This point is in response to this secondary discretionary feature that's been built into the regime, whereby administration of justice offences are stacking up and creating a large fine. There is specific discretion to reduce the fine in light of that stacking, but there exists no equal mechanism for non-administration of justice offences.
I agree with you that it might be redundant if we expand the discretion generally to everything and get rid of this one specific example, but if you're going to extend this secondary discretionary feature to administration of justice offences, then we see no reason why it should not be expanded to substantive offences that are stacking up in the same way.