I understand the question.
This requires a review of 20 years of Copyright Board radio broadcasting tariffs, which obviously we don't have time for here, but the point of the matter is that, until 2016, radio broadcasters paid a certain amount for all of the copies they made. It was only in 2016, after the 2012 amendments had come into force, that the Copyright Board felt that it had to go through the exercise of slicing and dicing those copies and determining what value was allocable to which. It was then that the 22% exemption was instituted.
Your point is a valid one, because nothing had changed. The approach that radio stations take to copying music hadn't changed. The value that they derived from the copies hadn't changed. The only thing that had changed was the introduction of an exception that the Copyright Board believed needed to lead inexorably to a royalty reduction.
That's what I am reacting to, and that's what I'm suggesting to the committee ought to be re-examined.