I think the first place to start on this question is that approaching government and petitioning government is a right, not a privilege. I don't think any legislative measure or any bureaucratic decision within the public service should try to remove that right from people.
Trying to shape the lobbying activities to conform with a legislative and regulatory framework is the prerogative of Parliament and its officers, and we recommend to our members that they follow all of that regime.
Our recommendation to eliminate the 20% rule as it applies to corporate in-house lobbyists is not, I can tell you, a unanimous recommendation. Many of our members came to us saying, “Are you guys nuts? I have friends who work for this company who are not going to be able to keep their jobs”, or saying, “I'd like to hire so and so, who is in government and wants to get out, and now I can't.”
We made that recommendation because we maintain that the rules should be the same for everyone and should apply equally to everyone. If I'm coming out of a minister's office, I can't work at a trade association, I can't work for a consultant lobbying firm, but I can work for a corporation doing exactly the same work, as long as I determine that it's 19% of the time.
As you rightly point out, that's just a recipe for confusion. We understand that it was meant as a guideline, but it's been treated as a loophole. We wouldn't suggest that you reset the level to create another guideline that could then be treated as a different kind of loophole.