If someone is communicating with you with regard to your decisions, then that's lobbying, and it should be registered.
The only exception should be if someone signs a petition or a letter-writing campaign through a website of an interest group. Then the interest group should have to register. The fact that the person just signed on to that letter-writing campaign or petition should not require them to be registered.
Otherwise, if you leave any loophole open for unpaid lobbying, like this issue of allowing business board members to be considered employees.... GRIC wants that. They also want, then, those people to be allowed to lobby for 32 hours without having to register. Lots of big businesses put former ministers on their boards, and then that minister spends 31 hours of the month on the phone lobbying, and they don't have to register. It never shows up. That's why GRIC wants that.
I wouldn't listen to anything that GRIC suggested. It was all self-interested and to keep things like this hidden.