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Norfolk Boreas DCO adds Marine Recovery Fund option

The government has approved a non‑material amendment to the Norfolk Boreas Offshore Wind Farm development consent order (SI 2025/1362), made on 18 December 2025 and in force from 19 December, according to the Department for Energy Security and Net Zero. The order updates definitions to include the Department for Environment, Food and Rural Affairs (Defra) and confirms Norfolk Boreas Limited (Company No. 03722058) as the undertaker.

The most consequential change sits in the compensation regime for the Haisborough, Hammond and Winterton Special Area of Conservation. The previous hard pre‑commencement trigger that required removal of at least 8.3 hectares of marine debris before cable installation in the SAC has been deleted. In its place is an adaptive route that allows payment into the Marine Recovery Fund where physical measures cannot be completed in full.

Under the amended schedule, the undertaker may apply to the Secretary of State to make a Marine Recovery Fund payment for any shortfall in debris removal. Approval hinges on two confirmations: that using the fund as an adaptive measure is acceptable in principle, and that Defra (or the body running the fund) has priced and agreed the sums due in lieu of on‑site compensation.

If the payment route is approved, cable works within the SAC cannot proceed until an implementation and monitoring plan is signed off and the undertaker is discharged from further delivery obligations. Discharge can be achieved by paying the full agreed amount or by entering a contract for instalments and making the first payment, with written confirmation from the Secretary of State that this satisfies the compensation requirement.

Monitoring and accountability are tightened rather than relaxed. Results from the benthic monitoring scheme must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the relevant statutory nature conservation body, including any findings where measures are not delivering. A completion report is due within 12 months of finishing activities under the benthic implementation and monitoring plan.

For investors, this is about capex certainty and programme discipline. Removing a rigid gating condition reduces schedule slippage risk in cable‑lay windows, a frequent cost driver in offshore wind. The ability to meet residual obligations via the Marine Recovery Fund-potentially through staged payments-supports cashflow management without pausing the build.

For the supply chain, especially cable‑lay vessels and environmental contractors, the change should cut idle time and re‑mobilisation risk. Environmental outcomes remain central: the Secretary of State can require revised measures if monitoring shows limited effectiveness, but sequencing becomes more predictable, which tends to lower contingency and day‑rate exposure.

Cost allocation is also clarified where the export cable corridor is shared with Norfolk Vanguard. The order requires the application to set out the proportion of the overall debris‑removal obligation attributable to Norfolk Boreas when impacts are shared, improving transparency for lenders and joint‑corridor planning.

A small but useful tidy‑up corrects project coordinates in the authorised development for points 29, 67 and 164. These mapping fixes sound minor, yet they matter when translating consent into marine licences, contractor method statements and interface drawings.

The amendment embeds the Marine Recovery Fund created under the Energy Act 2023 into a live offshore wind DCO. That signals a shift towards strategic, fund‑based compensation where appropriate, rather than relying solely on project‑by‑project physical measures-an approach many finance teams have modelled for pipeline projects.

Next steps to watch include publication of any updated benthic plan, confirmation of sums if the fund route is used, and subsequent approvals from the Secretary of State. For regional SMEs across survey, debris clearance and monitoring, steadier work orders are likely through 2026 as start‑stop risks ease.

SI 2025/1362 is signed for the Secretary of State by John Wheadon, Head of Energy Infrastructure Planning Delivery at the Department for Energy Security and Net Zero. That signature converts policy into executable consent, providing a clearer path for both programme timelines and the allocation of environmental compensation costs.

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