That's a very important question. It's an important difference between our acts, and it's very important and insightful to shine a light on it.
In British Columbia, the purpose of the act is to make sure that there is a transparency function, so the public is able to see what's going on. The general principle at work here is that if the public is able to see something through a means that is already public, and there's already a transparency function, it does not necessarily need to be duplicated.
With respect to, let's say, the procurement process, there is transparency reaching through the procurement regime, and the transparency function is achieved there. If someone is following the procurement process that is governed by that legislation, the lobbying activity in trying to get a government contract is not required. If a lobbyist steps outside of that and tries to influence that outside of the formal procurement process, that influence becomes lobbying. The key is the concept of influence, where someone is trying to influence decisions as opposed to participating in an established process.
The same would apply to grants. Let's say a non-profit organization is participating in a grant project. Of course, non-profits do a lot.... That's a big part of the business for non-profits. If it's putting 30 hours of work into preparing a grant application, that work does not count towards lobbying. If it gets a meeting with a senior public office holder, and it tries to influence the awarding of that grant outside of the grant application process, that is lobbying. That's a key difference between the provincial and federal acts, and it's insightful of you to put your finger on it.
