104 days from offence to NTK issue date?
That must be a record for incompetency 
Thank you for this Brenda, this makes me feel better that I have grounds to tell them to shove it!
Show us a draft before sending anything. The idea is to make it unarguably clear that they have not complied with PoFA (easy given the dates!) and that as such there is no keeper liability.
This is what I came up with and then asked ChatGPT to clean up. Let me know if it's ok!
"I am the registered keeper and I am not liable for this charge.
My original appeal clearly stated that the Notice to Keeper does not comply with the Protection of Freedoms Act 2012 Schedule 4, yet the operator’s rejection failed to address this point at all.
The dates are:
Alleged parking event: 18/10/2025
Notice to Keeper issued: 30/01/2026
This is 104 days after the event.
Under PoFA:
Paragraph 9(4) requires delivery of a Notice to Keeper within 14 days where no windscreen ticket was served
Paragraph 8(5) requires delivery between 29 and 56 days where a windscreen ticket was served
A Notice to Keeper issued after 104 days is non-compliant under either scenario.
Because the statutory conditions have not been met, the operator cannot transfer liability from the driver to the keeper.
I am under no legal obligation to identify the driver and will not be doing so. There is no legal presumption that the keeper was the driver.
The operator’s statement that a postal PCN can be issued within “7 months” is incorrect in law and does not override PoFA. It is therefore irrelevant to keeper liability.
As the operator has failed to establish keeper liability, this charge is unenforceable against me.
I respectfully request that the appeal be allowed and the PCN cancelled."
In addition, is it best to submit this appeal asap or on day 21 (I don't know if it makes any difference)
TIA