As an observer, again, I'm looking at this from more of a layman's perspective. It would appear that what you have done in reducing some of the exclusions you have in clause 78 for other purposes--not defined as spam--is that you've in fact opened yourself up to some pretty substantial changes in PIPEDA, which were never intended or perhaps not contemplated by the limited nature of that legislation as it was first presented.
Do you not believe that we should perhaps have a separate, stand-alone piece of legislation to introduce these rather substantial changes, whether it's implied consent or explicit consent that's required? It sounds like you're biting off quite a bit more than you can chew and, more importantly, possibly opening us up to the countervailing view that this is far more broad-reaching than it ought to have been.