Eye, Knowledge, Road Tests After 30-day Demerit Point Suspension?

Hi,

So I had 15 points accumulate between the offence dates may 2016 - apr. 2018. Ive had none since. Ive been fighting them in court, which finalized jan 8 2019. Some points came off. We were careful to spread them out so I could avoid a suspension of accumulated points on my record.

So I get suspended because of accumulation of 15 within two years, triggered by the system because of the offence dates. I had 9 points when my licence was suspended:

Question 1: Does this make sense? It didn't make sense to the traffic fighting paralegals I retained to help me. Should it not be based on conviction dates, ie innocent until proven guilty etc?

Second: I get a notice of outstanding licence requirements with a temporary licence attached. My suspension ends Feb 21 2019. I have to take eye, knowledge and road tests before Apr. 22 2019. I call the driver control center. I argue with them, saying it says no where in the HTA or on ontario.ca that I have to retake tests after a 30 day suspension. It's very clear regarding 1-3 years, 3-10 years suspended/invalid licences.

The agent says it's an internal policy and isnt posted anywhere, then gives me an e-mail address that is a dead end. An important detail: At my 9-month interview they tested my eyesight and asked me questions. The end result was that they interviewer checked a box stating "No further intervention needed" as I was improving my driving.

Being a driver, I was driving from Apr. 2018 until Jan 2019, with no further points. Another agent says the reviewing officer requested the tests.

Question: Has anyone heard of this before? Does the demerit point system not address this at the 9-point interview? Ontario.ca is very clear that the time to retake tests would be issued at the 9-point interview.

I work in my car. So the risk of having my licence cancelled because of a written or road test going wrong is extremely nervewracking. I don't see anywhere where it says this is normal for a 30 day suspension following demerit points. I see it for medical and criminal suspensions, and for licences invalid for years.

Any insight would help me alot, as I plan to keep arguing this and have tried complaining to the ombusman, but well see what happens with that.

Thanks

Frank