Well, first off, you are not "formally appealing", you are submitting an "informal challenge". It's important you know the difference because if your challenge is declined, like over 95% of them are, the next thing you will receive is a Notice to Owner, (assuming you are the owner), against which you can submit formal representations.
Representations against an NtO are usually looked at a lot closer, because councils just want the easy money, so you might get it cancelled at that stage, but many councils know that they can "DNC" (Do Not Contest) an appeal at the TPT having put you through a lot of hassle. OK they lose the case, but the enormous sums of money councils earn with PCNs means they can lose a few.
Secondly, it is almost inevitable that the location isin a Special Enforcement Area, because any council that has powers to enforce parking and traffic contraventions, must have first established a Special Enforcement Area in order to do so. This takes responsibility for enforcement away from the police and hands it to the councils under the Traffic Management Act 2004, plus associated regulations. Virtually the whole of England and Wales is now under decriminalised parking and traffic enforcement.
Of the points in your draft challenge, only 3 and 5 have any value. The disused entrance does not meet the statutory requirement for enforcement, because it serves no purpose as entrance or as a road crossing, so they really should cancel this PCN solely on that basis, but they won't because they know that on receipt of a rejection, most people, as I say above, just cough-up. If you want to succeed, you have to forego the discount option, wait for the Notice to Owner, send in reps against that, get rejected again, then register an appeal at the Traffic Penalty Tribunal. Are you prepared to do this ? If not, it's game over now.
