Offshore wind - compensating for adverse effects on Protected European Sites: statutory guidance 2026

8. Additionality

Plan or project promoters should provide a clear, evidence‑based assessment demonstrating that any proposed compensatory measure(s) is additional to normal practice for managing the site that will benefit from the measure.

Early engagement with the relevant SNCB is strongly encouraged to establish:

• what site management or restoration measures are already being delivered;

• what measures are formally agreed and planned for delivery; and

• whether proposed compensatory measures meet the criteria to be considered additional.

8.1 Establishing Additionality

For the purposes of this guidance, normal practice includes:

• site conservation measures currently being delivered. For example, predator exclusion fencing around bird colonies in a SPA; or

• planned site conservation measures formally agreed for delivery, where a clear delivery mechanism is in place. This includes actions:

  • required under statutory duties or regulatory processes;

  • supported by enforcement or regulatory action by a public authority; and

  • where funding is required, have allocated funding or a reasonable expectation that adequate funding will be secured in a timely manner at or before the point an application is submitted.

Examples of formally agreed measures include:

• conservation actions commissioned or contracted by Government or an SNCB; and

• measures for which permitting, licensing or procurement processes are already underway, such as an existing contract for installation of protective fencing.

Site conservation measures that cannot reasonably be expected to be delivered by Government or SNCBs, such as where there is no identified delivery mechanism and no reasonable expectation of timely funding may, subject to evidence, be considered outside normal practice and therefore capable of being considered additional.

In all cases, project or plan promoters must clearly evidence:

• what constitutes normal practice for the benefitting site or feature; and

• why the proposed compensatory measure goes beyond what would otherwise reasonably be delivered.

8.2 Measures that May Still be Considered Additional

A measure that falls within normal practice may be considered additional where it can be demonstrated, on the basis of evidence, that it materially accelerates the achievement of conservation objectives or expands the scale or effectiveness of outcomes beyond what would reasonably be delivered in the absence of compensation.

For the purposes of this guidance, acceleration or expansion may be considered to occur where the compensatory measure delivers one or more of the following:

• Increased scale beyond normal practice - the measure delivers site management actions at a greater spatial extent or intensity than would ordinarily be undertaken. For example, bringing forward and extending visitor management measures to redirect access away from sensitive breeding areas over a wider area than currently planned, thereby reducing disturbance to breeding seabirds.

• Enhanced effectiveness beyond normal practice - the measure improves the effectiveness, durability or reliability of site management compared with existing or planned approaches. For example, replacing temporary electric fencing around bird colonies with permanent, more robust infrastructure that provides more reliable exclusion of mammalian predators over a longer period.

In all cases, only the elements of a measure that go beyond normal practice may be counted as compensation.

Plan or project promoters must clearly distinguish between baseline (normal practice) actions and the additional components being offered as compensation.