London King William St/Arthur St, going north. - Driving into bus lane penalty

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Received TRO today and it's the same as posted by G&M.

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Any pointer on what I should write regarding TRO? I'm almost ready with appeal letter to PATAS but if TRO issue is of any importance, then don't want to miss. Thanks.

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PATAS hearing date given on mid of next month. Here are the grounds of appeal:

 

1) Missing sign to Diagram 953 on RHS of the road (post#27 photo#1). Tfl sent outdated photo of the site showing the presence of this sign.

 

2) The road marking "BUSES ONLY CYCLE LEGEND" (post#27 photo'2) is of the non-permitted variant of the diagram 1048.4 and there are previous PATAS cases where appeal was allowed on this basis.

 

3) PCN failed to mention the type of vehicle the route was restricted for and do not comply with 4(8)(a)(i) of Local Authorities & Transport for London Act 2003 which states

)A penalty charge notice under this section must—

(a)state—

(i)the grounds on which the council or, as the case may be, Transport for London believe that the penalty charge is payable with respect to the vehicle;

 

References given to previous PATAS Case#2120559829,2120563134 & 2130002155.

 

4) Lack of advanced warning sign that the straight ahead as per road marking (post#27 photo#3) is a restricted to certain vehicles only. PATAS case# 2110519282 is very similar to the situation and was allowed.

 

5) PCN was issued by Tfl under red route offence while TMO was originally made by City of London. London Local Authorities and Transport for London Act 2003 (4) (1) (b) and (4) (4) states that

4Penalty charges for road traffic contraventions

 

(1)This section applies where—

(b)in relation to any other road in the area of a borough council, the relevant borough council or, subject to subsection (4) below, Transport for London,

 

(4)Transport for London shall not exercise the power exercisable by virtue of subsection (1)(b) above unless they have obtained the consent in writing of the relevant borough council.

 

so unless Tfl can provide written copy of such consent from city of london, the PCN is invalid as per regulations & guidelines.

 

So this pretty much sums up my appeal. Anything else I could add, pls drop a line here.

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Administrative error