The California Environmental Quality Act (CEQA)1 was enacted by the California Legislature in 1970, one year after Congress enacted the National Environmental Policy Act (NEPA).2 While often referred to as a “little NEPA,” CEQA is not purely procedural like NEPA and, in fact, contains a “substantive mandate” that public agencies avoid approving projects with significant environmental impacts when there are feasible alternatives or mitigation measures that can substantially lessen or avoid such impacts.3