It says in your letter,
“A finding of such inadmissibility would render you inadmissible to Canada for a period of five years according to section 40(2)(a):”
So come clean and explain that the refusals and maybe it will be overturned. However don’t expect a study permit.
Cmon, it sounds like procedural fairness letter rather than outright ban as the letter clearly states to respond within 15 days or else permit will be refused.