It doesn't appear they've listed all the grounds of formal appeal accurately at the front. It should include:
The grounds referred to in sub-paragraph (1) above are—
(a)where the penalty charge notice was served pursuant to the said section 4 or, where an enforcement notice was served, that the recipient—
(i)never was the owner of the vehicle in question;
(ii)had ceased to be its owner before the date on which the penalty charge was alleged to have become payable; or
(iii)became its owner after that date;
(b)that there was no breach of an order or regulations of the type described in subsection (2) of the said section 4;
(c)that at the time the alleged breach of such order or regulations took place the recipient was not in charge of the vehicle.
They have stated that "the vehicle was being used without the owner's consent", but there can also be a driver who has been given consent by the owner to drive if the owner was not in charge of the vehicle, so it's a bit inaccurate.