“The Marine Recovery Fund will deliver industry-funded, strategic measures to compensate for unavoidable adverse effects.” That promise from Defra moved off the page on 19 December 2025, when the Secretary of State approved a non‑material change to the Norfolk Vanguard consent. The amendment, made on 18 December and in force from 19 December, introduces a route to use the Marine Recovery Fund if planned seabed debris clearance in the Haisborough, Hammond and Winterton Special Area of Conservation (HHW SAC) cannot be completed in full.

The Order also tidies up the paperwork. It inserts a definition of Defra and confirms the “undertaker” as Norfolk Vanguard West Limited, aligning the consent with the current project structure under RWE. Companies House lists Norfolk Vanguard West Limited (No. 08141115) as active, with its registered office in Swindon.

One notable shift is the removal of a hard pre‑condition that used to block any cable installation in the HHW SAC until a specified area of marine debris had been cleared. In its place, the amended consent requires at least annual monitoring returns to the Secretary of State, the Marine Management Organisation and the statutory nature conservation body, plus follow‑up proposals if the measures are not improving site condition.

For context, the HHW SAC sits off the north‑east Norfolk coast and spans roughly 1,468 km² of dynamic sandbanks and patchy biogenic reefs built by ross worms (Sabellaria spinulosa). It’s protected for Annex I sandbanks “slightly covered by sea water all the time” and for reef habitat that supports a mix of attached and mobile species.

The Marine Recovery Fund itself is enabled by section 292 of the Energy Act 2023. Defra’s guidance, published on 17 December 2025, sets out how developers can apply to fund strategic compensation delivered at scale, with the consenting authority deciding whether a payment discharges a project’s compensation duty. In short: it’s optional, but once accepted it can settle part or all of the required environmental compensation.

Under the Norfolk Vanguard amendment, if the required area of marine debris is not removed, the undertaker can apply to substitute a Marine Recovery Fund payment for that shortfall. The Secretary of State must agree the principle and the proportion, and Defra must confirm the fund can be used, including the cash value. Once an implementation and monitoring plan is approved and the agreed payment is made (or contracted in instalments), the developer can be discharged from further delivery of those specific compensation measures. The Order also recognises the shared cable corridor with Norfolk Boreas when calculating any payment.

Project ownership has been through a handover: RWE completed its purchase of the Norfolk Zone from Vattenfall on 27 March 2024. RWE says the next milestone for Vanguard West and East is securing a Contract for Difference in a future auction. Norfolk Vanguard did not appear among successful projects in the government’s AR6 results published on 3 September 2024.

Why this matters north of the Wash: supply‑chain firms across the North East are primed for subsea work as the next wave of East Anglian projects firm up. JDR’s new high‑voltage subsea cable factory at Cambois, near Blyth, has been progressing through commissioning in 2025, positioning the region to compete for export and array cable packages. Its long‑standing Hartlepool site underpins that capacity.

Local sea users will watch the practicalities closely. Eastern IFCA continues to signpost Notices to Mariners for Norfolk Vanguard activities, while the Planning Inspectorate confirmed approval of a Benthic Implementation and Monitoring Plan update in July 2024. The amended consent keeps annual reporting to the Secretary of State, MMO and Natural England, so evidence on the seabed’s recovery should be public‑facing and regular.

Environmental bodies will scrutinise any switch from physical seabed measures to cash‑funded compensation. Natural England’s 2025 research highlights continuing uncertainty over how rock protection alters sandbank condition-one reason ministers created a strategic compensation route in the first place. The new option is not a free pass; it just changes how, and by whom, the remedial work is delivered.