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Data-Driven Environmental Journalism

Norfolk Vanguard DCO adds Marine Recovery Fund for HHW SAC

On 19 December 2025, the Secretary of State approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022, updating how compensation and monitoring are delivered when works interact with the Haisborough, Hammond and Winterton Special Area of Conservation.

The Order names Norfolk Vanguard West Limited as the undertaker and inserts a definition of Defra, providing administrative clarity on who is responsible for delivering and agreeing any measures. It also sets out the benthic implementation and monitoring plan (BIMP) as the framework for scoping and reporting compensation. Norfolk Vanguard West Limited is registered as company number 08141115.

A key change removes the previous pre‑start condition that a set area of marine debris must be cleared in the SAC before cables are installed. The Order instead requires at least annual reporting to the Secretary of State, the Marine Management Organisation (MMO) and the statutory nature conservation body, with remedial proposals implemented if results show measures are not effective.

This matters because the HHW SAC spans 146,759 hectares of mobile sandbanks and Sabellaria spinulosa reef off Norfolk’s coast-features that are sensitive to seabed disturbance and cable protection. That context supports a monitoring‑led approach that can adjust to this dynamic system.

The amendment also creates an adaptive route to pay into the Marine Recovery Fund where debris clearance cannot be fully achieved. Under section 292 of the Energy Act 2023, such funds can receive payments from offshore wind projects and, where determined by the Secretary of State, treat those payments as discharging compensation duties.

In practice, the undertaker may apply for a Marine Recovery Fund Payment to substitute for the portion of debris removal not delivered, including a defined share where effects arise from the shared cable corridor with the Norfolk Boreas project; approval depends on confirmation of principle and quantified sums from Defra or the fund operator.

Once the Secretary of State approves either a completion report or the agreed Marine Recovery Fund contribution-in full or via an instalment contract confirmed with Defra-the undertaker is discharged from further on‑site compensation delivery under this part, while any payment schedule must still be honoured.

Strategic compensation of this kind is the direction of travel in UK consenting. The Energy Act’s explanatory notes describe the Marine Recovery Fund as an optional route to discharge compensation conditions, designed to enable measures to be delivered at the right scale and time across projects.

The Department for Energy Security and Net Zero published the decision on 19 December 2025, with the Order signed on 18 December by John Wheadon, Head of Energy Infrastructure Planning Delivery. The decision page lists RWE Renewables UK for the project, while the Order confirms Norfolk Vanguard West Limited as undertaker.

Delivery now matters most: transparent valuations for any Marine Recovery Fund payments, publication of monitoring results, and a live BIMP developed with the MMO and nature bodies will demonstrate whether cable works and compensation improve site condition in the HHW SAC.

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