Thank you very much, Mr. Chairman and honoured members of the committee.
Good morning. Bonjour.
The Canadian Society of Association Executives, commonly called the CSAE, welcomes this opportunity to comment on Bill C-2, the Federal Accountability Act, and is pleased to participate in its review on our members' behalf.
As the chairman mentioned, my name is George Weber. I'm the current chair of the CSAE. In my day job, I'm the executive director of the Canadian Dental Association. With me this morning is Michael Anderson, the CSAE's president and chief executive officer.
The CSAE is the professional organization of 1,600 men and women who manage many of Canada's most progressive trade, professional, occupational, philanthropic, and common-interest organizations, which in turn consist of 14.5 million individual and two million corporate members. An additional 600 business members that provide services and products to the sector also comprise an integral part of the CSAE's membership.
The CSAE and its member organizations support government initiatives to strengthen the rules and institutions that ensure an increased transparency and accountability to Canadians. We share those goals, and with the exception of two concerns are pleased to support the overall legislation commonly short-titled the Federal Accountability Act.
Our first concern relates to the restriction on lobbying activity that enshrines a five-year prohibition on lobbying activities for ministers, their staff, and senior public servants. We believe that government officials should maintain the right to move freely from government service to the not-for-profit sector in view of the unique relationship that non-profit organizations currently enjoy with the federal government.
Senior staff and CSAE member organizations who lobby government are defined by the Lobbyists Registration Act as in-house organization lobbyists. They lobby government officials, and their primary focus is to seek common good for all their constituents.
It is our position that eliminating this five-year moratorium or replacing it with a more reasonable period would ensure the continuing maintenance of a unique exchange of information and consultation that currently benefits both the government and the sector. Failure to remove this time constraint will ultimately dissuade government officials from working for not-for-profit organizations that provide societal benefits to Canadians.
Our second concern is the obligation to report all contacts with designated government officials. The act requires that in-house organization lobbyists record all registerable activities--with certain exceptions, such as chance encounters that may take place with senior officer holders--including who was met and what was discussed, and lobbyists must file regular reports with the registrar. And it will be monthly, as noted in the proposed legislation.
The CSAE is concerned that new and more frequent reporting requirements may lead to situations where contact with government officials is severely curtailed or avoided altogether. The free flow of information--research, knowledge, and consultation--between the government and the sector will be curtailed, and as a result, the informed decision-making process that currently exists will be weakened.
Will recording contacts with senior public office holders truly advance the public policy process to address issues in the public interest?
As you know, many not-for-profit organizations currently register twice annually--and Mr. Nelson has just noted the numbers, which are larger than for corporate or consultant lobbyists--through the Lobbyists Registration Act registrar. They provide updates on the issues and subject matter discussed as well as the government department or institution contacted.
We are concerned that increasing this compliance requirement will prove to be an onerous, time-consuming burden that will result in a loss of productivity for the many not-for-profit organizations currently facing resource constraints. As an aside, we should be aware that one-third of our membership have one to four staff members, so we're just adding an additional burden to their already heavy workload.
We encourage the committee to maintain the current reporting status for in-house organization lobbyists.
Honoured committee members, on behalf of the members of the CSAE, I would like to thank you for the time you've allowed me to express some of our concerns. We would be pleased to respond to any questions or points of clarification you may have.
Thank you.