I guess no, I’ve never said I’m not the driver. I agreed to fight this for my friend as I kinda gave him the go ahead as I was aware that we’re awaiting permits / visitor permits so thought it wouldn’t be an issue. I even contacted VCS straight away after my friend received the PCN & stated the permit issue and they said on the phone that this would be a valid appeal.
It’s clear at some point that they changed the address for communications from my friends address, got through DVLA, to mine - listed on the appeal.
What would stating I wasn’t the driver achieve?