The response from Ealing Council is not a statement of the law and they split the two questions into three. The Regulations about PCNs, representations and Appeals are in this document
which contains, amongst other provisions, Regulation 4(3)
The joint committee is the Transport & Environment Committee of London Councils and they made a resolution back in 2013. Regardless of whether Ealing attended or not they are bound by the resolution made. As it happens, they were represented by Cllr Bassam Mahfouz who is still a councillor in Ealing.
That committee agreed on the following resolution:
It is clear as a bell that the law is that a council in London, such as Ealing Council, must agree to accept verbal representations from people who due to their disability are unable to write. The disabled do not have to rely on family, friends, carers or social workers (is fighting PCNs in their job description?), the law says the council must help them.
Ealing Council seem to find the law to be inconvenient; accepting limited verbal representations is a small price to pay compared to the vast number of PCNs they issue. They merrily penalise drivers for not following the law but hypocritically don't want it to apply to themselves. Why don't they, as public servants, want to help the disabled?
End.
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