They'll reject your informal reps anyway, so I'd simply stick with the facts and see what mess they get themselves into.
Possibly along these lines:
On **** I parked in Amhurst Gardens on an unmarked length of carriageway, as shown in your photos, which indicates that there are no parking restrictions imposed under a local order. I returned to my car to find a PCN alleging a contravention in respect of a parking place. I looked around and could see a parking place sign but this had no effect because the mandatory road markings to indicate the extent of the restriction were not present. Subsequent to these events, I explored the area further and found Controlled Parking Zone entrance signs, but as these do not relate to parking restrictions I therefore dismissed them.
I am therefore making representations on the grounds that the contravention did not occur.
If the authority reject these representations they must prove in detail by reference to the relevant regulations why parking on an unmarked length of carriageway could give rise to the alleged contravention.