Norfolk Vanguard: new route to Marine Recovery Fund
“The Marine Recovery Fund will deliver industry‑funded, strategic measures to compensate for unavoidable adverse effects of offshore wind on marine protected areas,” says new Defra guidance issued on 17 December 2025. Two days later ministers signed off a change to Norfolk Vanguard’s consent that puts that option on the table.
On 19 December 2025 the Secretary of State approved a non‑material change to the Norfolk Vanguard Offshore Wind Farm Order 2022. The tweak allows a payment into the Marine Recovery Fund where agreed seabed debris removal inside the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) cannot be achieved, and updates the named undertaker to Norfolk Vanguard West Limited.
HHW SAC sits off the north‑east Norfolk coast and protects shifting sandbanks and reefs, including Haisborough, Hammond Knoll and Winterton Ridge. It’s a dynamic bit of seabed where cabling and scour protection are closely managed to avoid long‑term damage.
What’s changed in practice? The order refreshes Schedule 17 (Part 3) for the HHW SAC programme. If the required area of marine debris cannot be cleared, the undertaker may apply to make a Marine Recovery Fund Payment as an adaptive measure, subject to Secretary of State approval and confirmation from Defra on the sums due. Obligations are discharged once the payment is made or contracted, but any payment schedule must still be honoured.
The move dovetails with the Marine Recovery Funds Regulations 2025, which came into force on 17 December 2025 and formally set up how the fund operates across the UK. In short, payments can be used to deliver strategic compensation in place of bespoke project measures where regulators agree it’s appropriate.
The monitoring regime remains firm. Results must be sent at least annually to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, with corrective action required if measures are found ineffective. A completion report is due within 12 months of finishing the agreed activities.
There’s a Northern angle. RWE, which now owns the Norfolk Zone after purchasing it from Vattenfall in March 2024, is also building the 1.4GW Sofia project with export cables landing at Redcar, Teesside. The Norfolk update shows how Whitehall expects compensation to work nationally, and will be watched by North East ports and fisheries as more cables come ashore.
Industry is split on the detail. Trade body Energy UK welcomed progress on the fund but raised concerns over the ‘gatekeeper’ role for nature bodies and a 30% uplift on some adaptive payments-arguing costs and responsibilities must be crystal clear to keep projects bankable.
The order also clarifies who carries the can day‑to‑day by naming Norfolk Vanguard West Limited as the undertaker. Companies House shows the entity is active, with consents and variations in 2025 also noting address updates across the Norfolk Vanguard and Boreas licences.
For coastal communities and supply‑chain firms from Grimsby to the Tyne, the signal is straightforward: the Marine Recovery Fund is now live, with published reservation fees and an application process. Developers can switch from bespoke plans to the fund where agreed, but monitoring and accountability do not go away. Expect this Norfolk rule‑change to shape how future North Sea cable corridors are consented and paid for.