I think it's difficult to cast in words easily, but one of the issues is simply that the Telecommunications Act is perhaps not the best place to have this kind of regime, in any event. When you look at the “do not call” list today, it is a somewhat awkward fit with the Telecommunications Act. That is not to say the CRTC hasn't done a magnificent job making it work and applying it. It is early days.
The Telecommunications Act in this regard very much deals with some of the same subject matter as ECPA. For that reason it was necessary to consider the links and possible conflicts between the two. Those are not as apparent today as they will be in a few years.