Surely the PCN acts as the NTO, hence one bite at the cherry before adjudication.
If these facts fit...I would suggest..
The council alleges that my car was in contravention at 13.10 and served a PCN by post because it claims that:
A contravention had occurred, and
The CEO......a civil enforcement officer had begun to prepare a penalty charge notice for service but the vehicle was driven away from the place in which it was stationary before the civil enforcement officer had finished preparing the penalty charge notice or ..
In support, the council has posted photos taken by the CEO, one of which shows my car and me (together with the CEO) in situ at 13.15 therefore fundamentally undermining the second limb of its assertion that the 'vehicle was driven away [at or immediately after 13.10] or that the CEO was 'unable to serve [the PCN]'.
It therefore follows that based upon the council's evidence alone there was no legal power to serve the PCN which must therefore be cancelled.