In Lee v. Lost Hills Water District (Lee) (1978) 78 Cal. App. 3d 630, certain landowners challenged a water district's adoption of a negative declaration concerning the district's proposed construction of an irrigation system in an area under its jurisdiction called "Eastside 1 Service Area." To develop that project, the district needed to condemn easements and fee estates in another one of its service areas called "Eastside 2 Service Area." The landowners argued that the district needed to prepare a CEQA document for Eastside 2 Service Area. (Id. at p. at p. 634.) The appellate court rejected that claim, citing the "whole of the action" rule. (Ibid.) As the court emphasized, "A single activity does not become a series of projects simply because it may affect lands or owners within various service areas of a water or irrigation project. (Id. at pp. 634-635.)