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under the specific circumstances in which the proposed activity will be carried out,these potential effects will actually occur.”(Union of Medical Marijuana Patients,Inc.,7 Cal.5th at 1197.) Here,the Ordinance will result in direct or reasonably foreseeable indirect physical changes to the environment.If the City bans STRs,guests will be forced to find transient accommodations outside of City limits.By the City’s own count,there are approximately 1,000 STRs in Santa Ana.(Staff Report,p.2.)Removing all of these existing STR accommodations from the centrally located City will almost certainly change traffic patterns,as visitors to Santa Ana and the surrounding areas will have to seek overnight accommodations elsewhere.This shifting of traffic from within the City to other locations could have significant environmental impacts,including increased vehicle emissions from people traveling further distances across Orange County to their vacation destinations or temporary/transitory places of employment and residence.This could result in air quality impacts to residents of Santa Ana and potential traffic impacts at new locations.Other reasonably foreseeable environmental impacts include,but are not limited to, increased greenhouse gas emissions resulting from the additional vehicle miles traveled,impacts from increased construction of alternative overnight accommodations (hotels and motels)to make up for the loss in overnight accommodations that STRs currently provide,and urban decay if the ban ultimately results in homeowners being unable afford their homes and causes businesses to shutter from the decline in tourism and transitory resident revenue. A Recent California Supreme Court Case Confirms that the Ordinance’s Potential Impacts Require Environmental Review In Union of Medical Marijuana Patients,Inc.v.City of San Diego,7 Cal.5th 1171 (2019),the California Supreme Court held that San Diego’s medical marijuana ordinance was a project under CEQA because it was capable of causing indirect physical changes in the environment,including changed traffic patterns.(Id.,at 1199.)The court noted that “restrictions on the siting of dispensaries would require thousands of patients to drive across the City to obtain medical marijuana.”(Id.,at 1182.)Potential changes to traffic and circulation were enough to require CEQA review.(Id.,at 1200-01.)1 The court concluded that “[a]t this initial tier in the CEQA process,the potential of the Ordinance to cause an environmental change requires the City to treat it as a project and proceed to the next steps of the CEQA analysis.”(Id.,at 1200.) As set forth above,the STR ban has the potential to result in several environmental impacts (including changes in traffic circulation),but the City has to even consider those potential impacts,rushing to conclude that the Ordinance simply is not a “project.”At the very least,the City must proceed to step two of the CEQA decision making tree to determine whether an exemption applies to the Ordinance,though we do not believe that an exemption applies gives 1 Fullerton Joint Union High School District v.State Bd.of Education,32 Cal.3d 779 (1982)provides another example.There,the court found a school district secession plan “will change bus routes and schedules,and affect traffic patterns.Although it is uncertain whether the total impact will be significant enough to require an environmental impact report,it is clear that it is sufficient to require at least an initial study to inquire into the need for such a report.”(Id.,at 794.);see also Rosenthal v.Bd.of Supervisors,44 Cal.App.3d 815,824 (1975)[“[T]he adoption of each rezoning ordinance in the present case was a project within the meaning of [CEQA]...the trial court herein erred in ruling to the effect that the adoption of each rezoning ordinance was proper and lawful,without