The UK government has approved a non‑material change to Norfolk Vanguard’s consent that opens a new route to deliver habitat compensation in the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). From 19 December 2025, developers can use the Marine Recovery Fund (MRF) where agreed debris‑removal targets at sea cannot be fully met, with strengthened reporting and oversight retained.

Made on 18 December and in force from 19 December, the amendment updates the development consent order’s Schedule 17. It formalises a Benthic Implementation and Monitoring Plan (BIMP), shaped by a Benthic Steering Group, and requires at least annual results to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body, with remedial measures if monitoring shows under‑performance.

The change introduces adaptive management: if the required area of marine debris removal in the HHW SAC cannot be completed, the undertaker may apply to substitute the shortfall with a Marine Recovery Fund payment. Approval relies on the Secretary of State and confirmation from Defra or the MRF operator that the fund can be used, including a quantified sum in lieu of the on‑site measure.

Once a substitution is approved, cable installation inside the HHW SAC cannot proceed until an implementation and monitoring plan is signed off. The developer can then be discharged from remaining site‑specific compensation once the payment is made or contracted; all instalments and conditions under any MRF agreement must still be honoured.

The HHW SAC, designated for sandbanks and reefs off the Norfolk coast, is sensitive to seabed disturbance from cable installation and protection. The compensation framework aims to maintain the coherence of the national site network while enabling grid connections for strategic offshore wind. Scientific advisors at JNCC describe the site’s protected features and monitoring needs.

The MRF became operational on 17 December 2025 under The Marine Recovery Funds Regulations 2025. It allows payments in respect of offshore wind activities, with funds directed to strategic measures that deliver ecological outcomes at scale across projects. This complements project‑level actions and helps avoid delays where bespoke measures are hard to deliver.

In practice, developers enter conditional agreements through the fund’s operator and can reserve strategic compensatory measures drawn from the government’s library. Reservation fees are banded by measure value-for example, £15,000 for measures under £500,000 and £200,000 for measures above £10 million-providing budget clarity early in delivery.

This amendment lands alongside wider policy to speed clean power while protecting nature. Defra’s consultation confirms the fund is designed to streamline consents without weakening environmental safeguards, and ministers have now published their response and interim guidance to steer ornithological and benthic measures before full rollout.

Norfolk Vanguard sits within a 4.2 GW zone now owned by RWE, which also includes Norfolk Boreas and Norfolk Vanguard East. Each project is planned at 1.4 GW and shares well‑advanced consents and grid connections-context that explains why a strategic compensation pathway helps coordinate delivery across shared cable corridors.

For communities and campaigners, the signal is clear: monitoring data must show genuine ecological improvements in the SAC, with corrective action where needed. For developers, early engagement with Natural England and the Benthic Steering Group, alignment with the strategic measures library, and transparent annual reporting will be the difference between paperwork and proof. The decision was published on 19 December 2025 and sits within DESNZ’s latest round of consenting updates.