The UK government has approved a non‑material change to the Norfolk Boreas Development Consent Order, effective 19 December 2025. The update lets the project meet its benthic compensation duties in the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) via the new Marine Recovery Fund (MRF), rather than relying solely on site‑specific debris removal. The decision notice sits alongside the statutory instrument establishing the change.

Practically, the Order refreshes definitions, confirms Norfolk Boreas Limited as the undertaker, corrects several coordinates, and modernises the HHW SAC compensation provisions in Schedule 19. It introduces a clear pathway for an MRF Payment if on‑the‑ground debris removal cannot fully meet targets, with the Secretary of State’s approval and oversight from the Marine Management Organisation (MMO) and statutory nature bodies. Industry trackers flagged this shift earlier in the year as developers sought alignment with the national fund.

HHW SAC is one of England’s most studied offshore protected sites: 146,759 hectares of mobile sandbanks and biogenic reef, including Sabellaria spinulosa ‘ross worm’ reef. These features are sensitive to cable trenching and protection if not carefully planned and monitored. JNCC’s site dossier and MPA profile underline both the ecological value and the need for cautious construction methods inside the boundary.

The Marine Recovery Fund is enabled by section 292 of the Energy Act 2023 and brought into operation by secondary legislation published in late 2025. Defra’s guidance confirms the fund delivers strategic compensatory measures for offshore wind where adverse effects on MPAs cannot be fully avoided or mitigated. In short: developers can pay for approved, long‑term measures at scale, with delivery led by the MRF Operator.

What does it cost? Defra’s library sets an interim charge of £63,131 per km2 of benthic impact per year for the ‘MPA designation and/or extension’ measure, indexed for inflation, alongside a fixed administration fee of £230,000 per measure and staged reservation/deposit fees. Applications run through Defra’s Atamis system, with timelines for reservation and payment before works begin.

For Norfolk Boreas, the amended Order now allows an MRF Payment to substitute for any shortfall in removing marine debris within HHW SAC-subject to Secretary of State agreement, a compliant implementation and monitoring plan, and confirmation that obligations are discharged once full payment (or the first instalment under contract) is made. The previous emphasis on a fixed debris‑removal trigger has been replaced with adaptive management tied to measurable delivery.

Context matters across the shared cable corridor. Earlier consent documents for the sister Norfolk Vanguard scheme referenced debris‑removal areas “up to 8.3 hectares” to compensate for predicted cable impacts, acknowledging that impacts in HHW SAC are shared between the two projects. The new Norfolk Boreas route aligns compensation with a UK‑wide programme designed to deliver ecological gains that are harder to secure piecemeal.

Guardrails are baked in. Monitoring results must go at least annually to the Secretary of State, MMO and the relevant nature conservation body, with corrective measures required if monitoring shows compensation isn’t improving HHW SAC condition. That oversight sits alongside published MRF procurement and implementation plans, so outcomes can be checked against what was promised.

The ownership backdrop has stabilised too. RWE completed its purchase of the 4.2 GW Norfolk Offshore Wind Zone from Vattenfall on 27 March 2024, and the Secretary of State approved an updated Benthic Implementation and Monitoring Plan for the zone in July 2024. Together with the MRF route, that gives a clearer path to deliver cables responsibly while keeping pace with the UK’s clean power build‑out.

For communities and conservationists, this is a pragmatic shift. Instead of scrambling to find enough local debris‑removal opportunities at the right time, funds can flow into strategic measures like new or extended MPAs where ecological returns are higher and monitoring is transparent. The test now is delivery: whether annual reports show real habitat gains in HHW SAC and across the network, and whether lessons from Norfolk are quickly applied to other UK offshore projects.