Well, the exclusions and the loopholes define the rights to access, and so you're right. The Access to Information Act is actually more loophole than it is rules in providing access. The purpose in subsection 2(b) “is to enhance the accountability and transparency of federal institutions in order to promote an open and democratic society and to enable public debate on the conduct of those institutions”, but the rest of the act does not fulfill that purpose in any way.
The 18 changes I'm calling for today, and that have been called for by many others in the past, would actually turn it into an open government law instead of a guide to keeping information from the public that they have a right to know.