@Dottoy the NTO is defective so this is pretty close to an open and shut case. Here's a draft for you:
Dear London Borough of Bromley,
I rely on my informal representations in the first instance.
Furthermore, the notice to owner wrongly states that the penalty must be paid within 28 days of the date of the notice, rather than 28 days from the date of service of the notice. This is a procedural impropriety on the basis of which the PCN must be cancelled in any event.
Yours faithfully,