Template for a UK Local Authority Smart Traffic Management Complaint

A template complaint to a Local Authority on failure to notify or consult the Public on the instalation of Smart Traffic Managment Systems

(name of local authority) reference: Complaint xxxxxxx sent xx/xx/2025 this revision 5/Apr/2025.

(name of local authority) uses Smart Traffic Management Yunex systems at 24Ghz radar and Wifi pulsed data packets, and Lidar-Laser capable of Car cabin space resolution and surveillance, it appears that (name of local authority) have failed to observe several Government Act legislation to protect the Public from such harm.

Complaint 1. A list of Traffic management issues that (name of local authority) failed to address as they failed to implement the legal requirement within the Telecommunications Act 2003Schedule3A which have gone without Public Notification or consultation as the legally required Notification, and Public consultation was not implemented, and a (name of local authority) that has failed to facilitate legally required notification, and consultation.

There is (name of local authority) failure where the Telecommunications Act Schedule 3A requirement for Public notification and consultation appears to have not been observed for the installation of (name of local authority) Traffic Management system infrastructure at anytime.in the past

I am not aware of any (name of local authority) Public notices to inform the Public of proposed Smart Traffic management systems infrastructure, or of any existing Traffic Management systems, or any Public consultations by (name of local authority) on Smart Traffic Systems 3 mtrs above ground.

Complaints 1a,1b,1c are that (name of local authority) has not notified, or consulted the Public on their Traffic Management systems above 3mtrs and consequently denied the right to object, or comment, particularly as Smart Traffic Management is significantly different to previous systems especially the addition of invasive radar and laser scanning irradiation, and data harvesting surveillance which requires Public consultation as in contravention of the Telecommunications Act 2003 Schedule3A requirement Para75-79

Just to impose these Smart Traffic Systems by diktat is not “democracy at work”, but more ”Cavalier Health & Safety procedures”, and the encroaching detriment of my Civil and Human rights, and the reason why the UK has Government legislation to protect the public

Complaint 1a. It is (name of local authority)’s Public responsibility remit to address the lack of Public notification or consultation for Traffic Management systems above 3mtrs as listed in the Telecommunications Act 2003 Schedule 3A Pata75,76,77

(name of local authority) are in contravention of the Telecommunications Act 2003 by not implementing Public Notification or consultation as required in Schedule3APara75.

The (name of local authority) requirement (as “operator”) to consult the Public has not been conducted. I,e, Para75 1b; where “the whole or part of the apparatus is at a height of three metres or more above the ground.”, to “attach a notice”, “to every major item of apparatus installed”.

Relevant Government Legislation detail
Telecommunications Act 2003 Schedule 3A Para75
https://www.legislation.gov.uk/ukpga/2003/21/schedule/3A
Para 75. 1,2
75(1)This paragraph applies where—
(a)an operator has, for the purposes of the operator’s network, installed any electronic communications apparatus, and
(b). the whole or part of the apparatus is at a height of three metres or more above the ground.
(2). The operator must, before the end of the period of three days beginning with the day after that on which the installation is completed, in a secure and durable manner attach a notice—
(a). to every major item of apparatus installed, or
(b). if no major item of apparatus is installed, to the nearest major item of electronic communications apparatus to which the apparatus that is installed is directly or indirectly connected.
(3). A notice attached under sub-paragraph (2)—
(a). must be attached in a position where it is reasonably legible, and
(b). must give the name of the operator and an address in the United Kingdom at which any notice of objection may be given under paragraph 77(5) in respect of the apparatus in question.
(4). Any person giving such a notice at that address in respect of that apparatus is to be treated as having given that address for the purposes of paragraph 91(2).
(5). An operator who breaches the requirements of this paragraph is guilty of an offence and liable on summary conviction to a fine not exceeding level 2 on the standard scale.
(6). In any proceedings for an offence under this paragraph it is a defence for the person charged to prove that the person took all reasonable steps and exercised all due diligence to avoid committing the offence.

None of which appears to have been done for decades or any required consultation, as contrary to the Telecommunications Act 2003 Schedule 3A, and in particular contravention with the current significant technology changes implementation of the (name of local authority) Smart Traffic Management Systems Infrastructure, using Lidar laser 24 laser diode coherent, collimated, an aligned phased matrix, at more than one scanning location per crossing, and the use of 24Ghz radar.

This Yunex Smart Traffic Management “Fusion” System has had no Public consultation on the novel as well as the “Fusion” combined enhancement using coordinated various technologies that are invasive, imposed, and unconsented scanning of the Public for ID, while that very Pubic has no say no consultation, no notification in its implementation as government legislation has been ignored by those Local Authorities required to observe that legislation.

Complaint 1b. My right to object, or to be notified, or to be consulted on any significant changes especially with Smart Traffic management systems has been denied as defined in Para76,77 as a Government legislation requirement.

Complaint 1c. That right to object is defined by being a structure three metres or more above the ground, “is substantially different from the new apparatus” as using new scanning technology Lidar laser, 24Ghz radar and 25Ghz Wifi apparatus, and inclusive of hazardous “flicker”, and additional poles for Lidar and Radar, and also in significantly different pavement positions as obstruction. Para 76, 77.

All of which as denied Notification-Consultation objection on grounds of 1. Health and Safety as well as 2. Visual amenity detriment, 3. Street furniture obstruction, 4. At a time when preexisting sensor wires are already working and available in the road surface but made redundant for an untested, unconsented, unconsulted, unproven safety, imposed new “Fusion” technology.

Relevant Government Legislation detail.
The “operator” defined as (name of local authority) who commissioned, granted permission for installation, and as for their use, for financial receipt, installed for their purpose, collecting fines, and other charges as sole “operator”.
Telecommunications Act 2003 Schedule 3A Para76
PART 12
Rights to object to certain apparatus
Introductory
Para76; This Part of this code makes provision conferring rights to object to certain kinds of apparatus, and makes provision about—
(a). the cases in which and persons by whom a right can be exercised, and
(b). the power and procedures of the court if an objection is made.
Para77
(5. ) A right to object under this Part of this code is available where—
(a)electronic communications apparatus is kept on or over land for the purposes of an operator's network, and
(b). the whole or any part of that apparatus is at a height of three metres or more above the ground
(7). There is no right to object under this Part of this code in respect of electronic communications apparatus if the apparatus—
(a). replaces any electronic communications apparatus which is not substantially different from the new apparatus, and
(b). is not in a significantly different position.
https://www.legislation.gov.uk/ukpga/2003/21/schedule/3A

Traffic Management Systems issues that (name of local authority) failed to address as they failed to implement the legal requirement within the Telecommunications Act 2003Schedule3A Para75,76,77 which have gone without Public notification or consultation.

Complaint 2. The Health and Safety Executive not consulted

Complaint 2a. A (name of local authority) lack of notification, or consultation that has also denied my Civil, and Human rights within the Social Care Act 2012 for health and safety, privacy, imposed irradiation, and surveillance issues.

Complaint 2b. A (name of local authority) lack of consultation with the Health and Safety Executive Para58.6 that can impact the health and safety of the Public.

Non-existent consultations with Health & Safety Executive that did not take place, which if consultation had taken place would have disclosed Health and Safety issues on Radiation protection functions Para58.

A lack of adhering to the Health and Social Care Act 2012 Para 58 on Health and safety and to protect the public Para58.5,6 “must consult”- “Health and Safety”

Relevant Government Legislation detail.
Health and Social Care Act 2012
https://www.legislation.gov.uk/ukpga/2012/7/section/58
Para 58 Radiation protection functions
(1). The appropriate authority must take such steps as it considers appropriate for the purposes of protecting the public from radiation (whether ionising or not).
(2). The steps that may be taken under subsection (1). include—
(a). the conduct of research or such other steps as the appropriate authority considers appropriate for advancing knowledge and understanding;
(b). providing technical services (whether in laboratories or otherwise).;
(c). providing services for the prevention, diagnosis or treatment of illness arising from exposure to radiation;
(d). providing training;
(e). providing information and advice;
(f). making available the services of any person or any facilities.
(3). The appropriate authority may do anything which it considers appropriate for facilitating, or incidental or conducive to, the exercise of any of its functions under this section.
(4). The appropriate authority may make charges (whether or not on a commercial basis). in respect of anything done by it under this section.
(5). In the exercise of any function under this section which relates to a matter in respect of which a Health and Safety body has a function, the appropriate authority must—
(a). consult the body, and
(b). have regard to the body's policies.
(6). Each of the following is a Health and Safety body—
(a). the Health and Safety Executive;
(b). the Health and Safety Executive for Northern Ireland.[F1(c).the Office for Nuclear Regulation.]
(7). In subsection (2).(f)., “facilities” has the same meaning as in the National Health Service Act 2006.
(8). In this section, “the appropriate authority” means—
(a). the Scottish Ministers to the extent that the functions are exercisable within devolved competence (within the meaning of the Scotland Act 1998).;
(b). the Department of Health, Social Services and Public Safety in Northern Ireland to the extent that the functions relate to a transferred matter (within the meaning of the Northern Ireland Act 1998).;
(c). the Secretary of State in any other case.
(9). In this section, “the public” means—
(a). where the appropriate authority is the Secretary of State, the public in Wales, Scotland and Northern Ireland,
(b). where the appropriate authority is the Scottish Ministers, the public in Scotland, and
(c). where the appropriate authority is the Department of Health, Social Services and Public Safety in Northern Ireland, the public in Northern Ireland.
(10). This section does not apply in relation to England.

A list of Traffic Management Systems issues that (name of local authority) failed to address as they failed to implement the legal requirement within the Health and Social Care Act 2012 which has gone without Public Notification or consultation with the Health & Safety Executive not consulted as legally required Notification. Para 58 Radiation protection functions were not implemented.

A (name of local authority) that has failed to facilitate legally required notification, and consultation with that Health & Safety & Executive. “must—(a). consult the body. i.e. Health & Safety.

Complaint 3 (name of local authority) has failed to implement the Social Value Act 2012 Para1.3 “might improve environmental well-being “.

A failed requirement that may have caused the contrary “detrimental to well-being” due to unresearched health hazards from Smart Traffic Management Systems that use Lidar laser 24 laser diode matrix in coherent collimated alignment with known issue of induced eye, blood, neurological and skin health issues, and similar with 24Ghz pulsed data packet radar and 24Ghz WiFi irradiation 24/7 at these Smart traffic Systems, especially for those road users who are more vulnerable; pacemakers, the frail, the comorbidity vulnerable, those with compromised blood disorders, and the EHS EMF hypersensitive who are susceptible to 24Ghz radar irradiation, or to cause carcinogenic eye damage as well as blood disorders from skin penetrating laser, (2cm depth) or 24Ghz radar (approx. 2cm depth as all it needs to cause health impact.)

All of which as examples of possible objection or comments denied Public notification and supressed consultation that did not take place that may cause health detriment by not observing the Government legislation.

I list examples but not necessarily part of my complaint of (name of local authority) denied, and/or suppressed Public objections as well as Health & Safety executive due to a failure to implement the Social Value Act 2012 on environmental well-being.

The listed examples define what has been denied by a failure by (name of local authority) to implement Government legislation.

There is evidence that illegal Class 4 laser diodes >500mW Sicore2 Osram Oslon Black Class 3b have been used as well as multiple “3D” cross-irradiating 24Ghz radars which if used with the over specification capacitors is capable of large surge impact power beyond requirement that can be used even at “lower power” to identify who is in the car (a Car shell Faraday Cage does not stop that excess power) as evidence of a capability for the Lidar-laser, and Radar for excessive laser, and radar irradiation, beyond design.
A Human health disaster?

Laser and Radar are used as military hardware as that is their capability, as such any Civil use of such technologies clearly requires (name of local authority) to observe the Social Value Act 2012 and ensure environmental well-being.
That has not happened.

Even a civil airport scanning is only for seconds, but not to subject victims for hours in a traffic jam irradiation or pedestrians irradiated every time they cross the road standing for minutes crossing at Traffic Lights.
A laser diode above Class1 only takes a millisecond to blind.

Not least supposedly multiple Class1 lasers in phased cumulative alignment as a 24 matrix are not safe.

All of which as denied Traffic management Systems Public consultation and failed observance of the Social Value 2012 Act to assure that the proposal is “an improvement of well-being”, but due to denied notification, denied objection, denied debate, and denied ability to raise well-being issues within the Social Value Act 2012 that has supressed any assessment of Smart Traffic Management systems with a (name of local authority) that has failed to observe the requirements of the Social Value Act 2012 Chpt3 a contrary probably as “detriment to well-being”.

Relevant Government Legislation detail.
Public Services (Social Value) Act 2012 CHAPTER 3
https://www.legislation.gov.uk/ukpga/2012/3
An Act to require public authorities to have regard to economic, social and environmental well-being in connection with public services contracts; and for connected purposes.

1. Contracts of relevant authorities

2. (1). If a relevant authority proposes to procure or make arrangements for procuring the provision of services, or the provision of services together with the purchase or hire of goods or the carrying out of works, by—

(a). entering into a public services contract that is not a contract based on a framework agreement, or
(b). concluding a framework agreement as regards which public services contracts are likely to constitute the greater part by value of the contracts based on the agreement, it must comply with the requirements in subsections (3), (6) and (7) before starting the process of procurement
(3). The authority must consider—
(a)how what is proposed to be procured might improve the economic, social and environmental well-being of the relevant area, and
(b)how, in conducting the process of procurement, it might act with a view to securing that improvement.
(6). The authority must consider under subsection (3)(b) only matters that are relevant to what is proposed to be procured and, in doing so, must consider the extent to which it is proportionate in all the circumstances to take those matters into account.
(7). The authority must consider whether to undertake any consultation as to the matters that fall to be considered under subsection (3).

Complaint 4; Knowingly or unknowingly although that is not a legal excuse, (name of local authority) Smart Traffic Management System as evidence in my FOI request for the technical details of their Smart Traffic Systems evidences the use of multiple Yunex apparatus Traffic systems.

Yunex may be the name on the (name of local authority) Smart boxes on Traffic Management Systems 3mtrs above the ground, with Lidar, and Radar apparatus, but inside it is Chinese made Thale-Huawei circuitry, over-specification hardware, with software “keyhole” algorithms that the Government consider puts the nation at security risk such as to ban them in the UK.

There is disassembled Yunex apparatus evidence that Thales-Huawei components, circuit boards, some as OSRAM Sicore Oslon Black Class3b laser diodes are capable of well above lethal Class4 500mW laser phased coherent diodes, and microchips are present in the Yunex Smart Traffic System especially using components way beyond design parameters for any Traffic Management Systems which then begs the questions what are those components doing there ,and emphasises my complaint that (name of local authority) did not have a required notification-consultation that then suppressed the insight of the Public, which has allowed those Yunex Traffic systems to be deployed that should have never been installed.

That is why planning proposal have notifications, and Public consultations prior to considering installation and nationwide deployment.
(name of local authority) have failed to implement the Government ban on Huawei components and software as they use Chinese Yunex-Thale-Huawei circuitry.

By failing to observe the Government section 105Z1 of the Communications Act 2003 legislation Huawei ban that has compromised all that use the Yunex-Thale-Huawei Traffic Management systems.

This is the foreseen consequence of having no Public notification, and no Pubic consultation which then becomes detrimental unforeseen consequences, that could have been avoided.

Further listed examples that define how (name of local authority) has failed to implement the above Government Legislation (5 listed) legal requirements has negated those consultation issue leaving the Public vulnerable.

Unrequired or excessive heatsinks, lethal Class4 >500mW banned lasers identified, oversized capacitors, and inductors that can allow well beyond specification power surge on demand, Laser diode phased coherent irradiation in focused arrays, and, components using military grade “Radiation Hardened” for what purposes?

Not least some expert analysis as that Smart Traffic system that achieves way beyond specification with 137 watts of lethal irradiation power as another Health and Safety issue that was not consulted on by (name of local authority) to Health and Safety Executive .

It is no surprise to find Thales-Huawei are the prime manufactures for energy beaming, and laser military hardware. A reason for the ban on Huawei as that also included hidden software “keyhole” access vulnerability.

(name of local authority) have failed to observe the Huawei ban by Government legislation 105Z1 of the Communications Act 2003,

Relevant Government Legislation detail.
Huawei to be removed from UK 5G networks by 2027
https://www.gov.uk/government/news/huawei-to-be-removed-from-uk-5g-networks-by-2027

however the (name of local authority) legal transgression is in the use of Huawei components as banned within Government legislation updated Communications Act 2003.

Huawei issues;
section 105Z1 of the Communications Act 2003,
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1110248/Final_Huawei_Designated_Vendor_Direction.pdf

Complaint 5; It is clearly defined in the Road Traffic Regulations Act 1983 Section 23

Before establishing, altering, or removing a crossing a [F3strategic highways company or a] [F4local traffic authority]—
(a) shall consult the chief officer of police about their proposal to do so; [F5and]
(b) shall give public notice of that proposal; F6..

None of which has ever taken place, especially the installation of Yunex-Thales-banned Huawei Smart Traffic Management Systems using Lidar-laser, and 24Ghz radar as significant alteration to those Traffic crossing infrastructure systems. Not least as novel, imposed, unconsented private data collection, facial recognition, accessed engine management systems ID, mobile phones and any other invasive unconsented scanning for ID.

So significant as it requires Public Notification, Objection, and/or consultation.

Relevant Government Legislation detail for Complaint 6.

Road Traffic Regulation Act 1984 Part 3 Section 23 CROSSINGS AND PLAYGROUNDS Page 497
Section23
F2 [( 1 )A [F3strategic highways company or a] local traffic authority may establish crossings for pedestrians on roads for which they are the traffic authority, and may alter or remove any such crossings.
The crossings shall be indicated in the manner prescribed by regulations under section 25 of this Act.]
(2) Before establishing, altering, or removing a crossing a [F3strategic highways company or a] [F4local traffic authority]—
(a) shall consult the chief officer of police about their proposal to do so; [F5and]
(b) shall give public notice of that proposal; F6...
https://www.legislation.gov.uk/ukpga/1984/27/section/23

also if applicable;
Complaint 6; Due to no (name of local authority) response since my complaints email xx/xx/2025
A chronology of failed response to my complaints.
An inability to respond to my complaints made on the xx/xx/2025, other than an (name of local authority) Corporate reply to confirm Complaint reference xxxxxxx xx/xx/2025, to then ignore for nearly two months ongoing with no replies to date.

Summary.
(name of local authority) have failed their responsibility for scrutiny oversight to ensure Public safety.
Most of which caused by multiple failure to consult the Public, the Health and Safety Executive, and compounded by multiple failure to implement Government Legislation directives;

1. Telecommunications Act 2003 Schedule 3A Para75

2. Health and Social Care Act 2012

3. Public Services (Social Value) Act 2012 Chapter 3

4. Section 105Z1 of the Communications Act 2003 (Huawei)

5. Road Traffic Regulations Act 1983 Section 23 Crossings and Playgrounds

Additionally Failed to respond to these complaints to date.

My complaints reference Government legislation directives that (name of local authority) have failed to implement, and my listed examples of consequences due to that denied evidence, as certain public health impact.

My five Complaints on Smart Traffic Management implementation are about the failure of (name of local authority) to Notify or Consult the Public, to not consult with the Health and Safety Executive, the probable demise of Public health due to their failures to consult, and the inability to ban Huawei as it is an imperative security threat in that Smart Traffic Management equipment.

As to (name of local authority)’s responsibility to observe Government Legislation then that is set out in the listed statutory responsibilities of (name of local authority) listed in the Government document;

Review of local government statutory duties: summary of responses relevant to
List of statutory duties – other government departments (revised 30 June 2011)
https://assets.publishing.service.gov.uk/media/5a75ae42ed915d6faf2b4dfd/18927851.xls

https://www.gov.uk/government/publications/review-of-local-government-statutory-duties-summary-of-responses--2

My list of issues as objections, or as consultation comments are for example only that demonstrates what issues have been denied “the light of day” by failed governance from (name of local authority). Issues that are essential critical information evidence have been supressed due to not implementing those legislative directives.

This is the reason why we have Government legislation to protect the Public, and why (name of local authority) cannot continue to conduct business as usual as currently flawed governance in this matter.

If a lack of (name of local authority) response to my complaints continues then after 12 weeks the default appropriate elevation to an Ombudsman is required.
An Ombudsman would ask what can be done to resolve my complaints?
I suggest address the five complaints by rectifying the anomalies.

1. Real Public Consultations on Smart Traffic Management Systems.in accordance with the Telecommunications Act 2003 Schedule 3A Para75
It is not acceptable to deny responsibility by ignoring this complaint.
It is for (name of local authority) to accept they are the “operators” as defined in the Telecommunications Act 2003 Para75; as their individual sole use of that infrastructure, their use of tax payers’ money to install as their equipment, their receipt of charges; as the “operators” as defined in the Act 2003 Schedule 3A Para75

1. As “operators”, they commissioned for their purposes.

2. As “operators”, they granted permission for their own equipment.

3. As “operators”, they collected fines, and initiated polices based on it.

4. As “operators”, they used their equipment for their polices, and charges..

5. They are there to ensure observance of that Government legislation especially as

6. They acquired, and own that Traffic management infrastructure using Taxpayers funding for their use, not some other 5G provider.

7. As such (name of local authority) are the “operators” as defined in Telecommunications Act 2003 Schedule 3A para75 to notify the Public, and allow objection comment.

2. Consult the Health and Safety Executive on Radiation protection as required

in the Health and Social Care Act 2012 in the light of new information on disassembled Yunex-Thale-Huawei apparatus as a “Wolf in Sheep’s clothing” radiation issue.

3. Investigate, analyze, and convince yourselves at (name of local authority) that the Radar, and Lidar-laser component specifications actually inside the Yunex-Thales-Huawei apparatus are safe.
Do (name of local authority) Officials and Counsellors, fully understand the Yunex “Fusion” system using enhanced combination “fused” multiple technologies, Lidar-laser, Radar, and imposed unconsented, invasive surveillance and ID interrogation way beyond the remit of traffic management requirement.
There are concerns the Lidar in any Siemens Sicore2 Orlon Black laser diode units are using illegal Class3b laser diodes evidenced at an ongoing Transport for London tribunal.

(name of local authority) Police also use Sicore2, although (name of local authority) may have granted permission to install them as also their responsibility.

Also the issue of supposed safe Class1 Yunex laser diodes, which are used in a 24 array matrix are coherent, phased alignment, as collimated array, as cumulatively >Class1 unsafe in that multiplex version, with multiple “3D” cross referencing scanning systems at the same traffic crossing.

The use of a 24 laser matrix at 3 different scanning locations on a crossing is 72 Class1 supposedly safe laser diodes in phased alignment tandem are not actually Class1, or safe?

The Smart Traffic Management purpose goes well beyond remit if used for unconsented, invasive ID data farming acquiring the Engine management ID of cars scanned, Mobile Phone GPS and ID, and, paramagnetic bio MAC address acquired from the Media Access Codes,

The Yunex Fusion technologies are enhanced combination novel surveillance data ID acquisition, and especially compromised by the use of Huawei circuitry security risk.

All as examples of why Local Authorities need to consult the Public and why government insists that this is their legal responsibility in the above ignored legislation.

4. Observe the ban on the use of Huawei as an imperative immediate security issue as well as evidence for yourselves the capability to inflict Public irradiation harm.

5. Observe the Road Traffic Regulations Act 1983 Section 23 and implement the Government legislation to allow public notice of proposed Smart Traffic Management Systems

Add to that an overarching need to actually implement Government legislation directives otherwise the Public is at risk and also let down by failed governance.

The only thing that may be of consolation is that (name of local authority) Local Authority is not the only LA with this issue, and really requires a “national Class Action” on offending LAs, especially as there is an ongoing Transport for London v ICO tribunal Court precedent exactly on the same issues using validated evidence of harm.

The above as my detailed submission to date prior to any response on position by (name of local authority), or if after 12 weeks of no response, as a default Ombudsman Complaint on failure by (name of local authority) to observe Government legislation to allow Pubic notification, and consultation requirement for their Traffic Management Systems.

Regards
Name
Address