The UK has approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order, allowing payments into the Marine Recovery Fund when agreed seabed clean‑up cannot be fully achieved inside the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC). The amendment was made on 18 December 2025 and came into force on 19 December 2025. Officials confirmed the decision alongside the project’s change documentation.

The instrument updates definitions and names Norfolk Vanguard West Limited as the undertaker, reflecting RWE’s ownership of the Norfolk Offshore Wind Zone after its 27 March 2024 acquisition from Vattenfall. Companies House lists Norfolk Vanguard West Limited under company number 08141115.

What shifts in practice is how compensation inside the HHW SAC can be delivered. The earlier pre‑condition that cable works could not start in the SAC until the required area of marine debris had been cleared is removed. If debris retrieval falls short, the undertaker may apply to substitute the outstanding portion with a Marine Recovery Fund payment, subject to the Secretary of State’s agreement and Defra confirming that the Fund can be used and the sum due. Discharge from further on‑site compensation duties can follow either completion of works, full payment, or an instalment contract approved in writing.

The 2022 consent set the benchmark: compensation in the HHW SAC included retrieval of lost material and public‑facing measures to reduce future debris, with the removal area tied to the predicted footprint of cable installation and protection-up to 8.3 hectares. Those strands and the requirement for a benthic implementation and monitoring plan (BIMP) and a benthic steering group (BSG) remain the framework for managing impacts.

The Marine Recovery Fund itself was created under section 292 of the Energy Act 2023 to deliver strategic, industry‑funded compensation for unavoidable impacts from offshore wind on protected sites. Defra opened guidance and applications on 17 December 2025, including banded reservation fees for strategic compensatory measures, signalling that the scheme is now operational.

Why the HHW SAC matters is clear. Spanning about 1,467.6 km² off the Norfolk coast, the site protects mobile sandbanks and biogenic reef formed by Sabellaria spinulosa. These reefs rise 5–10 cm above the seabed and can carpet whole areas, creating complex habitat that supports rich epifaunal communities. The SAC straddles the 12‑nautical‑mile limit and is advised jointly by JNCC and Natural England.

Rock or concrete placed to protect cables can permanently alter sandbank character by introducing hard substrate. Natural England’s 2025 review links deposited rock in sandbank MPAs to unfavourable site condition and highlights evidence gaps-one reason government has moved toward strategic, pooled compensation alongside tighter monitoring. Project‑level assessments echo the risk that new hard surfaces shift communities away from soft‑sediment species.

The change also recognises reality in a shared corridor. Vanguard and Boreas share sections of export cabling through the HHW SAC; any application to use the Fund must set out the share of impact and what has already been delivered under Boreas. The Secretary of State must be satisfied on both principle and price before consenting to a swap from on‑site debris removal to a Fund contribution.

Monitoring remains non‑negotiable. Results must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body. If measures underperform, the undertaker must bring forward fixes and implement them once approved-an explicit feedback loop that should be matched by transparent, publishable datasets.

For communities and nature, debris retrieval still counts. Clearing derelict gear reduces snag risks and restores habitat, complementing strategic measures bought via the Fund. UK NGOs note that ghost gear is a persistent threat and that removing it delivers immediate ecological gains-useful context for judging the balance between local action and pooled compensation.

What to watch in 2026 is delivery. With RWE advancing the 4.2 GW Norfolk portfolio and procurement under way, the new route gives regulators and developers a clearer path to secure compensation while keeping pressure on outcomes in the HHW SAC. The test will be whether reported condition trends improve as promised.