Smart Parking: PCN After 14 Days

[crow99]

Friend received this from Smart Parking - issued after 14 days to the registered keeper.
Presumably they do not need to identify the driver and can't be held liable as after 14 days (from a while of reading on here).

Front of Letter
Back of Letter

If so, what would best appeal be?

Dear Sirs,

I have just received your Notice to Keeper No. xxxxx for vehicle VRM xxxx

You have failed to comply with the requirements of Schedule 4 of The Protection Of Freedoms Act 2012 namely, but not limited to, failing to deliver the notice within the relevant period of 14 days as prescribed by section 9 (4) of the Act. You cannot, therefore, transfer liability for the alleged charge from the driver at the time to me, the keeper.

There is no legal requirement to name the driver at the time and I will not be doing so.

Any further communication with me on this matter, apart from confirmation of no further action and my details being removed from your records, will be considered vexatious and harassment. This includes communication from any Debt Collection companies you care to instruct.

Yours etc

[crow99]

Also photos of Street View of Car Park.

Car Park 1 - Only small sign at wall, not easily visible if going into Shop.
Car Park 2 - Only sign at entrance off road, obscured by hedge and not visible at turning.

[des8]

Not so Smart make a habit of late issuance so your response should do the trick.