The government has approved a non‑material change to the Norfolk Boreas Offshore Wind Farm Order, in force from 19 December 2025. The amendment updates how impacts to the Haisborough, Hammond and Winterton Special Area of Conservation are compensated, adds a definition for Defra, confirms Norfolk Boreas Limited as the undertaker, and corrects several project coordinates. The Order was made on 18 December 2025.

Crucially, the previous pre‑condition that at least 8.3 hectares of marine debris be removed from the SAC before any cable installation could begin has been deleted. If debris removal cannot be fully delivered, the undertaker may now apply to substitute the shortfall with a Marine Recovery Fund payment; cable works can only proceed once an implementation and monitoring plan is approved and compensation arrangements are signed off.

What the Marine Recovery Fund is matters here. Under section 292 of the Energy Act 2023, ministers can establish funds into which developers pay and from which strategic compensatory measures are delivered for offshore wind. The Marine Recovery Funds Regulations 2025 came into force on 17 December 2025, and Defra has since set out its role as fund operator and published procurement guidance and SNCB advice forms for applicants.

Why this site matters is clear. HHW SAC spans 1,467.59 km² of mobile sandbanks and patchy biogenic reef, including Sabellaria spinulosa, and straddles inshore and offshore waters-so advice is shared by Natural England and JNCC. Its protected features are sensitive to physical disturbance, which is why cable installation and protection need careful sequencing and monitoring.

What continues and what tightens. The Order retains the benthic implementation and monitoring plan and a benthic steering group to shape delivery. It now requires results to be submitted at least annually to the Secretary of State, the MMO and the statutory nature conservation body, and any finding of ineffectiveness must trigger approved corrective measures. The text also recognises that impacts and obligations are shared with the Norfolk Vanguard projects where the cable corridor is shared.

The evidence base supports this monitoring‑first approach. JNCC’s sensitivity assessment highlights Sabellaria spinulosa reef as vulnerable to physical damage, reinforcing the need for robust pre‑ and post‑construction surveys. At the same time, repeat mapping at one offshore wind site found no measurable detriment to S. spinulosa reefs and even short‑term diversity gains-so decisions should be led by data, not assumptions.

Accountability is explicit. Any use of the Marine Recovery Fund must be signed off by the Secretary of State, including the proportion of original compensation it replaces, and Defra must confirm the fund can be used and quantify the sums due. An undertaker can be discharged from further site‑specific compensation duties once a completion report is approved, a full payment is made, or an instalment contract is entered into-though payment schedules must still be honoured.

On the ground, this creates a pragmatic fallback when debris removal proves unworkable without lowering the bar on outcomes. For communities and conservationists the test is delivery: publish survey methods, georeferenced results and success criteria; track the area of debris removed, condition trends for sandbank and reef features, and any Marine Recovery Fund payments and the projects they support.

What to watch next. RWE, which now leads the Norfolk Zone, will need to finalise any implementation and monitoring plan and, if required, agree Marine Recovery Fund arrangements. Defra’s procurement approach and new forms show the fund is operational; DESNZ’s decision record names RWE Renewables UK for this change.