IMO, your first procedural point is that the penalty exceeded the amount applicable in the circumstances of the case.
The authority assert that the PCN could be served by virtue of the CEO having observed the vehicle for no more than 1 minute during which time they had observed the prospective contravention, assessed the circumstances, reasoned that a penalty was due and begun to prepare a PCN for service .
On the basis of the council's evidence, I challenge that the CEO had begun to prepare a PCN, as opposed to merely carrying out simple preliminary activities, and therefore no lawful basis exists for the regulation 10 PCN and consequently the penalty exceeded the amount applicable.