“Payments may be made towards expenditure on measures to compensate for adverse environmental effects of relevant offshore wind activities.” With that principle written into the Energy Act 2023, ministers have now approved a non‑material change to the Norfolk Vanguard Development Consent Order (DCO), effective from 19 December 2025. The decision confirms a new route for compensation within the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC).

In practical terms, if the developer cannot deliver all the agreed seabed clean‑up and protection measures inside the HHW SAC, the Secretary of State can approve a contribution into the Marine Recovery Fund (MRF) instead. The Fund was created by section 292 of the Energy Act 2023 to support strategic environmental compensation linked to offshore wind.

The order also tightens oversight. Monitoring results must be sent at least annually to the Secretary of State and the Marine Management Organisation (MMO), with remedial proposals required if measures aren’t working. The change is classed as “non‑material”, but it resets how habitat compensation can be delivered and verified for this project.

Why here matters is clear. The HHW SAC spans shifting sandbanks and biogenic reef off the north‑east Norfolk coast, including features such as Sabellaria spinulosa reef. It is a protected site under UK law and overseen jointly by JNCC and Natural England for offshore advice.

There are housekeeping changes too. The ‘undertaker’ named in the consent is updated to Norfolk Vanguard West Limited (Company No. 08141115), reflecting the project’s current corporate structure, with RWE listed by government as the company behind the change application.

A notable clause deals with how compensation is shared because Vanguard and its sister project, Norfolk Boreas, use a shared cable corridor from landfall at Happisburgh to Necton. Vattenfall first set out the shared onshore route in 2017; the new wording formalises how any compensation is apportioned where impacts overlap.

For Northern readers, this is not just a Norfolk paperwork tweak. A clearer MRF pathway could speed decisions across the North Sea build‑out where our ports and firms are deeply involved in cables, seabed tooling and vessels. From Blyth’s mobilisation work to Teesside’s wider supply chain, standardised compensation could reduce delays that ripple through schedules and yards.

The Fund also raises accountability questions. Ministers can determine whether a payment into the MRF discharges a developer’s compensation condition. That makes transparency on valuations and where the money is spent essential, so coastal communities and marine users can see habitat gains, not just balance‑sheet entries.

Officials stress this is about keeping protections in place while giving a fallback if specific clean‑up targets inside the SAC cannot be met. Works within the HHW SAC remain conditional on the Secretary of State’s approval of an implementation and monitoring plan, even if an MRF payment route is agreed.

Signed on 18 December and in force from 19 December 2025, the order is a small but consequential change: it aligns a live East Coast project with the national compensation framework and signals how future offshore wind consents could handle tricky seabed habitats-without leaving developers or conservation bodies stuck in limbo.