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Caroll Mortensen January 13, 2012 Page 3 project concept" violates CEQA and mandates the conclusion that the lead agency did not proceed in a manner required by law. San Joaquin Raptor, 27 Cal.App.4th at 730. CEQA defines a "project" as "the whole of an action, which has a potential for resulting in either a direct physical change" or "a reasonably foreseeable indirect change in the environment." Guidelines § 15378(a) (emphasis added); see also Guidelines § 15378(c) (term "project" means the whole of the "activity which is being approved"). Thus, an agency must take an expansive view of any particular project as it conducts the environmental review for that project. See McQueen v. Bd. of Directors (1988) 202 Cal.App.3d 1136, 1143 (disapproved on other grounds in Western States Petroleum Assn. v. Superior Court (1995) 9 CalAth 559, 570) (term "project" is interpreted so as to "maximize protection of the environment"). Moreover, environmental review must be completed as early as possible in the review process. See, e.g., Bozung v. Local Agency Formation Comm., (1975) 13 Cal.3d 263, 282 ("Bozung") (expressing the importance of environmental review "at the earliest possible stage"). An EIR need not include speculation about future environmental consequences of a project, but an "EIR must include an analysis of the environmental effects of future expansion or other action if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effect." Laurel Heights, 47 Cal.3d at 394-396. Under the Laurel Heights standard, "the facts of each case will determine whether and to what extent an EIR must analyze future expansion or other action." Id. at p. 396. However, there must be discussion "in at least general terms" of future activity in connection with a project, even if the project is contingent on uncertain occurrences. Laurel Heights, 47 Cal.3d at 398. Laurel Heights requires a project proponent to analyze future expansion and other such action in an EIR if there is "telling evidence" that the agency has either made decisions or formulated reasonably definite proposals as to expand a project in the future. Id. at 396- 397. Here, there is ample "telling evidence" that the SWFP Revision and the proposed Landfill Expansion Project are inextricably connected and that the expansion of the landfill depends on the 184 -acre relocation of the landfill facility boundaries called for by the SWFP Revision. In fact, the 2010 draft environmental impact report ("2010 DEIR") for the Landfill Expansion Project identifies the 184 -acre facility expansion as SHUTE, MIHALY C, --WEINBERGERLLP