and TH have not complied with regulation ?? and confirmed that I may.

Keep in mind that if you do not challenge inside the deadline, you won't get to see the adjudicator.
hcandersen
Personally, I think H is reading into the regs meanings which are not there.
In this context, there is no requirement under the regs to reproduce the regs' wording, the duty is to include in the PCN 'the effect of the regulations'. IMO, this will be as much to do with reasonableness as explicit wording. I would not want to gamble my money on an adj finding that the authority will respond within 2 weeks is not the effect of 'shall comply within a reasonable time'.
PCN dated 28th is presumed served on 30th, therefore last day of discount has passed and last day for making reps is 27th.
Yesterday, I received a parcel from John Lewis. It was quite bulky. I'd ordered it online only 2 days earlier. Advert over.
But the point is that the parcel was NOT delivered by a JL van with 2 hefty loaders, it was delivered by a senior citizen driving an unliveried Ford Focus. As it happens, I was returning to my house at exactly the time he drove up and so he went straight to the rear passenger area, which was stuffed with parcels, extracted mine, gave it to me, took my signature and drove off. In such ways is business conducted in the 21st century which allows retirees and others to supplement their income. And what's the point of this?
Had he not been able to park immediately outside the house, would he have lugged my parcel, single-handed and possibly for 100+m there and back, to my door only to find that no-one was in, or adopted the old adage that time spent in reconnaissance is seldom wasted and seen whether anyone was in first?
The moral of this story: stop diving straight in to procedural issues and discover and test everything about the events first to see if the b****y contravention even occurred.
Hippocrates
I have admitted that my point is fine and delicate. However, the regs. are there for a purpose so that must be tested. While I appreciate HCA's knowledge and experience, I see nothing wrong in attacking on all fronts at the same time - it wins cases!
DancingDad
QUOTE (hcandersen @ Thu, 22 May 2014 - 07:25) *
...........
The moral of this story: stop diving straight in to procedural issues and discover and test everything about the events first to see if the b****y contravention even occurred.


We are waiting for Greeneyes' advise on whether or not loading restrictions were in force.
If they were, procedural may be all we have.

GreenEyes
ok, bad news, hubby said the sign says no loading 4-7 sad.gif so mad at him now. if I knew this we should have paid at discounted rate.. but he was so sure loading was allowed. in reality he probably never checked it properly, now says he never seen such a sign before. so where do we stand? I don't know on what basis to make reps..
GreenEyes
is there any way to make them reoffer the discount?
hcandersen
So we're discovering more about the events, although we've yet to see this in the form of the authority's evidence as opposed to the driver's recollections which are notoriously inaccurate.
His reticence in this matter has now left you with no choice other than to fight all the way.
GreenEyes
well, events are the same really, its the fact that he didn't read the sign properly, which is very frustrating. just seen some loading sign and assumed it was ok, because more often they allow loading after 5pm or so..

sorry guys for misleading you, I didn't expect such a turnaround. any suggestions for appeal points? I understand the need to fight all the way but with what? smile.gif
DancingDad
Have you sent the email requesting video evidence ??

If not do so, it's your best chance on what we have.

One question from Hubby's memory.

When he stopped, opened the boot and went to check delivery. How long was he away for and how far from car ??

Minimal contravention is one defence.
Second possibly is that he only stopped long enough to check sign, realised error and left.
Third is confusion of signs. Parked in clearly marked loading bay for purpose of loading, glanced at restriction plate, started process, then realised he'd misread plate and left immediately.

None are strong but IMO better to get in a weak challenge with added procedurals then challenge purely on procedurals
Incandescent
QUOTE
any suggestions for appeal points?

Yes, use of CCTV in a place where there is no problem for CEOs to patrol, in direct contradiction to the Statutory Guidance on CCTV enforcement. Check to see if Blue Badge holders can wait there, but really whether they can or not, appeal on "failure to have regard to Statutory Guidance, contrary to Section 87 of the Transport Management Act 2004"

extract from Statutory Guidance 2008
6. Where the Guidance says that something must be done, this means that it is
a requirement in either primary or secondary legislation, and a footnote gives
the appropriate provision. In all other instances, section 87 of the TMA
stipulates that local authorities must have regard to the information
contained in this Guidance.

and also
Enforcement using Approved Devices
48. TMA Regulations give the power to authorities throughout England to issue
PCNs for contraventions detected with a camera and associated recording
equipment (approved device). The Secretary of State must31 certify any type
of device used solely to detect contraventions (i.e. with no supporting CEO
evidence). Once certified they may be called an ‘approved device’. The
Secretary of State recommends that approved devices are used only where
enforcement is difficult or sensitive and CEO enforcement is not practical.
Approved devices should not be used where permits or exemptions (such as
resident permits or Blue Badges) not visible to the equipment may apply
.

Be aware that it is not a procedural impropriety to ignore the guidance, it is failure to "have regard to" it. This is a legal duty, and a council that cannot demonstrate it has had regard can be considered to have committed a PI.

So there is your appeal. Also there may be PCN errors
GreenEyes
yep, requested to view CCTV today. as far as I know he was very quick prob 2 mins.. but he had to go across the road. I guess it depends what they have on video, so fingers crossed. I guess I have to wait till I see the video before making reps? They themselves say that it will be put on hold, so surely I should still have chance to see adjudicator?

regarding having regard to SOS, I am familiar with this and thanks for suggesting it as I will have to use it for sure. The last time I used it though, adjudicator did not want to know and I kept saying that they did not have regard but he saw it differently and was getting annoyed smile.gif
DancingDad
Right.
If he crossed road, chances are video didn't track him...lets work on that.

He parked in a clearly marked loading bay relying on large road markings.
Opened boot to check address, started to go to address to check if anyone home.
As crossing road realised he hadn't checked loading restrictions so looked back. Realised error so returned immediately and left.
Any contravention was unintentional, minimal and largely because of relying on road markings.

Then chuck in the PI re video and regard to guidance. The second isn't what they had regard to, it's how they answer it that opens doors.

Do not wait for video viewing before making reps. Meet the deadline!!!
Incandescent
QUOTE
regarding having regard to SOS, I am familiar with this and thanks for suggesting it as I will have to use it for sure. The last time I used it though, adjudicator did not want to know and I kept saying that they did not have regard but he saw it differently and was getting annoyed


Well, he had no right to get annoyed as there is a clear legal duty in the Traffic Management Act 2004 to have regard to the Statutory Guidance. Clearly PATAS cannot get staff who know very much if anything about parking law these days !!. Yes, they can disregard the guidance but that is a separate issue, it is failure to have regard to it that is the procedural impropriety. To be fair, one or two adjudicators do understand this, but they are few in number, I'm afraid.
Hippocrates
And/or the failure to show that they have had regard.
hcandersen
You've requested to view the video which means, metaphorically, that you can now put the horse back in front of the cart.
GreenEyes
ok, the exact what has happened is this: Hubby stopped in loading bay, got out and went to 398 Roman road which is across the road, when no answer, he came back, went to the boot to move this parcel to the back and check next address, then drove off. The whole affair took about 2-3 mins. How can I explain that he went to open his boot AFTER allegedly seeing the sign?

umm, maybe, but please dont shout at me, I could say that he was meant to pick someone up from that address, but the person wasnt home? maybe minor or elderly? so assited boarding? but I think Tower Hamlets removed this exception from their TMO. The last time this really happened, few years back, adjudicator said that Tower Hamlets TMO dont have this clause (actually they removed it) and was going to loose my case and then I won on some technical point instead, they sent charge certificate before time for appeal was up.
DancingDad
It's never a good idea to tell porkies. They have a habit of bouncing back and this removes all credibility.

Better of IMO, telling the truth, honest mistake rectified as soon as possible (which is born out by that he stopped loading, simply started the process) when realised, admittedly belatedly, that he had misread sign.

Then add that requested to view video...refused/not answered (whatever applies) etc.
GreenEyes
Hi guys, this was the automatic email I received from TH, am I safe to wait for their reply first before submitting reps? I guess this counts as my case being put on hold? This will give more time to prepare reps and maybe after viewing will definitely see what they have on camera? Otherwise today is the deadline, and its really mad here with kids at home, so if possible i'd prefer to wait for reply. What are your thoughts on it?

"Thank you for your e mail which has been received by Tower Hamlets Parking Services.A response will be sent to you by post as soon as possible. We are obliged to reply within 56 days.

If you have not provided the Penalty Charge Notice number and your full postal address, please resend your email with this information.When we receive your e mail with the required information your case will be put on hold pending investigation.

Thanks.

Parking Appeals."
DancingDad
Nope
Unsafe to rely on automated replies

Lets get some reps into them before deadline expires.
GreenEyes
but what if the camera will show that he went all the way to the flat and put the card through the letter box? then I have no chance with adjudicator. All I have at the moment is that he parked walked across the road looked back at the sign to double check, realised its different sign and loading not allowed, quickly returned to his car (checked something in his boot, what??) and quickly drove off, so minimal contravention. This means 100% lose with TH as they always reject, even with obvious win cases.
And Adjudicator may also say that well you should check before crossing the road.

Whereas, if TH ignore their email re: case being held and still issue charge certificate, surely I can still go to adjudicator? how would any member of the public know not to rely on email from TH? they would simply wait for the video before making reps, especially as their trustworthy council confirmed it via email.. therefore adjudicator may find TH actions misleading etc.., which will add strong point to my case?

I understand there is a question of why I left it so long before asking for video, but this doesnt break any of the TH rules regarding appeal and can be expected with people being busy with work and family commitments..
DancingDad
Until you see the video we will not know.

But if you do not make reps, you may never see the video or an adjudicator.

The regs are clear, you have a 28 day deadline and while that can be varied with something specific relating to an enquiry, a generic response is open to question.
We see all too often, people who had a good case who have delayed for some reason, perhaps even a good reason but are now waiting for the bailiffs to knock.

The only safe route is to challenge within deadlines unless there is something absolute in writing that a judge will accept. Because that is the potential end result of missing deadlines. And even getting to the judge could mean that you have to commit perjury.
GreenEyes
ok, any ideas how to make safest reps at this point? Should I just be vague, to avoid lying? basically how to ommit the fact that he went all the way the door, so that I can still add it if it comes on video?

does it help that he has residents permit and can park in all TH for 3 hours?

i mean, if loading is not allowed, is parking allowed there? just a thought

ok, maybe not, as says loading only and the yellow bit of the sign seems to say till 7pm...
GreenEyes
here is the start to the reps, any advice and especially additions very appreciated, as I have hard time thinking smile.gif I am trying not to give too much detail, in case they have exact events on camera, so after/if I view I will then go into detail as to how far I got out of the vehicle.. hope this makes sense

Dear Sir or Madam,

I would like to appeal PCN number: XXX on the ground that no contravention occurred.
On DATE at TIME I have stopped in the loading bay assuming loading was allowed. However, when I got out of the car I looked back at the sign and realised that there were limitations on loading times. I have not commenced any loading / unloading activity as I am sure can be seen from your CCTV footage.
I have requested to see CCTV footage of the alleged contravention and I am yet to receive response.
I would also like to question the necessity to use CCTV for PCN purposes in this location, when nothing prevents traffic warden from doing it and it is not dangerous.
DancingDad
QUOTE (GreenEyes @ Mon, 26 May 2014 - 19:35) *
here is the start to the reps, any advice and especially additions very appreciated, as I have hard time thinking smile.gif I am trying not to give too much detail, in case they have exact events on camera, so after/if I view I will then go into detail as to how far I got out of the vehicle.. hope this makes sense

Dear Sir or Madam,

I would like to appeal PCN number: XXX on the ground that no contravention occurred.
On DATE at TIME I have stopped in the loading bay assuming loading was allowed. I relied on the large loading legend written on the carriageway.
However, as I left the car I looked back at the sign and realised that there were limitations on loading times.
Accordingly I returned to the car and left immediately. Any contravention was unintentional and minimal.

Having received a postal PCN I investigated the legislation and statutory guidance behind this manner of enforcement.
I have requested an appointment to view the video but to date have received nothing but an automated reply that I believe would be unsafe to rely on.

Statutory guidance only recommends CCTV enforcement in areas that would be difficult to cover with traditional enforcement officers.
I question the necessity to use CCTV for PCN purposes in this location, when nothing prevents traffic warden from doing it and it is not dangerous.
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