The Secretary of State for Energy Security and Net Zero has approved a non-material change to the Norfolk Boreas Development Consent Order. The Norfolk Boreas Offshore Wind Farm (Amendment) (No. 2) Order 2025 took effect on 19 December 2025, with the Department for Energy Security and Net Zero publishing the decision on GOV.UK the same day.
The Order makes four notable technical updates. It adds a definition of the Department for Environment, Food and Rural Affairs (Defra); replaces the definition of the “undertaker” with Norfolk Boreas Limited (Company No. 03722058); corrects specific co-ordinates within the authorised development boundary; and revises how compensatory measures for the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) are to be designed, monitored and, where necessary, funded.
Schedule 19, Part 3 (HHW SAC compensation) is reworked to define the Benthic Implementation and Monitoring Plan (BIMP) and the role of a Benthic Steering Group (BSG), and to integrate the government’s new Marine Recovery Fund. This aligns project-level compensation with the strategic compensation framework enabled by section 292 of the Energy Act 2023 and implemented through the Marine Recovery Funds Regulations 2025, which came into force on 17 December 2025.
Governance of the BIMP is tightened. Results from the monitoring scheme must be submitted at least annually to the Secretary of State, the Marine Management Organisation (MMO) and the relevant statutory nature conservation body, with remedial proposals required if measures are proving ineffective. This builds on the Secretary of State’s earlier approval of a Version 2 BIMP for Norfolk Boreas in July 2024, underscoring the iterative oversight of benthic compensation measures.
The amendment removes a fixed pre-commencement threshold that previously linked cable installation to clearing a minimum area of marine debris within the HHW SAC. The Norfolk Zone’s earlier documentation referenced “up to 8.3 hectares” of debris removal for comparable measures; the Norfolk Vanguard Order sets this benchmark in its BIMP provisions, illustrating the origin of the figure that Boreas now replaces with an adaptive approach.
A formal adaptive route is introduced if debris removal cannot be delivered in full. In those circumstances, the undertaker may apply to the Secretary of State to make a Marine Recovery Fund Payment as a substitute for the unmet portion. Under the Energy Act 2023 and the Marine Recovery Funds Regulations 2025, ministers may determine that a payment into the Fund discharges a compensation condition to the extent agreed, with Defra confirming use of the Fund and quantifying the sum.
Upon approval of this route, cable installation within the HHW SAC cannot proceed until an implementation and monitoring plan is signed off. The Order then allows the Secretary of State to discharge further obligations to deliver the relevant compensation either when a completion report is approved, when the agreed Marine Recovery Fund sum is paid in full, or when a contract to pay by instalments is executed and the first payment made. Any discharge on an instalment basis preserves the obligation to continue paying under the contract with Defra.
The Order also codifies how Norfolk Boreas must account for the shared cable corridor with the Norfolk Vanguard projects when calculating any shortfall and associated payment. This reflects the wider programme management across the Norfolk Offshore Wind Zone, which has seen coordinated licence variations and project structuring across Vanguard West, Vanguard East and Boreas, as recorded by the MMO.
For project controls teams, the practical effect is clear. The BIMP should be refreshed to reflect the new fallback route, with early engagement with Defra on eligibility, quantification and timing. Internal reporting lines should be aligned to the annual submissions to the Secretary of State, MMO and the statutory nature conservation body. Defra has published Marine Recovery Fund application guidance, a library of strategic measures and advice forms for the statutory bodies, providing the operative templates for developers.
For context, the HHW SAC protects mobile sandbanks and Sabellaria spinulosa reef features off the Norfolk coast. These habitats are sensitive to seabed disturbance, which is why compensation measures-and now the option of strategic, fund-based delivery-carry detailed monitoring and reporting duties in law.