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City of Santa Ana—Cabrillo Town Center Project May 16,2023 Page 8of12 include all phases of the project. (CEQA Guidelines §§ 15063, subd. (a)(1); 15378, subd. (a); Natural Resources Defense Council v. City of Los An (2002) 103 Cal.App.4th 268, 271 ["[t]he CEQA process is intended to be a careful examination, fully open to the public, of the environmental consequences of a given project, covering the entire project, from start to finish"].) Thus, CEQA prohibits evading comprehensive CEQA analysis by "chopping a large project into many little ones -- each with a minimal potential impact on the environment -- which cumulatively may have disastrous consequences." (Bo ung v. LAFCO. (1975) 13 Cal.3d 263, 283-84; Orznda Assn v. Board of Supervisors (1986) 182 Cal.App.3d 1145, 1171.) Further, "if projects are `various steps which taken together obtain an objective,' they are a single project for the purposes of CEQA." (Aptos Council v. County of Santa Cru.Z (2017) 10 Cal.App.5th 266, 283.) This is also true for projects that are "integrally related." (Nelson v. County of Kern (2010) 190 Cal.App.4th 252, 272.) Lead agencies must "construe the project broadly to capture the whole of the action and its environmental impacts." (Save Berkeley s Neighborhoods v. Regents of University of California (2020) 51 Cal.App. 5th 226, 239.) Here, although the Project was approved by the Planning Commission on April 24, 2023, the City is now separately considering the Water Supply Assessment for the Project. The Water Supply Assessment is particularly critical to determine whether the Project may have impacts on water and public services. Yet, the timing of it now indicates that the EIR omitted that analysis and discussion. Further yet, the timing of the Water Supply Assessment now is disfavored in CEQA since it amounts to nothing more but a post hoc rationalization. In the words of the Court, "A study conducted after approval of a project will inevitably have a diminished influence on decisionmaking. Even if the study is subject to administrative approval, it is analogous to the sort of post hoc rationalization of agency actions that has been repeatedly condemned in decisions construing CEQA. [Citations.]" (Sundstrorn v. County of Mendocino (1988) 202 Cal.App.3d 296, 307, 248 Cal.Rptr. 352 (Sundstrom).) That is what happened here. Thus, the Project approvals proceeded with piecemealed environmental review, in violation of CEQA, and must be set aside to ensure CEQA's mandates are not reduced to post hoc rationalization but are indeed scrupulously observed, including as to their timing.