Here's a draft letter:
Dear Sir or Madam,
I am writing to make a formal representation against the above Penalty Charge Notice on the grounds that the alleged contravention did not occur.
In your response to my initial challenge, you stated that vehicles are only permitted to park within clearly marked bays along this road. However, this restriction is not clearly conveyed by the signage present at the location.
On 28 January, I revisited the location and took photographs of the signs along the road. These photographs demonstrate that the signage does not clearly indicate that parking is restricted solely to marked bays. As such, the restriction relied upon in your response is not adequately communicated to motorists.
For a parking restriction to be enforceable, it must be clearly indicated by appropriate signs and road markings so that a reasonably diligent motorist can understand the restriction. In this case, the signage along the road fails to clearly convey the requirement that vehicles must park only within marked bays.
Given the lack of clear signage indicating this restriction, I believe the alleged contravention did not occur and that the Penalty Charge Notice has been issued incorrectly.
I therefore request that the Penalty Charge Notice be cancelled. Please find attached the photographs taken on 28 January which show the signage present along the road at the time.
I look forward to your confirmation that this notice has been cancelled.