The PCN is not compliant with Regulation 3 (1)(c) of the The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022
3.—(1) A regulation 9 penalty charge notice must include the following information—
(a)that a person on whom a notice to owner is served may, in accordance with these Regulations, make representations to the enforcement authority against the penalty charge and, if those representations are rejected, appeal to an adjudicator;
(b)that if, before a notice to owner is served, representations against the penalty charge are received at such address as may be specified in the notice for the purpose those representations will be considered by the enforcement authority;
(c)that if a notice to owner is served despite the representations mentioned in sub-paragraph (b), representations against the penalty charge must be made to the enforcement authority in the form and manner and at the time specified in the notice to owner.
Whilst they state that you can submit reps against a Notice to Owner, for me, it is not compliant with "if a notice to owner is served
despite the representations mentioned in sub-paragraph (b),
This particular clause is there to alert a PCN recipient that if reps are submitted but no response has been received to them, before an NtO is received, that reps must be made against the NtO despite reps having already been submitted.
This error really should win at the adjudicators on its own, but nothing can be guaranteed, I'm afraid.