The significant part of duties is a threshold for in-house lobbyists. Historically it's been interpreted quantitatively, rather than qualitatively because when you read “significant part of the duties”, you could think that “significant” also means the importance of the issue for them, but historically it's always been calculated in time. So it's 20%, meaning one day a week for about a month, total, and it has to be the total of the whole organization and not just one person, so you add up everybody's time.
The problem is that the act is written in such a way that it's not transparency by design; it's the reverse. You only have to register if you meet that 20%, so the onus is on the lobbyist to decide whether he meets that 20%, rather than the reverse, that you must register unless.... Then we need to have that discussion of whether you want every single in-house lobbyist to register. That's a policy decision. There must have been, at some point, a discussion when the act was enacted that you wanted someone to be paid and it had to be about a registerable activity. That's the second thing we need to look at. It has to be about the change of a state of affairs—about a law, about a regulation, about a program, about a policy, or asking for money. That's the second thing we need to look at.
The law is quite prescriptive in a way, and I think that needs to be fixed.
I hear you on the significant part of duties, and I will always interpret the law to meet the spirit of it, but I also have to look at the second step of whether it's an activity that is actually registerable.