After 16 months of futile complaints to Transport for Greater Manchester, Graham Roundhill wrote to the Chief Executive with the Litter Abatement Order WARNING NOTICE shown below. Three days later the offending track-side litter was cleared.
After seeking my advice Mr Roundhill wrote as follows:
Mr David Leather
Transport for Greater Manchester
2 Piccadilly Place
Dear Mr Leather,
Section 91 Environmental Protection Act 1990 Notice
TAKE NOTICE that I Graham Roundhill of 3 Balliol Street, Cheetham, Manchester M8 0WS claim that the land described in the schedule hereto is relevant land for which Transport for Greater Manchester has a duty under S89 (1) of the Environmental Protection Act 1990, as the relevant statutory undertaker, to ensure, so far as is practicable, is kept clear of litter and refuse.
AND TAKE NOTICE that you have failed to keep the land described so far as is practicable clear of litter and refuse
AND TAKE NOTICE that as I am aggrieved by the defacement by litter and refuse of this land I am giving you five days’ notice as required by S91 paragraph 5 of the Act that I intend to make a complaint to the Magistrates Court under S91 of the Act for an order to require you to clean this land.
5th March 2012
The railway embankments adjacent to the bridges carrying Moss Bank and Crescent Road in Crumpsall, Manchester M8 over the Metrolink railway line.