Positionality

Particular to my experience of conducting my research was my experience as a participant in many of the activities of regulatory policy development before and during my PhD research. Before beginning the PhD, my career was based on engaging with the regulator, government and devolved administrations regarding affordable energy policies on behalf of an energy supply firm. Further, my PhD was funded by the Centre for Competition Policy (CCP) at the University of East Anglia where there was regular engagement with economic regulators, including Ofgem.

As a member of CCP, I delivered research briefings directly to individuals working for economic regulators, contributed to CCP responses to stakeholder consultations conducted by Ofgem and participated in workshops funded by Ofgem for their employees. Finally, while writing up my thesis part time, I took a role for the statutory consumer advocate as a researcher and later, head of department. There

97 was therefore no point at which there was any relevant or meaningful distance from the procedures of regulatory policy formulation I sought to analyse. In setting out my research design, I therefore sought to ensure that the way I was embedded in some of the procedures I was analysing, provided benefits while maintaining a consistent reflexive focus on the extent to which my engagement with regulatory procedures might impact my research.

The core benefit of a previous career in, and enduring links with, procedures of regulatory policy formulations, related to the interviews I conducted in two areas:

access to interviewees and building rapport in interviews. First, I had an extensive network of direct contacts as a base for my approaches for participation. However, I was concerned that solely interviewing individuals whom I had worked directly with might have resulted in an overly narrow experience of regulatory procedures. I therefore asked my existing network for advice and introductions to possible

interviewees and limited interviewing people I had worked with people where another option was not available. This approach, along with the typically high turnover of staff within the regulator and government, meant that I had only worked directly with two of my 35 interviewees. My links to the CCP were also important, with Professor Waddams-Price of CCP introducing me to 2 further interviewees and 6 interviewees noting in the interview their familiarity with CCP research. Second, my long-standing familiarity with the technical terminology of energy markets and professional network together, led to a smooth building of rapport during the interview itself. As explained in section 3.3.2, rapport with face to face interviewees can be easier than telephone interviews. However, when an interviewee was distracted from a description by being unable to remember an event, name or number, I was able to give the detail and the interview could continue smoothly.

98 The most significant challenge to beginning the study given my embeddedness in the policy procedures being evaluated, was maintaining a reflexive focus on the implications of my experiences in responding to the data collected (Hanson 2013;

Leigh 2019; Munkejord 2009; Weber and Mitchell 1996). This was an important contributing factor to my use of the WPR framework which includes analysing the problem representations of the researcher in their analysis and presentation of findings. This included analysing my own problem representations in the thesis as systematically as analysis of the data collected in my research. This resulted in two adaptations to the original research design of my PhD funding proposal. My original research design reflected two assumptions based on my experience of regulatory policy making before my PhD: that distributional concerns were distinct from economic regulation and that fuel poverty was a separate policy issue from energy price policy. As I conducted my research, it was clear from interviewees and much of the documentary analysis that fuel poverty and regulation had become

overlapping issues that were connected in the work of many charities and third sector organisations. Further, the distributional outcomes of economic regulation were not only a core concern of those beyond the regulator engaging in energy market regulation activities: the CMA investigation (which completed after I had begun my PhD) found a clear, and concerning, distributional impact of energy market regulation (Competition and Markets Authority 2016b). I therefore adopted the EJF to ensure that distributional outcomes were a primary and explicit concern within my analysis, rather than an implicit motivation, in conducting my research.

A final way in which my positionality impacted my research design was my motivation to connect my findings to practical recommendations for future

procedures of regulatory policy formulation. This led to the adoption of the TPF and EJF frameworks, both of which had been used by researchers to reveal concerns and shortcomings regarding the procedures of policy making (Jordan and Turnpenny

99 2015; Simcock et al. 2016a). While the WPR provides a powerful lens for revealing concerns regarding policy procedures, it was not designed to result in practical recommendations for policy makers (Bacchi and Bonham 2014). However, many researchers using the WPR have chosen to do so (Goodwin and Robinson 2016;

Holloway 2019; Roulstone and Prideaux 2012). Using this combination of

frameworks provided me with the confidence of systematic prompts to reflect on the impact of my positionality (through examining my problem representation) alongside frameworks that had historically been used to make practical

recommendations regarding policy making. My recommendations that resulted from my analysis are in section 9.2.2.

In presenting my positionality in this thesis, a final contributing factor to the manner in which this research was conducted and impacted by my individual experiences as a researcher, are my choices related to data collection. As a neurodivergent researcher with restricted mobility, conducting interviews with participants or data collection in physical archives were simply impractical. Analysis of contemporary documents available on online archives secured me access to the data required for documentary analysis. Further, telephone interviews from an office at CCP adapted with reasonable adjustments meant that I was able to focus on interacting with the interviewee and securing a strong contribution from

individuals towards understanding their perspective on the policy procedures I was analysing.