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Thanks all for your thoughts and help. I've sent an appeal but not expecting much. Might leave it here when it gets rejected.

I didn't have any specific evidence the land wasn't relevant for PoFA. In another case with a private companies parking charge it turned out the land wasn't relevant. However, I appreciate that not all cases will be the same.

Thanks @Incandescent. @Hippocrates What's your view.

Much appreciated.

Here's a draft of the appeal:

I make formal representations against Penalty Charge Notice XXXXX on the ground of procedural impropriety.

The Penalty Charge Notice is legally flawed because it misstates the circumstances in which a Charge Certificate may be served.

The PCN states:

“Failure to pay the penalty charge in full before the end of the 28 Day Period may lead to the charge increasing by 50% to £240.00 and a Charge Certificate being served…”

This wording is incorrect and misleading.

Under Schedule 1 of the London Local Authorities and Transport for London Act 2003, a Charge Certificate may only be served if:
   •   no representations are made within the 28-day period, or
   •   representations are made and subsequently rejected, and the penalty charge is not paid within 28 days of service of a Notice of Rejection.

The PCN unlawfully suggests that a Charge Certificate may be issued automatically at the end of the 28-day period beginning with the date of the notice, regardless of whether representations are made. This fetters the recipient’s statutory right to make representations and misstates the legal position.

This constitutes a procedural impropriety and renders the Penalty Charge Notice unenforceable.

I therefore request that the Penalty Charge Notice be cancelled.

Feedback would be most welcomed!

Thanks both. @Hippocrates Could you help me understand why the pcn is flawed? They haven't served the charge certificate yet.

Yes sure, Here it is.

Decision Successful
Assessor Name Redacted

Assessor summary of operator case: The operator has issued the parking charge notice (PCN) for not purchasing the appropriate parking time.

Assessor summary of your case:
The appellant has raised the following points in their grounds of appeal: 1. Inadequate signage 2.
Lack of transparency and unfair terms, re Consumer Rights Act 2015 3. Landowner authority and
site boundary 4. Consideration and grace period 5. Operator maladministration In the comments,
they have raised three points. To support their appeal, the appellant has provided: 1. Three photos
of the entry and area they parked 2. A video of the area 3. A photo of their laundrette receipt

Assessor supporting rational for decision:
This decision relates to PCN: (REDACTED) The operator is a member of the British Parking
Association (BPA), which uses a code of practice detailing the standards that it needs to uphold as a
part of its membership - the Private Parking Single Code of Practice. It is the operator’s
responsibility to demonstrate to POPLA that they have issued the parking charge correctly. I am
allowing this appeal, with my reasoning outlined below: In this case, the appellant has challenged
the signage, providing photos and a video of the entry and where they parked outside the
laundrette. The appellant’s evidence shows there is an entry sign, but no terms and conditions
signs between the entry and up along the row of businesses. This evidence casts doubt on the
placement of the first number 2 sign, just after the entrance on the operator’s site map. The site
map shows signs throughout estate, however, they all appear to be down the road and round the
corner from the businesses at the entry. If a motorist was simply visiting one of those businesses,
they would have no reason to walk round the flats looking for signs, and I don’t consider it
reasonable to expect a motorist to do that. Accordingly, I conclude that the signage doesn’t meet
the standard required by Section 3 of the Code of Practice, and that no contract existed between
the operator and the appellant, and therefore, I allow this appeal.

As requested here https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/tfl-red-route-postal-pcns/. I've sent a DM to cp8759 directly.