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1 59. Failure to carry out the full CEQA procedures so that complete information as to a 2 project's impacts is developed and publicly disclosed constitutes a prejudicial abuse of discretion 3 that requires invalidation of the public agency action,regardless of whether full compliance would 4 have produced a different result. Cal. Pub. Res. Code § 21005. 5 60. In Union of Medical Marijuana Patients, Inc. v. City of San Diego, 7 Cal. 5th 1171, 6 1197(2019),the California Supreme Court reaffirmed the longstanding understanding that passing 7 a generally applicable zoning ordinance constitutes a "project" under CEQA and requires the 8 relevant public agency to "undertake an initial study to determine whether the project `may have 9 a significant effect on the environment."' Id. at 1186. Such study is a critical step in furthering 10 CEQA's core purposes of (1) informing the public about a proposed activity's potential 11 environmental impacts; (2) identifying ways to reduce, or avoid, environmental damage; 12 (3)preventing environmental damage; and (4) disclosing to the public the rationale for approval 13 of a project that may significantly impact the environment. Id. at 1184. 14 61. In Union of Medical Marijuana Patients, Inc., the California Supreme Court held 15 that San Diego's medical marijuana ordinance was a project under CEQA because it was capable 16 of causing indirect physical changes in the environment, including changed traffic patterns. Id. at 17 1199. The court noted that "restrictions on the siting of dispensaries would require thousands of 18 patients to drive across the City to obtain medical marijuana." Id. at 1182. Potential changes to 19 traffic and circulation were alone enough to require CEQA review. Id. at 1200-01. The court 20 concluded that "[a]t this initial tier in the CEQA process, the potential of the Ordinance to cause 21 an environmental change requires the City to treat it as a project and proceed to the next steps of 22 the CEQA analysis." Id. at 1200. 23 62. Despite these clear requirements under CEQA, the City disregarded California's 24 seminal environmental protection law and clear direction from the California Supreme Court. It 25 concluded Ordinance No. NS-3061 was not a project under CEQA, stating: "The proposed 26 ordinances are not subject to the requirements of [CEQA], pursuant to the Guidelines section 27 15060(c)(2) because the activity will not result in a direct or reasonably foreseeable indirect 28 physical change in the environment and 15060(c)(3)because the activity is not aproject as defined VERTFTED PETTTTON FOR WRTT OF MANDATE 17 AND COMPLATNT