The Secretary of State has approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022, taking effect in December 2025. The update introduces an alternative compensation route linked to the Marine Recovery Fund (MRF) and tightens monitoring and reporting for works that affect the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). The decision notice was published by the Department for Energy Security and Net Zero on 19 December 2025 and identifies RWE Renewables UK as the company associated with the change.
The Order now allows the undertaker to apply to make a Marine Recovery Fund Payment where the required area of marine debris removal in the HHW SAC cannot be achieved in full. This aligns the project with the statutory framework in section 292 of the Energy Act 2023 and the Marine Recovery Funds Regulations 2025, which enable payments into a central fund to discharge habitat compensation conditions in appropriate cases. The MRF regulations came into force on 17 December 2025.
Under the amended compensation provisions, any application to use the MRF must show the proportion of the overall debris‑removal obligation attributable to Norfolk Vanguard where impacts are shared with Norfolk Boreas via the common cable corridor, and must set out the amount of material already removed under the benthic implementation and monitoring plan (BIMP). The Secretary of State must be satisfied, including through confirmation from the MRF operator (currently via Defra), that the fund can be used and the sums due are correctly quantified. These steps implement the “strategic compensation” model described in government materials.
If the Secretary of State approves the switch to an MRF contribution, cable installation within the HHW SAC may only proceed once an implementation and monitoring plan has been approved. The undertaker can then be discharged from further delivery of on‑site compensation measures when either a completion report is approved, the full MRF amount is paid, or an instalment contract with the fund operator is in place and the first payment made. Where payment by instalments is used, the duty to meet the agreed schedule remains in force until all sums are settled.
The monitoring regime has been recast. Results from the monitoring scheme must be provided at least annually to the Secretary of State, the Marine Management Organisation (MMO) and the relevant statutory nature conservation body. Any finding that measures are ineffective must be accompanied by proposals to address performance; once approved, those proposals become binding on the undertaker. This formalises an adaptive management loop between the developer, the MMO and nature conservation advisers.
A previous explicit bar that prevented starting cable installation within the HHW SAC until a specified area of marine debris had been cleared has been removed. In practice, commencement remains controlled by the need for approved implementation and monitoring arrangements and by the possibility of an agreed MRF contribution where physical clearance falls short. The shift is intended to maintain ecological protection while offering a workable route where on‑site clearance is impracticable at scale.
Corporate definitions have been updated. “Defra” is now expressly defined for the purposes of compensation arrangements, and the “undertaker” is re‑stated as Norfolk Vanguard West Limited (Company No. 08141115). The 2022 Order had referenced Norfolk Vanguard Limited against the same company number; Companies House records confirm the entity now registered as Norfolk Vanguard West Limited.
The Order recognises interactions with Norfolk Boreas due to the shared cable corridor. Recent MMO variations covering both schemes underline the need for consistent drafting across Deemed Marine Licences and associated conditions. The explicit requirement in the application to apportion responsibilities where impacts are shared should reduce duplication and clarify reporting lines for regulators.
For project and compliance teams, immediate tasks include updating the BIMP to reflect the new reporting cadence, preparing an implementation and monitoring plan capable of swift approval, and modelling an MRF contribution scenario alongside continued efforts to deliver debris removal. Finance directors should ensure budget headroom and internal approvals for either a lump‑sum payment or an instalment plan, noting that discharge from delivering on‑site measures does not remove the obligation to complete any agreed payment schedule.
Policy significance extends beyond a single project. Parliament has positioned the MRF to enable pooled, strategic compensation where project‑by‑project delivery is constrained, with Ministers highlighting the potential for better outcomes for seabirds, marine wildlife and habitats when measures are delivered at scale. This DCO amendment operationalises that approach within a live scheme soon after the regulations took effect.