Yes, it would be easier to have discretion in some areas, but there are advantages to having clearer rules as well, which is why I have some focus on establishing guidelines so people know where I'm going. There's room for interpretation even within the four corners of the act as well, but it's the difficult cases. There are some instances, and I can't think of any off the top of my head, but here and there throughout the act there are places where a little more discretion might help, as with the summer students, for example.
Evidence of meeting #6 for Access to Information, Privacy and Ethics in the 40th Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was office-holders.
A recording is available from Parliament.