From: James Miller [mailto:jvmiller@talk21.com]
Sent: 05 October 2010 18:03
To: philip.hammond@dft.gsi.gov.uk
Cc: Dave.Higgs@connectplusm25.co.uk; petersilverman@cleanhighways.co.uk; mike.penning@dft.gsi.gov.uk
Subject: Section 91 Environmental Protect Act 1990 Notice

Attention of:

Mr Philip Hammond Secretary Of State for Transport

Dear Mr Philip Hammond,

TAKE NOTICE that I James Miller of  2 Tor Garden, East Ogwell, Newton Abbot, TQ12 6BG, claim that the highway described in the schedule hereto is one for which you have a duty under S89 (1) of the Environmental Protection Act 1990 to ensure, so far as is practicable, is kept clear of litter and refuse

AND TAKE NOTICE that  you have failed to keep the highway described so far as is practicable clear of litter and refuse

AND TAKE NOTICE that as I am aggrieved by the the defacement by litter and refuse of this highway I am giving you 20 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 the highway.

05 October 2010

James Miller
2 Tor Gardens
East Ogwell
Newton Abbot
TQ12 6BG

Schedule:

Significiant build up of litter.  M25 between junction 12 (M3) and juntion 10 (A3)
Significiant build up of litter.  M3 between junction 3 (beyond Kitsmead Bridge) and junction 2 (M25)
Significiant build up of litter.  M25 clockwise to M3 sliproad
Significiant build up of litter.  A3 to M25 roundabout sliproad