The Secretary of State has approved a non‑material change to the Norfolk Vanguard Development Consent Order, effective on 19 December 2025. The instrument revises compensation and monitoring for the Haisborough, Hammond and Winterton Special Area of Conservation and sits alongside the Marine Recovery Funds Regulations, which commenced on 17 December 2025.
Article 2 is updated so the undertaker is Norfolk Vanguard West Limited (Company No. 08141115), aligning the DCO with corporate changes since 2023 and the transfer of the Norfolk projects to RWE. The 2022 Order had named Norfolk Vanguard Limited; Companies House records show the same company number now registered as Norfolk Vanguard West Limited, and the decision notice identifies RWE Renewables UK.
Schedule 17 now codifies delivery and oversight by defining a Benthic Implementation and Monitoring Plan and a Benthic Steering Group. This formalises arrangements already in use on the project; the Planning Inspectorate recorded approval of a Version 2 BIMP in July 2024 under Part 3 of Schedule 17.
A previous pre‑commencement sentence preventing cable installation within the HHW SAC until a specified area of marine debris had been cleared is removed. The Order also requires at least annual submission of monitoring results to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, with remedial proposals where measures prove ineffective.
Where debris clearance cannot be delivered in full, the undertaker may apply to substitute delivery with a Marine Recovery Fund payment as an adaptive management measure. Acceptance depends on the Secretary of State’s agreement in principle and Defra’s confirmation that the Fund can be used with a quantified sum; if approved, no cable installation may proceed within the HHW SAC until an implementation and monitoring plan is approved and the undertaker is discharged from further delivery obligations. Discharge via an instalment contract does not remove the duty to complete payments under that contract. These provisions dovetail with section 292 of the Energy Act 2023 and the Marine Recovery Funds Regulations 2025.
The amendment also regularises corporate and delivery context. DESNZ’s decision notice confirms the non‑material change date of 19 December 2025 and names RWE Renewables UK, while Norfolk County Council notes RWE is now taking the Norfolk Vanguard and Norfolk Boreas schemes forward.
For project controls and consenting teams, the practical effect is a clearer fallback route if debris clearance proves impracticable, balanced by tighter evidence duties. Teams will need to keep the BIMP live, maintain BSG governance, schedule annual returns to the Secretary of State, MMO and the statutory nature conservation body, and-where the Fund route is contemplated-engage early with Defra on valuation and contract terms. This sits alongside 2025 variations to the projects’ deemed marine licences recorded by the MMO.
In policy terms, the Order embeds a strategic compensation pathway enabled by the Energy Act 2023: payments into a Marine Recovery Fund can be treated as discharging compensation conditions where determined by the relevant authority. For developers and regulators, it consolidates a national mechanism while retaining project‑specific monitoring and adaptive management.