Okay, I have appealed that first one. The other two are basically identical.
I added in those points you mentioned including the repeated use of "28 days from the date of service" instead of "28 days beginning with the date on which the PCN is served".
I also included the fettering of discretion in the use of "will" over rather than "may".
For the NoR I included the use of the word "delivery" rather than "service" and use of the phrase "after 28 days".
The comments regarding costs seems to be same across councils outside London, I had a look at a Slough Council and a Lancashire County Council NoR I had, and the wording is the same. I'm not saying it's right, it's just an observation.
Anyway, that's one down, two more to go, and I have a London Tribunal this afternoon so that'll be fun!