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From the council pics I'd say it's about a pedestrian crossing - there's nothing showing crossover access.

You keep coming back to your argument but without answering what IMO are key questions:

Does the raised footway extend beyond your crossover;
Was any part of your vehicle parked OTHER THAN adjacent to your crossover?

IMO, if it does and if you did, by more than a de minimis degree, and if it would be accepted by an adjudicator as a raised carriageway for the purposes of s86(b), then you have a problem.

Sorry, not intentional, does this photo help ?

- I'm not aware of any raised footway at all - but the speed hump and dropped kerb extends for a few reasons (see photo just linked)
- I do have a crossover, between my driveway and the road

Does this photo help to illustrate at all ? I don't think I'm anywhere near the pedestrian crossing

No, this was not the case.

ok thank you so much. I will raise a formal challenge then in response to the NTO. Will update you how I get on

How is this ?

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Formal Representation Against Notice to Owner
PCN Reference: [Insert PCN]
Vehicle Registration: [Insert VRM]
Location: [Insert Location]

I challenge this Notice to Owner on the primary ground that the alleged contravention did not occur. The PCN is both factually incorrect regarding the topography of the location and legally void due to the application of a statutory exemption.

1. Procedural Invalidation via Topographical Error
The PCN states the vehicle was "parked in a special enforcement area on part of the carriageway raised to meet the level of a footway, cycle track or verge" (Code 28). This physical description is false. The carriageway at this location has not been raised. Rather, the footway is sloped down to meet the level of the carriageway to facilitate vehicle access to a residential driveway. The Civil Enforcement Officer has conflated a dropped footway (Code 27) with a raised carriageway (Code 28). Because the PCN alleges a contravention that physically cannot have occurred at this location, the penalty is procedurally defective and must be cancelled.

2. Statutory Exemption under Traffic Management Act 2004
Notwithstanding the CEO’s fatal error in coding the topography, no parking contravention occurred. The location is a dropped footway serving a single residential driveway. Section 86(3) of the Traffic Management Act 2004 explicitly exempts vehicles parked in a special enforcement area adjacent to a dropped footway if the vehicle is parked outside residential premises by, or with the consent of, the occupier.

As the registered keeper of the vehicle and the occupier of the property at [Insert Address], I authorised the vehicle to be parked in this location. The statutory exemption is fully engaged.

I require immediate cancellation of the PCN. If this representation is rejected, you must provide the CEO’s complete topographical survey notes and photographic evidence specifically proving a raised carriageway, rather than a sloped footway, exists at this exact coordinate.

To accelerate the cancellation of this PCN, I have attached photographic evidence confirming the existence of a dropped footway, demonstrating unequivocally that the carriageway has not been raised. Furthermore, I have attached proof of residency at [Insert Address] to validate my authority to engage the Section 86(3) exemption.

Doesn't the statutory exemption only apply for a dropped kerb in front of a driveway?

So in order to apply this - I need to show that the carriageway has NOT in fact been raised to meet the footway ? (the alleged contravention)

The presence of the dropped kerb evidences this point, because had it been raised, then the dropped kerb could not possibly exist.

Doesn't the statutory exemption only apply for a dropped kerb in front of a driveway?

As per stamfordman, NO.

86Prohibition of parking at dropped footways etc.
(1)In a special enforcement area a vehicle must not be parked on the carriageway adjacent to a footway, cycle track or verge where—

(a)the footway, cycle track or verge has been lowered to meet the level of the carriageway for the purpose of—

(i)assisting pedestrians crossing the carriageway,

(ii)assisting cyclists entering or leaving the carriageway, or

(iii)assisting vehicles entering or leaving the carriageway across the footway, cycle track or verge; OR

(b)the carriageway has, for a purpose within paragraph (a)(i) to (iii), been raised to meet the level of the footway, cycle track or verge.

This is subject to the following exceptions.

...
3)The second exception is where the vehicle is parked outside residential premises by or with the consent (but not consent given for reward) of the occupier of the premises.

This exception does not apply in the case of a shared driveway.

No, this is not the right approach and looks like AI to me.

Can you recall what you said in your initial challenge?