The Secretary of State has approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022, effective 19 December 2025. The amendment enables the project to discharge certain benthic compensation requirements via the Marine Recovery Fund (MRF) where debris removal proves impracticable within the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). The decision is recorded on GOV.UK.
This change sits under paragraph 2 of Schedule 6 to the Planning Act 2008, which allows non‑material modifications to development consent orders, and follows the publicity and consultation procedures in the 2011 Regulations. In practical terms, it alters how an existing compensation obligation may be met without reopening the underlying consent.
The Order updates definitions in Article 2 and Schedule 17, including a definition of the Department for Environment, Food and Rural Affairs (Defra) for operational clarity. It also substitutes the “undertaker” to Norfolk Vanguard West Limited (Company No. 08141115), aligning the consent with the company now responsible for delivery. Companies House records confirm the corporate details.
The most visible shift is to Part 3 of Schedule 17, which governs compensation to protect the coherence of the national site network for the HHW SAC. The previous requirement that no cable installation could begin until a specified area of marine debris had been removed is omitted, replacing an absolute pre‑condition with an adaptive route that can include an MRF payment, subject to Secretary of State approval. For context, the original 2022 Schedule required debris removal ahead of cable works.
Under the amended provisions, if the required area of marine debris cannot be removed in whole or in part, the undertaker may apply to the Secretary of State to make an MRF payment in substitution for the outstanding element. The MRF is provided for by section 292 of the Energy Act 2023 and implemented through the Marine Recovery Funds Regulations 2025 and Defra’s published guidance for developers.
Any application to use the MRF must set out how impacts in the HHW SAC are apportioned where the Vanguard cable corridor is shared with Norfolk Boreas, and must quantify debris removed to date. Approval requires confirmation from Defra (as MRF operator) that the fund can be used and that the payable sum has been determined. Only once an implementation and monitoring plan is approved and the undertaker is formally discharged from further project‑level compensation duties may cable works proceed within the SAC.
Discharge pathways now include: acceptance of a completion report demonstrating delivery of activities, full payment into the MRF as confirmed by the Secretary of State, or entry into a contract to pay by instalments with the first payment made-while continuing obligations under that contract remain. This provides a predictable route for compliance where on‑site debris removal cannot be delivered at scale.
Annual monitoring and adaptive management remain central. Results must be submitted at least once a year to the Secretary of State, the Marine Management Organisation (MMO) and the relevant statutory nature conservation body, together with proposals where measures prove ineffective-provisions carried forward from the 2022 Order text for the HHW SAC.
The shift towards an MRF option reflects evidence that seabed debris in and around the HHW SAC is present at low densities, making target‑based removal difficult to achieve. In July 2024 the Secretary of State approved a Version 2 Benthic Implementation and Monitoring Plan across Vanguard and Boreas, noting Natural England’s advice on the scarcity of debris and the need to consider wider collaborations.
For project managers and consenting leads, the practical tasks now include early engagement with the MRF operator, confirming the availability and scope of strategic compensatory measures, and aligning financing and procurement through Defra’s Atamis system. Charges include strategic measure delivery, adaptive management and administration, set out in Defra’s guidance. Reporting cycles to the MMO and statutory nature conservation bodies should be retained.
The amendment does not change the policy objective to protect the coherence of the national site network. Instead, it provides a structured, government‑run option for compensation delivery at scale, backed by statute and regulation, while maintaining oversight by the Secretary of State and statutory bodies.
The Order was made on 18 December 2025 and came into force on 19 December 2025. DESNZ’s decision notice records the non‑material change for Norfolk Vanguard, operated by RWE Renewables UK.