PCN from Excel Parking

[Noodlesoup]

HiI recently parked in a retail park (driving a car in my husband's name) that used to be free but now requires a ticket. As such my husband has now received a PCN NTK. I was never issued with a NTD and this is the first notice we have had. The parking date was 17/10/21 and the notice is issued 05/11/21 (although we only received it 10/11/21).
I have done some research and my thoughts are that because no NTK was given, excel had 14 days in which to provide a NTD in order to obtain the keeper's details. As they have taken longer than 14 days I believe this is not valid with POFA and that my husband has no obligation to pay as he is the keeper but not the driver and that he also has no obligation to give my details.
Is anyone able to confirm if this is the case? I obviously would really like to not pay this ticket so want to appeal if possible but my husband is worried about appealing, being unsuccessful and then getting a CCJ against him.
I've included a picture of the PCN for reference.
Thanks so much for any help you can provide! If I can appeal then I will be donating the cost of the ticket to charity so if you are able to help me do so and would like to suggest a faboure

[Noodlesoup]

PCN letter

[echat11]

Hi NOODLE

ostell Can you take a look and advise, many thanks.

[ostell]

If this not a lease or hir car then:

Dear Sirs,

I have just received your Notice to Keeper 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 also failed to give the warning of keeper keeper liability in the format required by 9 (2) (f) of the same 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

First class post with free certificate of posting from a post office