When delivering services, we usually talk directly to people to learn from their experiences, needs, and pain points. But sometimes, you don’t get that luxury.
That is the situation we faced while working with the Department for Energy Security and Net Zero (DESNZ), developing services to support the setup of heat network zones across England. As a result of new policy, these services require entirely new processes to be developed as well as entirely new roles.
While these future roles and responsibilities may overlap with existing ones (like infrastructure teams in local authorities or heat network developers), they will operate in a completely new context. But how can we research and design support services before these new roles even exist?
In this post, I’ll share how we approached designing for users who don’t exist (yet) as part of this developing policy space.
Mapping the future through the lens of policy intent
Since there were no users yet, our initial focus was on understanding the draft policy intent, including the change the policy was designed to create, and what steps would be needed to get there.
Using the draft statutory instrument as our starting point, we mapped:
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How future heat network zoning processes might work
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Who would take part
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What they’d be responsible for
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How their roles would connect
As we analysed the policy, we focused on understanding the kind of system it aimed to create and what capabilities we anticipated those involved would need to make it work.
Sketching this future service ecosystem before anyone was occupying it helped us see early on where collaboration might be needed. For example, where dependencies could emerge, where the legislation outlined business requirements, and where legal boundaries might shape the journey.
It gave us, and stakeholders, a shared picture of the world that future users would imminently step into.
Talking to people doing similar things
Where new roles didn’t exist yet, we looked for similar ones. By analysing similar existing processes, or early pilots, we could gain valuable insights into what’s to come.
We explored these analogous contexts to see how similar systems work in practice. We spoke with planners and energy officers involved in local planning and statutory consultations, processes that heat network zoning will likely mirror in some way.
We also talked with teams involved in early pilot programmes. Their processes weren't identical, but there were relevant insights and pain points to carry forward. This qualitative approach helped us imagine what future zoning roles might value and need to collaborate effectively.
Finally, we interviewed teams that will likely take on zoning responsibilities once the policy comes into effect. And even though they had yet to perform this role, early patterns began to emerge in how they work, the skills they bring, where problems may arise, and where they might need support.
In most cases, similar roles existed - but the new laws and policies would reshape them.
By performing gap analyses between their current experiences and the policy intent, we were able to find where policy may either clash with current ways of working. Or, where we may need to feed back insights to policy makers for further consideration.
Creating proto-personas as living hypotheses
Once we had mapped the process and gathered insights from analogous roles, we created proto-personas: lightweight, evidence-informed hypotheses about potential users. Unlike traditional personas, proto-personas are based on assumptions and analogies that we can validate or disprove over time, as opposed to insights from research with existing users.
Instead of trying to project pain points into the future, we used these proto-personas to predict drivers, challenges and mental models, based on comparable systems, to design consciously and with a tangible user in mind.
With our proto-persona Elena, a local authority user involved in zoning processes, we combined insights from adjacent roles, such as local planners and energy officers, analogous processes (planning consultations), and the responsibilities outlined in the draft policy.
Proto-personas as a way of navigating ambiguity
In design, we often talk about embracing ambiguity, but when you’re designing alongside emerging policy, it becomes essential.
Policy drafts evolve, sometimes subtly, sometimes dramatically. A new version of a statutory instrument might shift responsibilities or redefine a role or process entirely, and that’s normal. The key is to stay informed and open to change.
At DESNZ, we worked closely with the policy team to keep up with these shifts. Tracking updates and understanding why they happened became a valuable part of our collaboration with the client. That collaboration worked both ways, with findings from the interviews we conducted influencing changes to terminology that users had found confusing.
To stay organised and keep up with all the changes, we versioned everything. Each version of the proto-personas was tagged with the relevant policy draft and research phase it related to. This change log helped us trace how things evolved and why.
Finally, we learned to let things go. Some policy updates meant discarding or changing big pieces of work, delivery plans, and approaches. We learned to pivot, stay agile, and not get too attached.
Proto-personas like Elena aren’t just speculative user profiles; they provide policy intent with a user-centred context. They offer teams and stakeholders a grounded hypothesis to align around, translating abstract policy goals and insights from analogous processes into a tangible design direction. We design for Elena.
It was also important to think of these proto-personas as living documents. As research evolved and policy drafts became more comprehensive, we ensured Elena’s profile stayed current and relevant.
Proven approaches for designing with emerging policy
So, if you’re working on a service or face a similar situation where your users don’t exist (yet), try the following. Think about mapping the future state by using the policy intent as a guide. Talk to people who might be doing similar things, and, last but not least, consider using proto-personas to help you navigate through that ambiguity.
By embedding these approaches early (even before users were part of new processes), we have made sure that when those new roles were finally in place, the services waiting for them were relevant, usable, and best met their needs.