Don’t identify the driver, because with no period of parking the PCN does not allow liability to be transferred from the unknown driver to you, the registered keeper.
Plenty of appeals here, such as
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. PPS 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. PPS have no hope should you be so stupid as to try and litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
The appeal will be rejected because they always are, but come back here when it is.