I don't know what an adjudicator would make of the evidence, I know that Uber-speak is not my first language and I'm certain it won't be theirs. If you decide to appeal, then don't presume knowledge, try to make it absolutely clear, as you did in your last post.
IMO, IF an adjudicator accepts that there was a pre-booked pick-up at the time, then your father's next hurdle is why did they stay in the bay when there was no-one on the kerb. Again, he'd need to explain the difference between hailing a cab, where the ride is at the kerbside, and Uber where the rider is given an approximate time. I'd try to personalise matters e.g. you're certain that the adjudicator would have booked a taxi for, say, a journey to an airport and would not have stood at the kerbside outside their house until the taxi arrived: this is not the order of events i.e. taxi arrives, passenger(s) appear from behind closed doors then load and go.
IMO, the bay is for the 'purpose' of picking up/setting down. Sometimes things don't go to plan, although in this case I would refer to the person who approaches the bay because how would your father know this was not his fare until that person got into the car in front. It's not a taxi rank(which has precedence protocols).
IMO, there are also procedural issues with the NOR, but for me fundamentally the issue is convincing an adjudicator that a pick-up had been arranged.