Wheeler North Reef Expansion Project Protects Marine Mammals and Tribal Cultural Resources

As mitigation related to the former operation of the San Onofre Nuclear Generating Station (SONGS), Southern California Edison (SCE) sought to expand the existing 174-acre Wheeler North Reef, a manmade rocky reef, off the coast of San Clemente, California by an additional 202 acres. Dudek environmental planners, archaeologists, and marine biologists assisted California State Lands Commission and Southern California Edison to ensure compliance with CEQA, tribal consultation requirements, the Marine Mammal Protection Act, and more.

To determine effects of the proposed expansion, Dudek recommended preparation of a Subsequent EIR, tiering from the 1999 EIR analyzing the original 174-acre Wheeler North Reef. By using this document, Dudek was able to maximize incorporation of useful information and analysis from that older document, while providing fresh analysis for resource areas of particular interest like marine biological resources and socioeconomics, as well as resource areas that were not previously identified in detail like greenhouse gas emissions or tribal cultural resources along the submerged historic shoreline.

Tribal Consultation Yields Special Treatment of Marine Cultural Resources

To facilitate resolution of tribal concerns, Dudek’s marine archaeology team, led by William Burns, RPA coordinated a multi-week diving program with expert subconsultant Steve Villa of NDNA Monitoring and Consulting, and Gabriel Lopez from the Acjachemen Nation of Juaneno Indians. The results of the dive surveys were used to adjust the project footprint to minimize potential for effects to tribal cultural resources, likely a first in California in the marine environment.

Extensive Monitoring Protects Marine Mammals on Wheeler North Reef

The Final Subsequent EIR was certified by the California State Lands Commission in February 2019. Then, Dudek’s marine biology team including subconsultant Tenera Environmental, commenced providing marine mammal observer services for the 2019 and 2020 construction seasons, including development of the Marine Wildlife Monitoring Plan.

A sea lion swims near a barge covered in rocks for the Wheeler North Reef expansion project.
Dudek’s marine biologists were on site to monitor for marine mammals as rock was laid during construction of the Wheeler North Reef expansion.

Dudek’s team of experienced marine mammal observers were on site for every day of construction, working as a team with SCE’s monitoring team and Connolly Pacific construction employees to ensure that no impacts occurred to marine mammals or sea turtles, and that human health and safety was prioritized.

Biologists carefully monitored marine mammal activity during construction and successfully protected marine species during this project through the issuance of more than 20 “stop work” orders in the 2020 season when California sea lions and harbor seals ventured into the exclusion zone. Other species observed included coastal bottlenose dolphins, long-beaked common dolphins, blue sharks, a humpback whale, and even one great white shark.

Stakeholder Engagement Reduces Project Risk

At key points throughout environmental review and project implementation, Dudek reduced risk to the Wheeler North Reef project through:

  • Extensive tribal outreach and collaboration with tribal representatives, including helping to modify the project footprint to alleviate tribal concerns and working together to catalog the area’s resources
  • Careful consideration of public comments from the local fishing community and taking measures to minimize effects, such as stopping construction before the start of lobster season.
  • Close coordination with California Coastal Commission and National Oceanic and Atmospheric Administration staff to ensure that violations of the Marine Mammal Protection Act did not occur.

Completed in July 2020, the Wheeler North Reef, at 376 acres, is now the largest man-made rocky reef in the world. Jenny McGee, SCE project manager, said “All work was completed without safety incident, on budget and ahead of schedule. This is a tremendous achievement and I am so proud of the teamwork that pulled this project to close with success.”

In September 2020, Dudek’s marine archaeologist will complete another dive with representatives of the Acjachemen Nation of Juaneno Indians to document the final conditions on the seafloor for tribal cultural resources. These findings will inform an article on the unique tribal consultation process for this project.


For more information on the Wheeler North Reef Expansion project or Dudek’s marine biological and archaeological, as well as tribal consultation services, contact Project Manager Michael Henry.