Below are the representations I used to appeal the decision (minus the photographs i submitted in support)
I believe the PCN should not have been issued and should be cancelled.
The lack of signage in the area, its poor positioning and miniscule writing made it impossible for me to be fully aware of any terms and conditions for parking at Llanddulas beach.
I arrived at 6:30am planning to fish with my 12 year old son. It was still dark when I drove in.
Neither of the 2 signs were illuminated. Both were placed a good 8ft or more off the ground so were very difficult to spot in my vehicle with a cab over the front which further restricts visibility, even more so in the dark.
The 2 signs are placed either side of an entrance that is roughly 40ft wide. My vehicle is 7ft wide, so the closest sign would have been roughly 16ft away, while the passenger side sign would have been about 19ft away. The signs are about the size of an A4 piece of paper with lettering about 1cm size so impossible to read without binoculars and very easy to miss altogether.
Once parked there is no further warning that there are any terms, conditions, restrictions or any other mention of prohibited vehicles.
The ground at Llanddulas beach is pot holed and rough gravel and there are no ground markings whatsoever. There is no mention of the words Llanddulas Beach car park and there are no signs saying thats where you are. Infact there's no signs to say your in a car park at all
There is also no signage that suggest that Conwy council or anyone else is responsible for the land.
All the above points highlight how difficult it is to know there are restrictions to park in that area.
Furthermore, even if I had been fortunate enough to spot the small signs and stood on a box to read them, I would then have wondered if the signs were actually real or had been placed there by an irate local resident. (The councils earlier letter confirmed there had been complaints from some local residents). The signs lack of any council related symbols highlights their amateur appearance which look more like they were acquired from a sign writing shop/business and fixed up by an annoyed local resident than by any one with authority.
The signs contained no mention of Conwy council, or any TRO's, nor do they make any mention of Llanddulas Beach car park. This adds to the argument that the signs lack any authority.
I feel that if the council was taking local residents complaints seriously about large vehicles parking in that area , then the council could have solved the problem very easily if they wanted to.
The council could have installed some height barriers to restrict vehicles. These have been fitted at many coastal car parks along the A55 from Abergele up to Bangor and make it clear which vehicles can park in any area. Indeed I notice that Llanddulas already has one set of height barriers installed in one area (marked on attached photograph) so it could also have been done at this entrance to solve the problem instantly.
The council could also have erected proper car park signs like they do at other car parks I have visited in Conwy and Llandudno (2 examples attached). The usual car park signs in the area are at least 2ft x 3ft. They tell you where you are, ie Llanddulas Beach car park. They also tell you which vehicles can use the car park and then list any that can't. They explain any charges to park and any penalties if the terms and conditions are broken.
None of this exists at Llanddulas and so I believe the council should cancel this PCN and stop ticketting other restricted vehicles until they have at least made alterations to the signage present and preferably fitted height barriers so there is no confusion thereafter.
During my research I was quite surprised to read the Llanddulas council minutes from 2016 in which they were visited by Conwy council who offered to sell them llanddulas beach car park. Conwy council explained that the car park didn't meet their projected income targets and was therefore being sold. Since there are no parking charges at Llanddulas, perhaps this explains the councils approach to raising funds from the area.
Fit up some inadequate signs and then penalty charge every large vehicle when they don't spot said signs.
I also found a video on the youtube platform about Llanddulas beach car park. Among the replies one elderly motorhome owner said they had been parking there for 30 years, so clearly the location has built up a good reputation over a very long time period.
Then I came across a recent freedom of information request in which the council confirmed a complaint on 19/7/2016 in which a local resident counted as many as 18 motorhomes and similar vehicles parked over night. Its clear llanddulas has been used by many large vehicles for many years so for the council to suddenly change policy and restrict them should call for at least the measures I describe above, not the 2 tiny signs offered by the council.
In another complaint on 9/10/2016 a resident complained the signs were to small and to high up. Yet another local resident complained on 8/4/2017 that motorhomes were parked in the area with no clear signs on view and yet another resident complained on the 9/10/2017 saying the signs were to small and to high up.
When even the local residents are saying the signage is poor then there is clearly a problem!
I hope the council will take these points into account and cancel this and any other outstanding tickets.
The council should also alter the parking signage at Llanddulas and fix up barriers to make it clear that despite being free to park for the last 30 years that that is no longer acceptable. Otherwise it simply looks like the council is ignoring residents, entraping motorhomes and similar vehicles and just filling its pocket with lots of money from PCN's.
Your sincerely,
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Typical car park signs in the Conwy area.
(photographs of various Conwy Council car park signs for comparison)
(A photograph of Llanddulas parking area with height barrier fitted to the left side at the back)
The view on entering this parking area. Notice the excessively wide entrance and a large obstacle immediately in front which has since had large rocks placed around it. Both contribute to making the small signs virtually invisible.
Entering this area in the centre of the road, would place the driver to the extreme left of this picture below. They would need binoculars to read even one word of the English and Welsh versions of the sign, assuming they were fortunate enough to see it while avoiding the rocks and pot holes. At dusk and thereafter the signs have no illumination making them virtually invisible. Even in day light some people would require steps to get high enough to read the words.
By comparison there were over a dozen signs warning of the dangers of climbing on the rocks. These were placed just 3ft off the ground for maximum visibility and they appear to have the borough of Conwy name at the top to prove their authority.