Try this: -
Dear Sirs
PCN <number> dated <dd/mm/yyyy> served at Kincardine Road
I deny responsibility for the penalty charge demanded on the above PCN on the grounds that the contravention did not occur. The contravention stated on the PCN is only valid when the vehicle allegedly in contravention is actually parked on the carriageway. As your own photographs show, my vehicle was not parked on the carriageway.
The PCN is therefore invalid and I request its immediate cancellation
Yours faithfully
They will inevitably just send you the usual Fob-Off letter. Please post it here when you get it.
Be aware that virtually all staff in council traffic and parking enforcement offices have no knowledge of the law at all and just send out whatever the computer tells them to. In addition, councils know that if they send out Fob-Off letters refusing every representation received, then most people, (like 98%), just cough-up.