Information & Ethics committee  I think it's clear that the point of the recommendation is that transparency should trump some of those circumstances where small groups are doing occasional lobbying, assuming they are actually engaged in registerable activity; that is, they're paid and communicating to government about specific policy changes and the various activities defined in the Lobbying Act as it is now.

Information & Ethics committee  There's no jurisdiction that I'm aware of in the OECD that would do that, that has legislation around this kind of matter. It's all narrowly defined in terms of actual direct communications to government or third-party communications. That is what is defined as grassroots lobbying; that is, a call to action whereby a lobbying organization gets a number of people to write letters to MPs or develops advertising and that kind of thing that is advocating a specific legislative or policy change.

Information & Ethics committee  There are differences, but I don't know if there's confusion. For example, the federal system requires the filing of monthly communications reports that the lobbyists would have with designated public office holders, as do B.C. and Alberta. Manitoba has legislation; it's not in force.

Information & Ethics committee  Generally speaking, there is a distinction in the act. Certain types of communications are registerable communications. Certain types of government relations consultants and firms would not have direct conversations with government. They would advise clients on, for example, who makes what kind of decision.

Information & Ethics committee  Right now the provincial jurisdictions that have lobbying registration systems have a cooling-off period for political staff or public office holders of one year. There are some differences, such as a cabinet minister, for example, who was involved in sensitive negotiations in a particular sector becoming a lobbyist in the same sector where his or her ministry dealt with a variety of very sensitive files.

Information & Ethics committee  There are also some complexities involved in the nature of the Lobbying Act. If you are a member of a board of directors for an organization and you routinely lobbied on behalf of that corporation, for example, you would be considered a consultant lobbyist. There may be some complexities around that.

Information & Ethics committee  A number of individuals have consulted with the commissioner's office around certain kinds of grey areas involving different kinds of cases that may or may not involve registerable activity--certain kinds of organizations, certain kinds of communications. For example, what exactly is, as the GRIC mentioned, an oral and arranged communication?

Information & Ethics committee  Yes. It's about just making sure that the rules are consistent and easily understood across the board among all organization, in-house, and consultant lobbyists. I think Charles's point about the exemption for the small individual who might lobby once in a blue moon.... The issue is also a question of fairness.