And therein lies the biggest problem with the CVOR system ... you are guilty, period. No opportunity to explain or defend yourself, save one.
That one is to ramp up your CVOR so bad that you have to go to St. Catharines and appear before the panel to explain your poor CVOR record. Then, and only then, do you get the opportunity to have your say. However, you are not adjudicated by a court of law, by either judge or jury. You are adjudicated by bureaucrats that bend with the wind of the day, and the mood they left home with.
The USDOT system exists to make carriers better and roadways safer. The CVOR system exists for one reason only, and that is to fill the government's coffers. They have no real interest in making carriers better, or roadways safer. That is counterproductive to their end goal.
If there ever existed a less-than-zero-value government agency, it is the MTO.
Quick story on how inept MTO really is ...
A couple years ago I met a guy that did highway construction and paving on Ontario 400 series highways via the MTO. As they pave contractors have to take samples of the pavement. MTO has 14 days to test the samples and if they are under spec the contractor has to replace the pavement under warranty. Problem; MTO never gets samples done in less than 30 days, and is quite often several months. If the pavement is under spec, MTO has to pay that crew again, this time by the hour, to tear up the pavement and replace it. This guy told me he ran a small crew and his company bills his crew at $125,000.00 an hour.