Licence Appeal Tribunal

Safety, Licensing Appeals and Standards Tribunals Ontario

Tribunal d’appel en matière de permis

Tribunaux de la sécurité, des appels en matière de permis et des normes Ontario

Date: 2020-11-02

Appeal under Section 50(1) of the Highway Traffic Act, R.S.O. 1990, c. H. 8 from a Cancellation and Seizure Order of the Registrar of Motor Vehicles pursuant to Section 47 of the Act.

Between:

2356409 Ontario Inc.

Appellant

and

Registrar of Motor Vehicles

Respondent

DECISION AND ORDER

Adjudicator: Evelyn Spence, LL.B.

Appearances:

For the Appellant: Giovambattista (John) Tomasone, Paralegal

For the Respondent: Patrick Moore, Counsel

Heard by Videoconference:

October 16 and 19, 2020

DECISION AND ORDER

A. Overview

1The appellant, 2356409 Ontario Inc., appeals to the Tribunal under section 50(1) of the Highway Traffic Act, R.S.O. 1990, c. H8 (the “Act”), from a Cancellation and Seizure Order dated April 1, 2020 (the “Order”) made by the Deputy Registrar of Motor Vehicles (the “Registrar”). At the hearing, the appellant was assisted by an interpreter.

2The basis for the Order is the appellant’s extremely troublesome on-road safety rating. At the time the Registrar decided to issue the Order, the appellant’s safety rating stood at 115.08% of the maximum allowable safety rating. Very few CVOR operators have such a dismal safety rating. The appellant reached this level despite the Registrar drawing its increasingly poor record to its attention and giving the appellant the opportunity to improve.

3The effect of the Order is to cancel the appellant’s right to operate trucks on Ontario highways by cancelling its Commercial Vehicle Operator’s Registration (“CVOR”) certificate # 181-679-004 and the plate portion of permits, and to seize the plate portion of permits and number plates for all commercial motor vehicles and trailers registered to the appellant.

4The appellant appeals on the basis that there has been improvement since the Registrar’s latest intervention and that the appellant is continuing to take steps to improve its safety and compliance record. It asserts that the proposed sanction of cancelation and seizure is excessive.

B. ISSUE AND DECISION

5The issue to be decided is whether the Registrar has reason to believe, having regard to the safety record of the appellant, that it will not operate its commercial motor vehicles safely or in accordance with the Act, the regulations and other laws relating to highway safety.

6For the reasons that follow, the Order is confirmed.

C. LAW

7After reviewing the appellant’s safety record, the Registrar exercised the powers set out in s. 47, 47.1 and 50 of the Act to issue the Order. The appellant has exercised its rights under s. 50(2) to appeal the Order to this Tribunal. Section 50(2) gives me the authority to confirm, modify or set aside the Order.

D. EVIDENCE

8The appellant has been in operation for almost 6 years. Over time, it has accumulated a record of violations that call into question its ability to operate vehicles safely on Ontario highways. Particularly, the evidence suggests the appellant has regularly failed to comply with its legislative and operational duties, demonstrating a clear disregard for the regulatory regime in which it operates.

9Before I get to the evidence of the appellant’s safety record, I will outline the evidence of the CVOR system, including the responsibilities of CVOR operators, and how the system tracks safety violations. I will also discuss the evidence on the Registrar’s attempts to have the appellant address its safety record, and correspondingly, what efforts the appellant undertook to improve its safety record.

a) CVOR Operator Responsibilities

10The Registrar’s witness, Mr. Travis Donohue, is a longstanding Ministry of Transportation (“Ministry”) employee, having occupied various positions working with commercial vehicle operators over a period of twenty years. During his first six years at the Ministry, Mr. Donohue worked as a Transportation Enforcement Officer, where he was responsible for inspecting commercial motor vehicles and examining the documentation required to be carried by operators. Thereafter, he was a Facility Auditor, conducting audits of CVOR holders to ensure compliance with the Act. In 2015, he assumed the role of Carrier Safety Rating Administrator, which is the position he continues to occupy. In this role, Mr. Donohue explained that he prepares files for the Registrar’s review, conducts operator interviews, evaluates action plans, and represents the Ministry in proceedings before the Tribunal.

11Mr. Donohue explained that a CVOR operator is the person or legal entity responsible for the operation of a commercial motor vehicle. The operator is responsible for the conduct of the driver, the mechanical safety condition of the vehicle and the goods or passengers of the vehicle.

12Legislative and operational requirements, including operator responsibilities, are set out in the Act and regulations, and are also included in the Ministry’s Commercial Vehicle Operators’ Safety Manual, which is available to all commercial vehicle operators in Ontario.

13Operators are responsible for all the drivers and vehicles in their operation. These responsibilities include, among others:

• Employing qualified and licensed drivers,

• Monitoring the safety performance of drivers, including hours of service,

• Resolving driver safety issues when they are identified,

• Keeping vehicles in good, safe condition at all times,

• Ensuring load security,

• Ensuring that daily and annual/semi-annual inspections are completed,

• Keeping records on file (for example, vehicle repairs, kilometres travelled per year, annual inspection reports and so on), and

• Notifying the Ministry of changes such as name, address, telephone numbers, fleet data, kilometric travel, changes in corporate officers and so on.

14In addition to the above, operators must comply with all regulations and legislation under the Act. Failure to do so results in sanctions or loss of operating privileges.

b) The CVOR’s Safety System

15Mr. Donohue explained that the Ministry manages a computer database which tracks the on-road safety record and performance of all commercial vehicle operators. This information is recorded in an abstract, referred to as a commercial vehicle operator record (a “CVO record”), and contains information about all convictions, collisions, inspections, kilometric travel, fleet size and other significant events for each CVOR holder.

16The goal of the CVOR system is to improve road safety for all users of Ontario highways by employing an effective monitoring and intervention system of operators. Poor performance may result in the loss of privileges to operate commercial motor vehicles.

17Mr. Donohue stated that commercial vehicle operators are assigned a safety rating, which is based on the number of kilometers the company will travel in a twelve-month period in Ontario. The system is not dissimilar to the points system for personal drivers’ licences except it takes into account the fact that trucks travel much greater distances than the average car driver. Kilometric travel is calculated by operators from trip sheets and annual safety pre-trips and then is reported to the Ministry. It is the responsibility of operators to accurately report their kilometric travel as it forms the basis of threshold points. Operators with higher mileage will be assigned a higher threshold, and vice versa.

18Safety-related events, such as at-fault collisions, convictions and vehicle defects identified through inspections, are tracked on the company’s CVO record. Each category is tracked against its own maximum permissible violation rate (% VR) and then all three categories are combined using a weighting system to arrive at the overall % VR. Events are assigned points, with more serious events (e.g. those involving driver impropriety or resulting in fatal and/or personal injury) being assigned more points. Mr. Donohue explained that the higher the violation rate, the higher the risk to public safety. Points stay on a company’s record for two years, so a % VR shows a company’s performance over the last 24 months.

19The Ministry uses an intervention model so that when an operator achieves a certain violation rate, an intervention will be applied. Interventions include warning letters, facility audits, interviews and sanction proceedings. For instance, if an operator’s % VR reaches 35%, the Ministry will typically issue a warning letter to the operator, advising it to take corrective action. At 50%, an auditor may be sent to audit the operator’s facility and operations. At 85%, there is normally an interview, and over 100%, the Registrar will consider sanctions ranging from limitations to suspension to outright cancellation. The purpose of intervention is to bring to the attention of the operator that corrective action is needed.

20Mr. Donohue explained that the triggers are discretionary, and interventions may be skipped if the Registrar has concerns about the safety of a company’s operations. He further stated that the Ministry maintains statistics, collected as of January 2018, which indicate that roughly 80% of operators have a 10% or less violation rate and over 96% of operators fall below the first intervention level, of 35% VR. Carriers with a violation rate between 85 -100% comprise only 0.18% of carriers, and those with a % VR over 100% make up 0.08%.

c) The appellant’s safety record

21The appellant was first issued its CVOR on December 16, 2014. By August 20, 2018, it had reached or exceeded the first intervention level (35% VR) and was issued a warning letter. Less than three months later, on November 14, 2018, the appellant was assigned a “Conditional” safety rating, indicating that it had an on-road performance level that exceeded 70% of its overall CVOR threshold.

22There was no improvement to its record following the aforementioned interventions and on April 25, 2019, the appellant was called in for an interview with the Ministry (the “April 2019 interview”). Mr. Donohue conducted the April 2019 interview on behalf of the Ministry.

i. The safety record before the April 2019 interview

23The focus of the April 2019 interview was the two-year performance analysis period from February 18, 2017 to February 18, 2019 (the “analysis period”), in which the appellant had accumulated an overall violation rate of 87.75%. The CVOR information the Ministry had regarding the appellant indicated that it had 20 trucks and 20 drivers under its operation during that period and had reported 2,221,900 kms as its kilometric travel.

24The appellant’s collision performance during the analysis period was very poor, resulting in a collision violation rate of 83.5%. It had been involved in sixteen collisions, nine of which were at-fault collisions and were assigned points. Mr. Donohue explained that collisions are pointed based on severity (property damage, personal injury or fatal injury) and impropriety (vehicle defect, driver action, driver condition) as noted on motor vehicle accident reports from police.

25Broken down even further, the appellant’s collision record indicated that there had been one collision involving driver condition, seven collisions resulting from driver action, one collision with vehicle defects, and four collisions where charges were laid.

26The appellant’s conviction performance was also very poor during the analysis period, having attained a conviction violation rate of 106.36%. In total, there had been 23 convictions which related to speeding, vehicles being overweight, vehicle maintenance and insecure loads.

27Mr. Donohue addressed the conviction violations with the operator at the interview, inquiring into whether the appellant believed that its practice of paying drivers by the load could be a contributor to speeding, where drivers are motivated to speed in order to move as many loads as possible in a day.

28Mr. Donohue did not comment, in his testimony, on the appellant’s inspection violation rate, however the Tribunal notes it was at 59.11% during the analysis period. The Ministry’s interview sheet indicated that inspections were discussed with the appellant at the April 2019 interview, with one particular inspection, dated April 3, 2019, being discussed in some detail. That inspection revealed three defects, with weight being an issue, and also included one out-of-service defect in respect of the condition of the vehicle’s tires. Mr. Donohue explained that out-of-service vehicle defects pose an immediate danger to the public, such that when an out-of-service defect is identified, points are awarded to the carrier and the vehicle is immediately taken out of service until it is repaired.

29At the time of the interview, the sole officer and director of the appellant, Mr. Raza Ahmed, reported that he had installed dash cameras in fifteen of the vehicles and that the remainder of the vehicles would have cameras installed within 30 days. He also produced a copy of an action plan, which identified three broad areas in which the appellant was undertaking to improve. The action plan was signed by the appellant above the statement that “Failure to meet the commitments of the Action plan or improve compliance, can lead to Sanctions.”

30Significantly, the first action indicated that drivers were to be trained in defensive driving, conducting proper pre-trip inspections, and they would undergo a road test. The appellant indicated it expected fewer or no collisions, and that fewer or no vehicle defects would result from these actions.

ii. The record after the April 2019 interview

31Despite the appellant’s commitment to improve its safety record and undertake certain measures, the appellant’s safety performance did not improve and less than a year later, on February 6, 2020, the Registrar issued a Notice of Cancellation and Seizure and invited the appellant to a Show Cause meeting. The basis for the proposed cancellation and seizure related to the appellant’s safety record, which again revealed unacceptable performance.

32At the time the Notice was issued, the two-year performance analysis period had shifted forward, and represented the period from January 6, 2018 to January 6, 2020 (the “further analysis period”). Instead of decreasing its violation rates, during the further analysis period the appellant reached 97.26% of the collision threshold, 148.93% of the conviction threshold, and 83% of the inspection threshold. Its overall violation rate increased to 115.08% resulting from multiple at-fault collisions, convictions for speeding, weight issues, driver action and vehicle maintenance issues.

33Specifically, the appellant was involved in 20 collisions during the further analysis period. More significantly, however, is that 11 of the 20 collisions occurred after the April 2019 interview, with six of those collisions involving an impropriety of the driver and two of the collisions involving injuries.

34During the further analysis period, there were also 32 pointed convictions and an out-of-service rate of 21.88%. The bulk of the convictions related to driver actions, for example, speeding, disobeying traffic lights, and driver inattention. Further, of the approximately 26 inspections that occurred between the April 2019 interview and February 5, 2020 (the date the CVO record supporting the Notice was generated), the appellant’s record indicated 20 defects, as discovered through inspections, of which five resulted in the vehicles being placed out-of-service.

35Mr. Ahmed attended the Show Cause meeting on March 3, 2020 with Mr. Zafar Iqbal and Mr. Sarabjeet Gogia. Mr. Iqbal, a safety consultant employed by the appellant in 2019, had also been present with Mr. Ahmed at the April 2019 interview, while Mr. Gogia was introduced at the Show Cause meeting as a general manager, having been hired in November of 2019 to help Mr. Ahmed with his operations. The focus of the meeting was on the appellant’s safety record, and the Ministry zeroed in on the fact that the same types of infractions appeared on the appellant’s record as were there before the April 2019 interview.

36Notably, at the Show Cause meeting, the Ministry raised its concerns with the appellant in respect of its CVO report recording 3,146,501 kms travelled, with 30 trucks, despite that Mr. Ahmed stated at the meeting that he was only operating 19 dump trucks and one truck with a pony trailer. Since he also stated that each of its trucks was travelling between 10,000 and 12,000 kilometers each year, Mr. Donohue said he expected the appellant’s true reported mileage to be closer to 2 million kilometers.

37The Act requires operators to report fleet size and travel information to the Ministry within 15 days after a change in the fleet size of 20% greater or less than last reported. Mr. Donohue testified that the kilometric travel is particularly relevant to the Ministry’s analysis when reviewing an operator’s CVO record, since threshold points are assigned based on the number of kilometers travelled. If an operator overreports its travel, it is assessed at a higher point standard and the operator’s violation rate would ultimately appear to be lower than its actual rate.

38The appellant provided an action plan at the Show Cause meeting, however Mr. Donohue stated that it highlighted continued deficiencies and concerns for the Ministry. For one thing, it was substantially the same as the one provided at the April 2019 interview. The updated action plan again made mention of the dash cams, stating this time that “dash cams have been installed in ten trucks, and cameras for the rest of the fleet are on order.” This statement seemed to contradict the one Mr. Ahmed had previously made, when he reported that the appellant had already installed fifteen dash cameras.

39Further, the financial model set out in the action plan indicated the appellant was not able to change the way that it paid its drivers, which was in some cases by the load and others by the weight transported. This model was identified by the Ministry as being a potential contributor to the appellant’s poor performance record, where drivers are incentivized to speed or overload their vehicles.

40The appellant was asked to submit an additional action plan, outlining specifically how it would gain the knowledge to run its business safely. This plan was requested by March 15, 2020, yet the appellant submitted its further updated action plan only after the Order was issued, on or about April 13, 2020 (the “2020 action plan”). The 2020 action plan was substantially similar to the one the appellant produced at the April 2019 interview, again referencing installing dash cameras and focusing on delivering training for defensive driving and pre-trip inspections, follow-up reviews after collisions occur and updates to company policies.

b) Improvement to the appellant’s safety record

41The appellant did not significantly challenge the Registrar’s evidence with respect to its non-compliance with its legislative responsibilities or its safety record. However, at the hearing, the appellant produced its CVO record from September 28, 2020, which revealed that its overall violation rate had reduced quite significantly (based on the two-year analysis period from August 30, 2018 to August 29, 2020 (the “most recent analysis period”)), to 72.2%.

42Mr. Ahmed testified that the appellant has taken steps to improve its performance record, concentrating particularly on its efforts to prevent drivers from accumulating violations and ensuring that no further events appear on the CVO record. While admitting that its previous company disciplinary policy was quite relaxed and would afford drivers multiple chances, he explained that it has now implemented a much stricter policy, where drivers who are found to be at-fault in collisions are being terminated immediately. Drivers are informed, he said, from their first day working for the appellant, of its zero-tolerance policy.

43Mr. Ahmed expanded that since the Show Cause meeting, the appellant has fired six drivers. Five of those drivers were terminated for their involvement in at-fault collisions, and the sixth was terminated as a result of a “bad inspection.” Mr. Ahmed further confirmed that between January 2020 to October 15, 2020, the appellant had only been involved in one collision, where the driver was not deemed to have been at fault. Moreover, there have been no convictions reported on the CVO record since an event which occurred on December 13, 2019.

44Finally, Mr. Ahmed explained that the appellant has delivered two training sessions to its drivers, covering pre-trip inspections and how to secure vehicle loads. These two sessions were conducted in June and September of 2020.

E. ANALYSIS

45The Registrar has the onus to prove that there is reason to believe the appellant will not operate a commercial motor vehicle safely or in accordance with the Act, the regulations and other laws relating to highway safety. I find that the Registrar has more than satisfied that burden in this regard.

46The appellant has been subject to Ministry interventions since August 20, 2018, when it received its first warning letter. The expectation after that point in time would be that the appellant would make changes to its business practices and take necessary remedial measures to bring its % VR score down to a more acceptable level. It did not do so. Instead, its overall violation rate increased in the subsequent analysis periods, with higher numbers of reported collisions, convictions, defects and out-of-service defects discovered through inspections. The fact that there were more collisions occurring in the period after the April 2019 interview than before is of particular concern to me and indicates that the Ministry’s interventions did little to change the appellant’s practices and conduct.

47And while the appellant’s safety record does appear to have improved, at least on paper, in the short period between January 2020 and the date of this hearing, I find that the Registrar’s concerns regarding the continued safe operation of its business continue to be well-founded.

48To begin, I am mindful that the appellant’s misreporting, or failure to report, its reduced kilometric travel and fleet size means that its actual current violation rate is unknown. At the Show Cause meeting in March 2020, the appellant indicated its fleet comprised 20 vehicles and during the hearing, Mr. Ahmed testified that this number had been further reduced after that meeting, to twelve vehicles. Despite this fact, the CVO record that was generated on September 28, 2020 still indicates the appellant has 30 vehicles traveling over 3 million kilometers per year. Mr. Donohue’s evidence was that threshold points are assigned based on mileage, such that operators reporting higher kilometric travel are assessed at a higher point threshold, meaning that their violation rate would ultimately be lower. It is reasonable to assume, then, that the appellant’s 115% violation rate during the further analysis period and the 72% violation rate in the most recent analysis period grossly understates the company’s performance.

49The basis for the appellant’s appeal is that there has been an improvement in the safety record and more improvement is expected as a result of changes it has implemented more recently, for example with driver training and stricter employee policies in place. These efforts are long overdue, however, and seem to only have come about as a result of the Registrar’s more recent sanction proceedings.

50Not only that, I find that the appellant’s attempts to improve its record have been half-hearted, and do not instill confidence that they will adequately remedy the company’s continued safety issues. For a period of years, the appellant has allowed its vehicles to operate on Ontario roadways with defects, some of them major, and has substantially failed to comply with its operator responsibilities by not adequately monitoring or resolving driver safety issues. Many of the Ministry’s earlier concerns persist, and the appellant provided very little evidence to demonstrate it has taken concrete steps to seriously action what it has committed to do over the last few years.

51This lack of action is demonstrated first by considering that many of the remedial steps the appellant undertook in its initial plan have simply been carried forward and restated in the 2020 action plan. In the 2020 plan, the appellant specifically undertook to create written reports in respect of collisions, conduct defensive driver training and random spot checks to monitor performance, update and clarify company policies and document the preventative maintenance program, among other things. Yet the Tribunal received no evidence of any of these practices or actions being implemented – no collision reports were filed, no training materials were provided, nor were updated written policies produced. Mr. Gogia, whose qualifications are unknown, was touted as being instrumental in developing and implementing the 2020 action plan, including providing driver training sessions, but yet Mr. Gogia was not called to testify.

52The only information put forward to demonstrate how the appellant has implemented its plan are the driver sign-up sheets for training from June 13, 2020 and September 12, 2020. On its face, the logs comprise a sign-up sheet, with seven training topics listed, including “Logbook, HOS, PTI, Load Securement, Company Policies, Winter driving, Defensive Driving”. Despite this, Mr. Ahmed testified that not all of the listed topics were covered in the sessions, and that the training focused instead on pre-trip inspections, how to secure the loads, and general knowledge about the vehicles. Each session lasted between forty minutes and one hour.

53When Mr. Ahmed was asked why the training sessions did not cover more information, for instance to provide defensive driver training (as undertaken previously), or why they lasted no longer than one hour, he stated that the drivers did not have the time for a longer training session, as they wanted to be back on the road. Perhaps more concerning, however, is the fact that Mr. Ahmed testified that the training was not mandatory, and that some of its drivers, including at least one of whom had accumulated points for vehicle defects and another in respect of a collision, did not attend either of the training sessions.

54The appellant’s unwillingness to take the time to properly educate its drivers on expected conduct and safety practices indicates not only its lack of commitment to administering needed improvements, but also that the appellant cannot be trusted to set and hold its drivers to an expected standard. This, while sanction proceedings are pending, is particularly concerning to me. Furthermore, considering the appellant indicated it intends to continue its practice of paying drivers by the load, and seeing that the appellant tends to reinforce the notion that time is of the essence by rushing drivers through its training sessions, I find that the legitimate concerns the Ministry expressed about speeding and weight issues, which it found contributed to the number of collisions, are likely to continue.

55Secondly, Mr. Ahmed stated that the company has put in place much stricter policies, such that drivers who are involved in at-fault collisions are now subject to immediate termination. Notwithstanding this statement, a particular driver (“Driver A”), whose record was very poor, continued to be employed by the appellant until at least December 2019, despite multiple convictions and collisions. During his employment, Driver A was involved in three at-fault collisions; one involving a non-fatal injury caused by exceeding the speed limit, one for losing control and inattentive driving, and one involving a non-fatal injury for following too closely. That same driver was also convicted for disobeying a red light and, on a separate occasion, for speeding. On yet another occasion, Driver A’s vehicle was placed out-of-service after an inspection revealed an unsecure load. Mr. Ahmed testified that Driver A was terminated after an accident where he was found at fault for following too closely in November 2019. However, Driver A was not terminated at that time, and was allowed to continue driving for the appellant until at least December 13, 2019, as evidenced by the fact that he was convicted for an incident that occurred on that date.

56Further, there is no evidence that any such policy applies to drivers receiving poor vehicle inspections, with one particular driver having been cited for out-of-service defects and multiple other defects on three separate occasions between January 2020 to June 2020 and another driver whose vehicle was placed out-of-service in respect of three defects during one inspection in August 2020. At the time of the hearing, both drivers continue to be employed by the appellant. Remarkably, neither of these drivers attended the appellant’s training sessions.

57Finally, it concerns me that Mr. Ahmed, as the appellant’s sole officer and director, has shown a general reluctance to take responsibility for events and improprieties that occurred under his leadership, choosing instead to pass the blame and make unsubstantiated excuses.

58For example, on every occasion when the Ministry discussed the appellant’s record with respect to its collisions and convictions, Mr. Ahmed blamed the drivers for any impropriety. Similarly, in response to questions about whether he updated the appellant’s information with respect to mileage or fleet size, Mr. Ahmed asserted that he did report the information to a Ministry employee by email on or about February 11, 2019, implying that she may not have updated the information on the Ministry’s end. That alleged email was not produced in evidence at the hearing, however.

59Furthermore, in addressing the six out-of-service inspections that were uncovered from the period January 2020 to September 2020, Mr. Ahmed stated that one vehicle was placed out-of-service because the truck was not standing at level during the inspection, and another had suspension problems which were known to the manufacturer, and that the appellant had received a letter explaining the defect. Once again, neither of these claims were supported at the hearing by any evidence. Instead, the appellant’s representative suggested that Mr. Ahmed was intimidated by people in authority, suggesting this might have been the reason he did not challenge the inspection findings.

60The appellant’s representative submitted that the appellant is deserving of another chance to operate the business in a safe manner and proposed that it would:

• commit to the corrective action plan submitted to the Registrar on or about April 13, 2020;

• not exceed 50% overall safety violation rate for one-year performance period commencing after sanction;

• not exceed 50% inspection violation rate for one-year performance period commencing after sanction; and,

• not fail a facility audit conducted by the Ministry.

61Registrar’s counsel argued that the conditions are not appropriate in the circumstances because the appellant has already been given ample opportunity to implement the action plan and there has been no concrete efforts to do so.

62I find that this is not a situation where registration subject to conditions is appropriate. Given the appellant’s past safety record, the continuing concerning record, including the limited efforts it has made to remedy the deficiencies in its operations, and its apparent disregard for its responsibilities as an operator, the proposed conditions are not adequate to address my legitimate concerns about public safety.

F. ORDER:

63Having reviewed the evidence and taken into account the submissions of the parties, and pursuant to s. 50 of the Act, I order the Registrar to carry out the Order dated April 1, 2020, to cancel the appellant’s CVOR certificates and seize the permits and number plates of its vehicles.