I believe that even the recommended appeal above is already over embellished, especially for a (not so) Smart Parking appeal. The following has never failed:
This is an appeal by the registered keeper - No driver details will be given. Please do NOT try the usual Group Nexus trick of asking for driver details in order to get around the fact your NtK does not comply with PoFA. As there is no keeper liability, therefore, liability cannot flow from the driver to the keeper and so, is an automatic win at POPLA. Please cancel the notice or issue a POPLA code at which point you will auto withdraw.
I note you have edited your post to remove the photo showing where you believed the car was parked - if it was indeed where that image suggested, I would be very surprised if it was outside the bounds of the car park and actually on the public road.
However, with this being Smart Parking, you have a very easy way to get out of this without really needing to engage with the specifics of the case. They choose not to make use of Schedule 4 of the Protection of Freedoms Act 2012 to be able to recover charges from the registered keeper*. As such, you have no liability. You could therefore appeal along the lines of the below as the keeper (no telling them who was driving!):
Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for vehicle registration mark ____ ___, in which you allege that the driver has incurred a parking charge. I note from your correspondence that you are not seeking to hold me liable as the registered keeper, under Schedule 4 of the Protection of Freedoms Act 2012 ("The Act"). You have chosen not to issue a Notice to Keeper in accordance with The Act, and it is now too late for you to do so.
There is no obligation for me to name the driver and I will not be doing so. I am therefore unable to help you further with this matter, and look forward to your confirmation that the charge has been cancelled. If you choose to decline this appeal, you must issue a POPLA code.
Yours,
If appealing online, be careful there are no drop down/tick boxes that cause you to identify who was driving, and keep a close eye on your spam folder for their response. If they do not respond within 35 days, chase them.
* If you are not the registered keeper, tell us before submitting anything, as the approach will need to be different.