Segmentation or piecemealing is illegal in the State of California under  the 
Environmental Quality Act, as defined by Appellate Court Decisions and  
written into law. A project is different from a permit, as it encompasses all  
necessary actions associated to make the project go forward. Agencies that try  to 
only assess the impact, of say a driveway or access road without looking at  
the sum total of all its parts can get sued and lose big time.
 
Ron May
Legacy 106, Inc