As above, essentially. As they have chosen not to comply with the requirements of Schedule 4 of the Protection of Freedoms Act, they cannot hold you liable as the registered keeper. They can only hold the driver liable, and they don't know who that is, so don't tell them.
I am assuming that:
- You are the registered keeper of the vehicle, with the vehicle's V5C document in your name
- The notice you have showed us is addressed to you
If either of those assumptions are wrong, tell us, as it will affect the approach.
If both of those assumptions are correct, you can appeal as the registered keeper with the below:
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 28 days, chase them.