First of all, I am not saying that the act is working; it's quite the reverse. The fact that it's been in existence for 25 years, I think on this point..... So has the charter. They were enacted one year apart.
What doesn't work is making changes to a moving target, and that's really what you have. Any one of the twelve recommendations will do nothing to ameliorate the current situation. What is the current situation? We have institutions that have very little respect for the act. Today at my office, just by happenstance, I received three replies to three requests that I had put in about a month ago. The replies are from the Privy Council Office asking for an extension of 210 days. That's one aspect of the act. Currently, as worded, it simply doesn't work.
My only choice as a requester in the face of this is to submit a complaint to the Information Commissioner. The Information Commissioner right now has a backlog of two years. I know from current experience that it will require at least two years to get a response. The act, when you submit a request, basically says you'd better be patient because the norm is two years.
My point is, change it if you must, but none of these 12 recommendations will, in any way at all, change either the backlog of the Information Commissioner or the institution's lack of respect for the act. My recommendation is that you need to address this first.