If you appeal as the registered keeper and do not identify the driver, as you have done above, then the notice is not compliant with PoFA 2012 to transfer liability from the unknown driver to you, the registered keeper.
Horizon will probably reject your appeal simply because accepting it means they get no money, but eventually you will get to a point where you pay £0.
For example,
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. Horizon has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Horizon have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
The requirement to transfer liability is to issue the notice so that it reaches the registered keeper within 14 days, two working days after the issue date. In this case, the issue date was too late for this to be possible.
