The DYL are clear as are 24/7 no loading markings;
The kerbstones are the same before and after i.e. it's not a footway lowered to meet the carriageway.
What indicators are there that this is part of the carriageway?
OP, remember that as you were parked you were also in contravention of the DYL and no loading restriction...as were the other vehicles in your photos. But the CEO chose 'parking in a road other than on a carriageway'.
But you're free to challenge at this stage, thence the registered keeper ultimately to adjudication.