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This is what I am submitting as my representation:

"I am appealing this PCN because the road markings are severely faded, making the single yellow lines almost impossible to see under normal conditions. The CEO’s high contrast photographs exaggerate their visibility because the lines are not maintained to a standard that clearly indicates any restriction. And the area that would have been underneath and to the front of my vehicle are completely faded. This location is also within a controlled parking zone so lacks the proper signage directly at the location, this in conjunction with the severely faded lines, and the fact that I also hold a valid resident permit for the entire area is what caused the confusion and led me to believe that I could park there.

Additionally, I did not receive the initial Notice to Owner, depriving me of the opportunity to pay at the discounted rate. It is unfair to penalise road users for a delivery failure beyond their control, especially because the initially offered discounted rate is not re-offered and that a delivery failure caused a debt recovery to be issued. Notice to Owners should be sent with signed or recorded delivery to prevent this unjust stress on road users."

Additionally, I did not receive the initial Notice to Owner, depriving me of the opportunity to pay at the discounted rate. It is unfair to penalise road users for a delivery failure beyond their control, especially because the initially offered discounted rate is not re-offered and that a delivery failure caused a debt recovery to be issued. Notice to Owners should be sent with signed or recorded delivery to prevent this unjust stress on road users."

Is nonsense, I'm afraid, I'd leave it out.

There was no 'opportunity to pay the discount' with a NTO. You had your chance with the initial PCN.

As regards how NTOs are served, this is by first-class post and not signed or recorded, after all if this was the case then motorists could just refuse to sign.

In view of the number of times we see on here that postal PCNs and NtOs are not received before Charge Certificates are received, my view is that all postal enforcement documents should be sent by tracked mail. That way there cannot be any argument about when they arrive at the addressee.

They have accepted my representation and cancelled the PCN:

"Thank you for your representations received on 11 February 2025, against the above penalty charge notice (PCN). Your comments and the notes of the Civil Enforcement Officer (CEO) have been considered.

We have noted your comment but due to the fact that an important information about the case cannot be retrieve a decision had being made to accept your representation. [sic]

In view of the above information, your representation has been accepted and penalty charge notice has been cancelled."

Bit of fortune. Is there anything here that can be used for future cases?