In a letter addressed to Minister Goodale, Conservative MP's Michelle Rempel, Larry Miller, Bob Zimmer, Blaine Calkins, SECU Member Glen Motz, Public Safety critic Pierre Paul-Hus, CFAC Chair John Major, CFAC Vice Chair Lynda Kiejko, ethics critic Peter Kent and the Ethics Commissioner, the CCFR's Tracey Wilson requested 3 immediate measures in light of CFAC co-vice chair Nathalie Provost's actions. While the Lobby Commissioner may have found Provost did not violate the Lobby Act, simply by unregistering herself as a lobbyist, it appears she did in fact violate the terms of reference agreement signed by her upon her appointment to the Minister's committee.

The letter included a request from Wilson that immediate action be taken.

"...There are some immediate measures that should be implemented to rectify this situation;

1. Miss Provost should be removed from her appointed position on the committee. She clearly violated the terms of reference she agreed to, damaging the integrity of the work done by CFAC.
2. Minister Goodale should be reviewed by the Ethics Commission for permitting this kind of insider lobbying and violation of the terms of reference.
3. C-71 should be suspended pending an independent investigation into the insider influence and its affects on the legislation. I am sending this to the Senate to request this.

I encourage you all to consider the integrity of the committee. The deciding factor here in the decision by the Lobby Commissioner to dismiss my complaint about her insider lobbying seems to boil down to whether or not Provost gets a paycheck from the Quebec anti-gun lobby organization.
While Provost may have been cleared of any violation of the Lobby Act, she has clearly violated the Terms of Reference for CFAC. I would expect this government to take its own advisory committee seriously and find a more suitable delegate for the position."

Wilson awaits a response from the Minister and the other stakeholders.

Full text of the letter: 

Dear Minister Goodale et al;

Black’s Law dictionary, Sixth Edition, defines “lobbying” as “All attempts including personal solicitation to induce legislators to vote in a certain way or to introduce legislation. It includes scrutiny of all pending bills which affects one’s interests or the interests of one’s clients, with a view towards influencing the passage or defeat of such legislation.” That definition is consistent with the use of the term in the Lobbying Act (Canada).
In February 2017, Natalie Provost was appointed as vice-chair of the Canadian Firearms Advisory Committee (CFAC). In being so appointed, Ms. Provost specifically agreed to the following Conflict of Interest provision in the “Terms of Reference” of CFAC:

“Any member participating in this committee in his or her own personal capacity or as an authorized representative of a specific organization or corporation agrees for the duration of his or her term as a member of this committee not to … Engage in lobbying activities or work as a registered lobbyist on behalf of any entity making submissions or representations to the Government of Canada on issues relating to the mandate of this committee.”

Take careful note of the disjunctive “or” between “lobbying activities” and “work as a registered lobbyist” in the conflict of interest provision of the Terms of Reference of CFAC; there are two prohibited activities, not one.
Notwithstanding this agreement, during her appointment as vice-chair of CFAC, Natalie Provost signed a letter dated November 24, 2017 to the Members of Parliament of the House of Commons, on behalf of Poly Remembers, which included the following excerpts:

“MEMBER OF PARLIAMENT
HOUSE OF COMMONS
OTTAWA
Subject: Strengthening the Firearms Act
…
In this letter we would like to present to you our expectations relating to changes to the Firearms Act, including measures that were in the Liberal Party’s election platform, which should be tabled before the end of the year, according to the recent statement by the Minister of Public Safety.
…
RECOMMENDATIONS:
1. Tighten eligibility criteria and strengthen the screening process for people wishing to acquire, renew or keep a Possession and Acquisition Licence (PAL);
2. Forbid all marketing that encourages multiple registrations with respect to firearms safety training courses;
3. Strengthen the measures related to the sale and transfer of firearms, including the reinstatement of mandatory verification of the validity of a potential buyers licence;
4. Reinstate the full discretion of Chief Provincial Firearms Officers as well as the full authority of the RCMP with regards to establish additional safety conditions associated with the granting of licences and the classification of firearms according to the law, respectively;
5. Reinstate the controls over the sale of non-restricted weapons, including inventory controls and sales ledgers for gun merchants as well as the requirement to notify authorities of private sales;
6. Reinstate transportation permits for restricted weapons so they include the locations in which a specific weapons can be present;
7. Ban assault weapons, which are designed for killing humans, once and for all; and
8. Revise the measures on large-capacity magazines in order to eliminate an important loophole and impose a real limit of 5 rounds for non-restricted weapons and 10 for restricted weapons.
We are convinced that these demands are reasonable and perfectly coherent with a society founded on peace, order and good government. We hope we can count on you to support these measures in order to make the public interest the government’s priority rather than the interests of a loud minority of opponents of gun control.

Heidi Rathjen, B.lng., Dr.h.c., LLD, C.S .M
Coordinator

Nathalie Provost. B.lng. MB
Member and spokesperson”
(The “Firearms Act Lobbying Request Letter”)

Receipt of the Firearms Act Lobbying Request Letter was confirmed on December 12, 2017 by Global Affairs Canada on behalf of Chrystia Freeland, Minister of Foreign Affairs, with the advice that it was forwarded to Ralph Goodale, Minister of Public Safety and Emergency Preparedness for his consideration. Presumably it was also received by all of the other Members of Parliament to whom it was addressed.

Unquestionably, this constituted an attempt to induce legislators to vote in a certain way or to introduce legislation with a view towards influencing the passage or defeat of such legislation. Obviously Ms. Provost was lobbying the government when she signed this letter.

Unquestionably, Ms. Provost blatantly disregarded her agreement to abide by the Conflict of Interest elements in the Terms of Reference governing her appointment to CFAC.

The only remaining question is this: what, if anything, is the Liberal government going to do about this?

There are some immediate measures that should be implemented to rectify this situation;

1. Miss Provost should be removed from her appointed position on the committee. She clearly violated the terms of reference she agreed to, damaging the integrity of the work done by CFAC.
2. Minister Goodale should be reviewed by the Ethics Commission for permitting this kind of insider lobbying and violation of the terms of reference.
3. C-71 should be suspended pending an independent investigation into the insider influence and its affects on the legislation. I am sending this to the Senate to request this.

I encourage you all to consider the integrity of the committee. The deciding factor here in the decision by the Lobby Commissioner to dismiss my complaint about her insider lobbying seems to boil down to whether or not Provost gets a paycheck from the Quebec anti-gun lobby organization.

While Provost may have been cleared of any violation of the Lobby Act, she has clearly violated the Terms of Reference for CFAC. I would expect this government to take its own advisory committee seriously and find a more suitable delegate for the position.

Many thanks,

Tracey Wilson
V.P. of Public Relations
CCFR
P.O. Box 91572
RPO Mer Bleue
Ottawa, ON, K1W 0A6