I could say the same thing about any of the exemptions. They're all, unfortunately, too broad. They all need to be narrowed. Section 20 is one of the most regularly abused. That's our general recommendation. There can be a specific discussion about how to narrow any particular exception.
There are also exclusions, and those exclusions should all be turned into exceptions, because currently with exclusions, the commissioner has no power to review the documents to determine whether they're being withheld properly.
Those are the general recommendations I would make, and if you ask me about any of the sections, I would make the same statement. They're all too broad and they all need to be narrowed to ensure that what is not disclosed—for example, to protect national security, a police investigation or a cabinet decision-making process—is protecting only what really needs to be protected. Again, as the Liberals promised in 2015, government information shall be “open by default”.