You are beyond the point when you can submit representations. The only point when you can revert the process is when the council register the debt at the Traffic Enforcement Centre (TEC), and send you an Order for Recovery. You can then submit a Statutory Declaration that you did not receive the PCN. The process is then reverted to the PCN stage. It is a mere box-ticking exercise.
However, this doesn't mean you can now sit back and wait the OfR, because having missed getting the PCN, you might not get the OfR. So, once the period to pay the CC is expired, you should ring TEC every week asking if the debt has been registered. Once it has, you can download the form from the TEC website, fill it in, and send it off. I understand TEC will accept this electronically.
Traffic Enforcement Centre forms, including the form to challenge an unpaid penalty charge notice.
