The Secretary of State has approved a non‑material change to the Norfolk Vanguard Development Consent Order, effective from 19 December 2025. The amendment creates a formal route to make a Marine Recovery Fund payment where required seabed‑debris clearance in the Haisborough, Hammond and Winterton Special Area of Conservation cannot be fully delivered, subject to approvals. The order was made on 18 December 2025. Source: legislation.gov.uk and GOV.UK.

What changes on the ground is scope and sequencing. The amendment updates Part 3 of Schedule 17 on compensation for impacts in the HHW SAC, refreshes definitions, and sets out reporting that must be submitted at least annually to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, with follow‑on actions if measures underperform. A completion report is due within 12 months of finishing activities.

A notable shift is the removal of the previous blanket wording that prevented starting cable installation inside the HHW SAC until the full area of marine debris had been cleared. If debris removal cannot be achieved in whole or part, the undertaker can apply to substitute an agreed Marine Recovery Fund payment, priced by Defra or the fund operator and signed off by the Secretary of State.

This dovetails with the statutory framework that went live two days earlier. Under section 292 of the Energy Act 2023 and the Marine Recovery Funds Regulations 2025, the government can establish and operate one or more Marine Recovery Funds and determine when a payment discharges a project’s compensation conditions. The Regulations came into force on 17 December 2025.

Defra’s guidance, published on 17 December 2025, confirms how developers engage the fund: reserve a strategic compensatory measure from the MRFO’s library, sign a contract and pay fees. Reservation fees are banded against the quoted measure cost; for example, a £3 million allocation currently carries a £75,000 reservation fee, while allocations over £10 million attract a £200,000 fee.

Critically for scheduling and finance teams, responsibility for delivering the compensatory measure transfers to the MRFO when the developer pays in full or makes the first instalment under the fund contract. With the implementation and monitoring plan in hand, the developer can then ask the consenting authority to discharge compensation conditions. That sequencing is now mirrored in the Norfolk Vanguard amendment, which allows discharge of remaining obligations once the Marine Recovery Fund route is agreed and payments begin.

Governance remains tight. The Secretary of State must first judge the substitution acceptable in principle and confirm, with Defra’s input, the amount payable in lieu of the original measures. No cable installation within the HHW SAC can proceed until an implementation and monitoring plan is approved. This keeps environmental accountability aligned with delivery timetables.

The order also clarifies parties. The “undertaker” is now defined as Norfolk Vanguard West Limited (Company No. 08141115). The GOV.UK decision notice lists RWE Renewables UK as the company behind the change, reflecting RWE’s acquisition of the Norfolk Offshore Wind Zone from Vattenfall, completed on 27 March 2024.

Cost sharing matters because the cable corridor is shared with Norfolk Boreas. Any application to use the fund must set out the relevant proportion where impacts are shared, which should help avoid double‑counting compensation and support cleaner cost allocation across the zone.

For project finance, the practical read‑across is improved cost and timeline certainty. Instead of linking early construction strictly to successful debris clearance, Norfolk Vanguard can-if the tests are met-swap delivery risk for a priced obligation with a defined payment schedule. That makes it easier to provision under accounting standards and to set clearer contingencies ahead of any final investment decision.

The consenting environment has been evolving all year. The Marine Management Organisation varied multiple deemed marine licence conditions for the Norfolk projects with effect from 1 October 2025, signalling an active approach to tuning conditions as delivery approaches. Today’s DCO tweak fits the same pattern of tightening risk where it bites.

What to watch next: MRFO library updates and any payment band revisions from Defra; evidence of an agreed implementation and monitoring plan for the HHW SAC; and, ultimately, confirmation from the Secretary of State that a Marine Recovery Fund contract and initial payment satisfy compensation requirements. Those milestones will tell us how quickly the cable corridor can move from consent to construction without adding unnecessary environmental risk.