From Process to Policy and Back Again

The imperative of academic knowledge mobilization in the legislative and political environment often means translating research about — and current practices in — culture, communication, and media into policy recommendations for regulators struggling to understand new social landscapes generated by, for example, digital platforms. Contemporary research into any form of cultural production has as its precursor studies about propaganda, influence, and representation, including the use of such production to promote or impose particular nation-state identities. Such issues tend to draw researchers into public debate through the practice of articulating policy recommendations including those that address understandings of social, economic and cultural ‘impacts’. This tendency is so ingrained in communication studies that it has been critiqued as a sort of “policy reflex” to automatically suggest the regulatory implications of any research study (Wagman, 2010).

We consider how the policy reflex works to modulate research methods in dirty ways, through the tensions between scholarship, civic practices, and advocacy within the colonial politics of policy making. The policy reflex is dirty in that it permeates the politics of research design by accommodating regulatory institutions that reproduce their imperialist foundations through modern bureaucracy. Scholars who engage in policy proceedings must comply with the requirements of regulatory institutions, and the dirtiness of discomfort pivots on this complicity. 

As central examples, we recount our own experiences attempting to intervene in media policy making at the Canadian Radio-television and Telecommunications Commission and in cultural policy making at arts councils and the Department of Canadian Heritage. These experiences are envisioned as forking paths that bend back on themselves in recursive loops starting and ending with the embodied politics of policy. Policy is not simply a set of codified stipulations but an assemblage of relationships between people and institutions, and these relationships are often uncomfortable, sometimes oppressive, and always dirty. Dirtiness here means trying to acknowledge our embodied complicity in the institutions that legitimize injustice while also navigating the ways that such complicity invites a constant reworking of our own research designs.

The politics of regulatory institutions

Essential to the legitimacy of policy making is precisely its appearance as apolitical. In democratic decision making, legitimacy comes as a result of “the free and unconstrained public deliberation of all about matters of common concern” (Benhabib, 1996, p. 68). From this Habermasian point of view, democratic deliberation requires a set of institutions that protect the values of fairness and rationality in enabling a public sphere to function. Such institutions must “represent an impartial standpoint” in furnishing decisions based on rational public processes if they are to claim legitimacy (Benhabib, 1996, p. 69). Such an ideal democratic situation invites critiques of the way legitimacy rests on institutions’ ability to represent a polity when not everyone participates in deliberation (e.g., Dryzek, 2001), but also suggests a critique of such institutions themselves. When examining institutions for media policy making, scholars have examined how a political-economic legitimation crisis inflects the decisions of regulators dealing with oligopolistic firms that control the communications infrastructure (e.g., Horwitz, 1991; Winseck, 1995). This holds true in the cultural sector as well, which in the Canadian context, includes the legislative creation and development of the Canada Council for the Arts, the Canadian Broadcasting Corporation, the CRTC, the National Film Board, and other public (often propagandist) services from the 1930s onwards, up to and including the articulation of the Creative Canada Framework of 2017 (Bourcheix-Laporte, 2019; Luka, 2016). The federated Canadian configuration was contingent on refusing the distributed American model of broadcasting and culture but nonetheless is highly influenced by U.S. cultural hegemony. Contemporary media policy making in several countries is further subject to the dominance of U.S. based internet firms, which tend to exert disproportionate power over governments due to their massive user bases and cash flows (Jin, 2015).

Power imbalance in deliberation and language

While the political-economic climate around particular media policy decisions bears dedicated scrutiny, a deeper concern with the legitimacy of democratic institutions is suggested by the entire liberal project of deliberation. For deliberation hinges on the use of language within institutions. Habermasian discourse ethics suggests that what is said during deliberations needs to match the institutional context in order to be legible (e.g., Ngwenyama & Lee, 1997). For example, Seyla Benhabib (1996) notes that, because the rule of law is the dominant discursive currency in policy making institutions, “Greeting, storytelling, and rhetoric, although they may be aspects of informal communication in our everyday life, cannot become the public language of institutions and legislatures in a democracy” (p. 83). While these informal figures of speech do indeed suffuse the deliberative spaces of policy making, they nonetheless do not officially appear in the eventual enshrining of such deliberation into law.

This offers an example of how existing power asymmetries between institutions and the public structure any kind of deliberation recursively, by ultimately distilling the everyday language into a legitimized institutional form. Moreover, in order to claim such legitimacy, deliberation itself appeals to rationality in its procedures through rules that further entrench existing power dynamics:

Those who follow the rules and observe the conventions appear to be showing a greater willingness to advance the deliberative process, to engage with others and to find common ground, but it is also possible that they are simply better served by the rules in place. Those who are most willing to search for common ground may be those who hold a strategic advantage on that ground. (Lupia & Norton, 2017, p. 72)

Thus, despite the ideal of fairness promoted by deliberative models, in practice there is no way to prevent the rules of deliberation from creating unfair advantages and disadvantages. These sorts of power imbalances can be traced even more insidiously to the power dynamics inherent in language, and the way that language comes from bodies, which serves the essential communicative function at the core of deliberation. 

We might connect the political-economic critique of media policy making to this deeper problem of power as embedded in and exercised through language by looking at the Canadian context. The fact that giant oligopolistic firms (as typically represented through middle-aged white men in suits) tend to dominate policy deliberations, whether directly in regulatory contexts or more generally in the structures of power in the broader cultural sector, reflects a set of conditions significantly determined by colonialism. Canada is a settler colony with a history of oppression, erasure, and genocide levied at its Indigenous population (TRC, 2015). The systematic disenfranchisement of Indigenous peoples across the country has been facilitated by a set of legal instruments intended to suppress Indigenous sovereignty. The English Canadian legal system, a common-law approach largely imported from Britain (after 1759), might also be seen as structurally legitimizing a dominant discursive regime in which the very language of the courts precludes the effective representation of alternative conceptions of rights (Asch, 1984). Since the common law system is based on following precedent, Canadian laws emerge directly from historically dominant discursive practices of power. On the other hand, the French-Canadian legal system (in Quebec) is based on civil law, which aims to articulate so-called universally held values, and then apply the law to realize specific interpretations (Department of Justice, 2017). However, not even this helps shift perspectives from settler points of view, as the values articulated are from the perspective of those who held the balance of power at the time the civil code was enacted. Therefore, although attempts have been made to recognize “Aboriginal Rights,” from the colonial treaties of the eighteenth century to the Constitution of 1982, not only have they been intentionally disregarded, but the entire language of rights as inherited from the colonizer embeds a judicial system that itself oppresses through legal rationality (Poplar, 2003). Benhabib’s (1997) assertion that storytelling cannot serve as the language of democratic institutions highlights one aspect of the colonial discrimination implied by appeals to such rationality (see also Connell, 2007).

Intervention in Canadian media and cultural structures

In this general climate, we can recognize in the contemporary activities of any division of the federal government a legacy of colonial power that manifests in procedural and discursive structures. Likewise, a number of institutions regulate and organize the media and cultural sectors, including the Canadian Radio-television and Telecommunications Commission (CRTC), the Canada Council for the Arts, the Canada Media Fund and Telefilm Canada, Canadian Broadcasting Corporation, and so on. The legislative body of documents at work here is virtually impenetrable without knowing how colonial legal systems are structured as sites of deliberation, management and control. With more than fifteen foundational pieces of legislation relevant to culture and communications at the federal level alone, as well as the regulatory and rule-bound nature of various agencies, departments and programs that have been spawned by them, scholarly and civic engagement in these deliberative spaces becomes limited and bound. Here, we discuss two institutional structures within which we have aimed to intervene: the country’s main federal media regulator, the Canadian Radio-television and Telecommunications Commission (CRTC), and the country’s arts councils, including the Canada Council for the Arts and Canadian Public Arts Funders network. These organizations report to and are funded by the Department of Canadian Heritage or the equivalent in provincial/territorial and municipal jurisdictions.

The CRTC is an administrative tribunal that operates as a quasi-judicial body by soliciting public consultation, government direction, and stakeholder input on how legislation should be developed, enacted, and enforced in telecommunications and broadcasting. In practice, parties engaging in CRTC proceedings are constrained by the technocratic character of media policy making (Obar, 2016), as well as by the broader subordination of public deliberation to the rule of law. In this way, although the CRTC like other regulatory institutions presents itself as apolitical and “public interest-oriented” (Doern, 1997, p. 521), it is deeply complicit in various iterations of longstanding power dynamics in the representation of that public through the vehicle of legislation (King, 2020, p. 111). Indeed, as Gretchen King (2020) observes, the Indian Act of 1876 is in some ways Canada’s first communications policy as it sought to regulate (i.e., sever) the communications between rebellious Indigeous communities (p.112). Today’s CRTC is charged with ensuring that legislative and regulatory processes protect the interests of Canadians not just through the powers articulated in the CRTC Act (1985) but also the powers assigned through the Broadcasting Act (1991), the Telecommunications Act (1993), the Copyright Act (1985) and others. Even more pointedly, its position in the federal administrative hierarchy means that the CRTC must provide annual reports to the Ministers of Canadian Heritage and of Innovation, Science and Economic Development.Other numerous funding and regulatory bodies constrain and shape how cultural production and distribution are organized, gate-kept and executed. These include the Canada Council for the Arts and the provincial/territorial arts councils, all of which are joint members of Canadian Public Arts Funders (CPAF) network. Furthermore, the structuring work that is carried out by the Canada Council, for example, is reflected or rejected throughout the national and regional arts council funding systems (Gattinger, 2017). Specifically, Canada Council’s definition of a professional artist is the generally-accepted definition used across government departments, arts councils and accreditation systems including the post-secondary system. Peer assessment is regarded as a cornerstone of decision-making in the arts but is closely managed by regulatory and policy decisions derived from the colonial legislative framework within the arts council system. From the founding of the arts councils in the 1950s until the late 1990s, the definition (and public funding) of the professional arts only included traditional Western (colonial) forms of artwork. Even now, art practices from non-Western or colonial traditions are regarded as hybrid, alternative or otherwise outside the norm. This core understanding of the arts underpins the meaning of culture in this country. Arts funding agencies report to the Minister of Canadian Heritage (or the equivalent at the provincial/territorial level), and are governed by the same web of legislation as the CRTC, except for the Broadcasting Act (1991) and the Telecommunications Act (1993).

Translation trouble: from research to policy

We have offered an overview of the ways institutions exert and reproduce political power in order to frame the particular challenges of knowledge mobilization in media policy spaces. For scholars aiming to translate their research findings into such a space, its political contours shape the ways that scholarship can function in evidentiary and/or advocacy modes. Among the various ways that scholars can engage with policy making, there is always an instability to the role of the researcher in the policy domain, due to at least the following four factors:

  • the policy environment’s predisposition toward (or away from) certain kinds of empirical evidence (Braman, 2008);
  • the requirements and time constraints of researchers’ grant funding (see movement of money, and also Shade, 2011; Cole et al., 2018);
  • inadequate incentives within academia to encourage scholars to engage with policy making (Noam, 1993);
  • an uncertain relationship between the researcher and the space of policy making, as pervaded by crises of discursive legitimation (Shepherd, 2018).

an uncertain relationship between the researcher and the space of policy making, as pervaded by crises of discursive legitimation (Shepherd, 2018).

We focus on how this fourth factor has played out in our experiences at the CRTC, the Department of Canadian Heritage, and arts councils in Canada in order to emphasize the dirtiness of the back-and-forth translations between research language and policy language.

For example, most research studies that implicate policy making nonetheless do not exactly fit the needs of a particular policy proceeding, as articulated in the juridical and technocratic language required by the regulatory institution. Researchers entering the policy space often both create and experience a jarring sensation when they don’t quite fit — an affective resonance produced by the dirtiness of engaging with policy. To give an example, in the CRTC’s 2015-2016 proceedings for the Review of basic telecommunications services, academics who participated were met with requests for further information from Telus, one of Canada’s ‘big three’ telecommunications conglomerates, who asked for copies of researchers’ CVs and sources of research funding. Telus thus intimated that academics participating in a public proceeding were veiled lobbyists operating covertly rather than university-based researchers with public profiles and easily searchable online CVs. The irony here comes from the political-economic climate where such proceedings tend to be dominated by industry representatives and in many cases academic research is not represented at all. In CRTC proceedings, the always uncertain status of academic researchers comes from the structural bias toward telcos in the juridical procedures and language of regulation, which gets reinforced in the norms of policy participation. This vicious cycle reflects Wendy Brown’s (2015) reading of Foucault’s homo juridicus in economic terms, where corporations — themselves construed as democratic actors — exert disproportionate influence over the policy making process through their disproportionate resources and exercise of legal language. The result is that actors like Telus not only bolster the legitimacy of their own participation but take up the space that may be used by other voices.

This is made clearer still in instances where citizen input is actively sought. For example, during the Let’s Talk TV consultations held by the CRTC between 2014-2016, the agency used a broad range of communication tools (social media, emails, letter uploads, web surveys, etc.) to survey the general public about changing expectations for television program delivery (Luka & Middleton, 2019). However, very little of the input trickled through to the final regulatory decisions. Instead, the input was relegated to anecdotes, quotations, and summaries offered in interim reports (Luka & Middleton, 2017). While such input may help policymakers visualize how decisions rendered in these quasi-judicial forums might look to citizens who want to be able to participate in them, a more cynical take on the process might suggest that the political agenda is to find ways to articulate back to the voting public how the regulatory decisions made to satisfy large corporations might (or might not) help the ‘everyday citizen.’

In this uncertain context for academic intervenors, one that systematically privileges industry voices while delegitimizing the perspectives of citizens, any advocacy for some other perspective or any kind of regulatory intervention is treated with extra suspicion. In this way, not only does research need to be translated into the terms of the regulatory proceeding in a pragmatic sense, but it also needs to contend with the political rationalities that guide contemporary policy making. The conceit of deliberation implies that policy making is itself a translation exercise. In a Latourian sense, translation works to link political rationalities, actor networks, and technologies into government, for example by turning politicized debate into an administrative protocol or representing ‘the public interest’ through a legible political agent (Flew, 1998, p. 320). Within this space, translating research likewise takes on these sorts of dimensions, where not only the results of a research study but the politics embedded in the research questions must be translated into the administrative, technocratic, and/or legal language required by the particular institution. In this context, while scholars may or may not have the goal of advocacy in mind at the outset of a research study, the endpoint of policy translation implicates all those earlier decisions about the way research is conducted. The dirtiness of research methods becomes a recursive terrain revisited through the process of translation that requires a researcher to, in some ways, move backward from the end goal of policy participation.

A story from Tamara Shepherd:

As an example of how this form of translation works, on two separate occasions at CRTC hearings I have spontaneously articulated some version of a critique of the oligopolistic structure of Canada’s telecoms industry when not really intending to do so nor having any sort of direct research on that topic to support my assertions. Here is an example of this happening during the February 2017 hearings for the revisions to the Wireless Code, a CRTC initiative to improve consumers’ dealings with wireless service providers that was provoked in part by comparative statistics on Canada’s globally high rates for mobile services. Here is an exchange I had with CRTC Chair Jean-Pierre Blais during a presentation by myself and Catherine Middleton:

THE CHAIRPERSON: […] I actually don’t understand what you’re trying to say when you say [in your written submission]: “…a political economic analysis of Canada’s wireless industry reveals that achieving the objectives of the Code – including contributing to a more dynamic marketplace within which Canadians can access quality, affordable, and innovative communications services – are subject to structural issues within that marketplace.” What does that mean? What are you getting at?

DR. SHEPHERD: In short, consolidation of ownership.

THE CHAIRPERSON: Right. Do you think there is too much consolidation or there is proposed consolidation that’s not in the public interest?

DR. SHEPHERD: I think it’s relatively consolidated if you do sort of analysis from a political economic point of view. And here I’m thinking of the Canadian Media Concentration Research Project out of Carleton University that has done extensive political economic studies in this regard. But also, just more anecdotally, when you look at, let’s say, comments from consumers about their frustration, often those sorts of comments cite the sort of structural marketplace issues. So there is a general feeling, and you can see this in the comments that have so far accrued on your own online commenting portal, there is a general feeling that somehow the shape or the texture of Canada’s marketplace, being dominated by a few large providers, unfairly disadvantages consumers. (CRTC, 2017, paras. 3410-3417)

In this exchange, I could feel myself grasping for evidence of market consolidation and its impacts – things that are quite self-evident but that I as a researcher needed to support with recognizable evidence as part of claiming my role in the hearing as an expert. These were not the sorts of evidence that I myself generated through my own research projects, but I said those things to answer the Chair’s questions because they point to the evident underlying issue for a host of deficiencies in the provision of internet connectivity in the country. In the process, my position became twisted to fit a certain mold in situ. The experience was one of accidentally ventriloquizing a version of a public interest perspective (Canada needs better internet infrastructure in underserved areas/communities), but also one that proposed a marketplace solution (Canada needs more internet service providers) to problems in the public provisioning of infrastructure.

For me, this spontaneous articulation of a position – in response to the Chair’s line of questioning – that both fits (public interest) and opposes (marketplace) my own politics troubled the way I subsequently went about formulating the research that I had intended would inform this sort of policy making. I had to reevaluate my scholarly work from the position of imagining myself presenting again at a future hearing – what kind of research could I produce that would help me say things to the CRTC? This question in turn potentially undermines other political commitments I might want to uphold in my work by instrumentalizing the research design and making it fit within the parameters of quasi-judicial interrogation. Moreover, by maintaining the marketplace framing that the CRTC itself proposed in its framing of the hearing, I also upheld the distinctly colonial aims of Canada’s communications policy (Toso, 2020). 

Only after the hearing experience, where I hastily responded to the questions posed by commissioners, was it possible to go back to earlier moments in the research design and try to figure out how I could trouble the utterances made in the moment. I had to double back on the way I do research to account for this spontaneous translation and try to deal with the implications of the CRTC hearings for the original research questions. As a result, the scholarly articles that came out of this work had to address the way that the deliberative process structured by institutions such as the CRTC imposes certain limits on researchers’ participation in proceedings. And since doing that analysis, I have more or less stopped participating in these public spaces. I still feel uncomfortable about claiming the role of an expert in the institutional context of the CRTC (the character of which has itself become increasingly closed off to public engagement with the appointment in 2017 of a chairperson from industry). But backing away to avoid the moment where I’m tasked with translating an academic subject position into a public one doesn’t solve the discomfort of complicity. 

Academic Intervention in Policy Proceedings

When attending to the specifically colonial context for policy making, translation is also important in a second sense. The translator establishes themselves as a spokesperson (Callón, 1984, p. 214), where the subject-position of the researcher brings additional dirt to bear on policy making by entrenching certain bodies as legible in deliberative institutions. Academics intervening in policy proceedings may find themselves on uncertain footing, but they nonetheless exercise and reinforce privilege. As a process endemic to policy making, translation involves the delineation of common language between stakeholders, but always in the service of the rulemaking institutions that have long legitimized the systemic disenfranchisement of Indigenous communities in this country. If translators “speak for publics, give them visibility, and mesh public concerns with a political process” (Gangadharan, 2013, p. 9), then most academics intervening in policy proceedings don’t tend to stray too far from the ideal subject of policy making in representing a settler perspective. There are some notable exceptions in the context of the CRTC, such as in the work of the First Mile Connectivity Consortium that brings together a number of Indigenous communities to advocate for regulatory measures that would improve rural and remote telecommunications services (McMahon et al., 2014), and the Community Media Advocacy Centre, which advocates for non-profit Indigenous- and community-owned media organizations at the CRTC (King, 2020).

Nonetheless, in our experience, intervening as white, settler, cis-gendered, university-affiliated researchers who present in accordance with the norms of judicial language, a dirty ethical question remains as to how far our presence can destabilize the colonial structures of the policy process. Simply being present in the hearing room at the CRTC, for example, requires a number of privileges: the ability to travel to the national capital, spare time during business hours, fluency in one of Canada’s two official (colonial) languages, and general appearance and comportment that fits within the quasi-judicial setting. Just being there reinforces the exclusionary power of the way that such a space constructs political legitimacy. So while I have felt pretty cool (in an extremely nerdy way) to be part of CRTC hearings, my presence there also upholds a kind of institutional domination. As Katie Boudreau-Morris (2017) notes about doing activist and academic work in solidarity with Indigenous peoples, acknowledging colonial oppression doesn’t change the researcher’s “continuing in many ways to participate in and benefit from Canadian settler-colonial occupation of Indigenous lands […] and that is an uncomfortable reality” (p. 456). Certainly, researchers who present normative whiteness must engage with such “reflexivities of discomfort” (Pillow, 2003) as part of the dirtiness of both upholding and benefitting from colonial institutions. Further, it’s not clear whether or how my own experiences at the CRTC have actually impacted what goes on at the regulatory level, or if they have merely been an exercise in CV-building or obtaining (extremely nerdy) policy scholar clout. 

A story from Mary Elizabeth Luka:

While chair of a provincial arts council Board of Directors, I led a governance review of the terms of reference for the loose network of provincial, territorial and federal arts councils known as the Canadian Public Arts Funders (CPAF) network. Notwithstanding the many successful commitments to ‘diversify the bodies’ on these boards, their peer assessment committees, and their staff, as well as in the bodies of artists supported, adherence to principles of settler-based deliberative conduct established in the Western world from the 1950s onwards (e.g., at Canada Council: see Gattinger, 2017) in the field of cultural funding and production invariably pulled us back to the colonial foundations of legislative and policy processes. The deliberative processes of peer assessment in arts funding committees are more or less the same as it has been for decades (notwithstanding hard-won additions to and changes in artistic genres), which is to say an evaluation of proven creative capacity and viability of projects. These deliberations privilege what has traditionally been understood to be good business practices and audience impact measures in non-profit (and for-profit) spheres. Through the recruitment of already-successful artists and creative peers into the current funding assessment processes, it fundamentally replicates itself by selecting artists and organizations whose work and approaches are similar to or fit within the generally accepted mode of creative work. Similarly, since the group of people at the table at the CPAF network are already the heads of the arts councils (whether staff executive directors or volunteer Board chairs), the consensus-building that takes place here tends to reinforce established patterns of disciplining these organizations, even when the ‘bodies’ in attendance are not necessarily white, cis-gendered, or highly educated creative workers. Despite the potential for scholar-advocacy in media and cultural policy making “to ask tough questions about whose interests are best mobilized in existing policy contexts and whose perspectives are marginalized” (Freedman, 2010, p. 358), dirtiness persists in the whiteness of even those perspectives considered ‘alternative’ in such spaces. This is a kind of dirtiness that needs to be considered throughout the research process as constituent of the policy reflex.

Provisional, recursive conclusions

Even while the policy reflex carries intrinsic structural constraints as well as ethical dirt, it can still be a valuable means of approaching the more practical aspects of knowledge mobilization. Making the attempt to translate research in the policy domain takes the policy reflex beyond the tendency to remain “in a vacuum, not only cut off from the influence of policymakers on the ground, but also cut off from an understanding of the ways that policies are made” (Wagman, 2010, p. 620). In Tamara’s experience, intervening in CRTC proceedings has been (relatively) cool enough to shift her career trajectory toward studying how policy gets made in these institutions, precisely because of how weird and conflicting it is to participate in a hearing. In Mary Elizabeth’s case, working with program, research or policy staff at arts councils, creative hubs, media production bodies, or at the Department of Canadian Heritage has been alternately rewarding and troubling enough to keep moving in and out of these spheres, whether as an advocate for artists, a volunteer in the governance systems, a commissioned researcher or as a critical scholar. When it comes to offering service or input during legislative reviews, such as the 2018-2020 Telecommunications and Broadcasting Act reviews (Telecommunications & Broadcasting Legislative Review, 2020), the complexities that emerge from often-invisible colonial histories, assumptions and past practices provide openings for shifting the various landscapes that these regulatory tools and approaches have taken to date. Sitting in a windowless room in the national capital, listening to assorted vice presidents being questioned and coming up with convoluted answers, pushes someone more comfortable with the university’s version of institutional politics to consider how another colonial institution renders itself as legitimate. This experience has also highlighted both the pragmatic problem of how to repackage ‘findings’ – a term itself fraught with colonial, exploratory connotations – to fit the regulatory brief in ways legible to regulators, and the more existential problem of what our bodies enact when they act in regulatory theatres. At least at the CRTC or in government buildings more generally, what may seem to be clean in some ways (austere government buildings, behaviours adhering to a judicial protocol) are much more dirty in practice (smelly old carpet and rickety chairs, rodent infestations or asbestos, barely concealed toxic work cultures).

To bring this back to methods, we might see that while policy recommendations are often found in the conclusion sections of academic articles, they also cultivate new beginnings that invite a confrontation with the politics of the policy space. Any kind of engagement in policy, given its tendency to reinforce the naturalized white, male, homo economicus as ideal interlocutor, demands that researchers engage early on in the research process with the dirtiness of translation and complicity in colonial institutions. Despite the benefits of thinking research outward toward different publics, policy engagement risks reproducing power hierarchies through the valuation of certain kinds of research as evidence, rendered recognizable within the legal language that structures regulatory proceedings. One way to destabilize recurring patterns of power in policy making thus requires that researchers make methodological choices with certain publics in mind at the outset, considering how alternative frameworks and marginalized perspectives could break through the procedural veneer of a quasi-judicial space like the CRTC’s hearing room, a Departmental program staff meeting, or a Board of Directors. Acknowledging the dirtiness of research as well as the dirtiness of participation in such spaces, while taking up the room that might be accorded to the same old intervenors, offers potential for at least starting to disrupt policy making but also for rethinking the methodological process as akin to the ouroboros looping backward to devour its own tail.


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