For what it's worth, I ran the response through Claude and it analysed it against what I originally appealed based on. I know AI is never 100% accurate but thought I'd try it out! Here is its response
"Being straight about it this isn't a toss-up, but it's not open-and-shut either. Here's how I read it, ground by ground.
Ground 1 (no period of parking) your stronger ground, genuinely.
Para 9(2)(a) of Schedule 4 POFA 2012 doesn't carve out an exception for attendant-observed contraventions it just requires the notice to specify "the period of parking." UKPC's rebuttal ("this wasn't ANPR so no period was needed") doesn't actually engage with the statutory wording; they're asserting an exception that isn't in the Act. Your vehicle was on site for some duration before the warden's 19:06 observation, and the NTK only captures a single moment of that, not a period. This is a well-established line of appeal and has succeeded at POPLA plenty of times.
The honest caveat: POPLA assessors are not perfectly consistent on this. Some have accepted UKPC's kind of argument that for a contravention which is true at a single moment (parked outside a bay, as opposed to an overstay), a single observation time is adequate specification. It's a real split in outcomes, not settled law, so I'd rate this "more likely to succeed than not" rather than "certain."
Ground 2 (illegible signage) weaker than when you filed it.
Your original point was solid: the image on the PCN itself was too blurry to read. But UKPC has now supplied a second, clear, contemporaneous photo (timestamped 19:06:02 on the actual day) of a wall sign near where you parked. That's a real evidentiary cure it goes a decent way to discharging their burden on this specific point, whatever you think of the rest of their pack.
The other "signage evidence" photos dated 3 Feb 2020 are worth flagging (they're not evidence of what was displayed on 15/07/2026), but I wouldn't oversell that point it's a credibility ding on the quality of their evidence pack, not a rebuttal that cancels out the one photo that is dated correctly and legible. An assessor is likely to weigh the good photo over the stale ones rather than throw out the good one because of the bad ones.
Net assessment: I'd put this as a reasonable-to-decent chance of success, carried mainly by Ground 1, with Ground 2 now doing less work than it was when you first appealed. If I had to bet, I'd lean toward "arguable win, not a sure thing" worth pursuing, but I wouldn't walk in assuming it's in the bag. The comments stage is really your chance to sharpen Ground 1 (hold UKPC to the actual statutory text, not their "ANPR only" gloss) rather than lean on Ground 2, which has been partly answered.