There's an argument to be made. I'd like to have a little debate offline with you on whether it's valid, but my recommendation number 12, which would allow time extensions for multiple and simultaneous requests by single requesters, would go a long way to cure that in terms of the pressure on the agency and the number of complaints that result, as well as giving discretion to the commissioner on whether to investigate or not.
In Ontario, a limit has been imposed on the number of complaints any one individual can hold with the commissioner. The commissioner has that discretion.