Save Tara v. City of West Hollywood (2008) 45 Cal.4th 116, rejected the argument that an agency's execution of a development agreement could never constitute approval of a project if that agreement provided that the agency retained future discretion to make final CEQA decisions. (Save Tara, supra, 45 Cal.4th at p. 134.) The court stated: "Such a rule would be inconsistent with the CEQA Guidelines' definition of approval as the agency's 'earliest commitment' to the project. (Cal. Code Regs., tit. 14, 15352, subd. (b).) Just as CEQA itself requires environmental review before a project's approval, not necessarily its final approval (Pub. Resources Code, 21100, 21151), so the guideline defines 'approval' as occurring when the agency first exercises its discretion to execute a contract or grant financial assistance, not when the last such discretionary decision is made." (Save Tara, at p. 134.) Save Tara explained: "A public entity that, in theory, retains legal discretion to reject a proposed project may, by executing a detailed and definite agreement with the private developer and by lending its political and financial assistance to the project, have as a practical matter committed itself to the project. ... For similar reasons, we have emphasized the practical over the formal in deciding whether CEQA review can be postponed, insisting it be done early enough to serve, realistically, as a meaningful contribution to public decisions." (Id. at p. 135.) Accordingly, "postponing EIR preparation and consideration thereof until after a binding agreement for development has been reached would tend to undermine CEQA's goal of transparency in environmental decisionmaking. ... When an agency reaches a binding, detailed agreement with a private developer and publicly commits resources and governmental prestige to that project, the agency's reservation of CEQA review until a later, final approval stage is unlikely to convince public observers that before committing itself to the project the agency fully considered the project's environmental consequences." (Id. at p. 136.) "On the other hand, we cannot agree with the suggestion ... that any agreement, conditional or unconditional, would be an 'approval' requiring prior preparation of CEQA documentation if at the time it was made the project was sufficiently well defined to provide '"meaningful information for environmental assessment." ' Citation." (Save Tara, supra, 45 Cal.4th at p. 136.) "Approval, within the meaning of sections 21100 and 21151, cannot be equated with the agency's mere interest in, or inclination to support, a project, no matter how well defined." (Save Tara, supra, 45 Cal.4th at p. 136.) Save Tara explained that certain "preliminary or tentative agreements may be needed in order for the project proponent to gather financial resources for environmental and technical studies, to seek needed grants or permits from other governmental agencies, or to test interest among prospective commercial tenants." (Save Tara, supra, 45 Cal.4th at p. 137.) Save Tara adopted the following general approach: "Courts should look not only to the terms of the agreement but to the surrounding circumstances to determine whether, as a practical matter, the agency has committed itself to the project as a whole or to any particular features, so as to effectively preclude any alternatives or mitigation measures that CEQA would otherwise require to be considered, including the alternative of not going forward with the project. (See Cal. Code Regs., tit. 14, 15126.6, subd. (e).) In this analysis, the contract's conditioning of final approval on CEQA compliance is relevant but not determinative." (Save Tara, supra, 45 Cal.4th at p. 139.) In support, Save Tara quoted from an authoritative CEQA treatise: " 'First, the analysis should consider whether, in taking the challenged action, the agency indicated that it would perform environmental review before it makes any further commitment to the project, and if so, whether the agency has nevertheless effectively circumscribed or limited its discretion with respect to that environmental review. Second, the analysis should consider the extent to which the record shows that the agency or its staff have committed significant resources to shaping the project. If, as a practical matter, the agency has foreclosed any meaningful option to going forward with the project, then for purposes of CEQA the agency has "approved" the project.' (Remy et al., Guide to the Cal. Environmental Quality Act (CEQA), supra, p. 71.) As this passage suggests, we look both to the agreement itself and to the surrounding circumstances, as shown in the record of the decision, to determine whether an agency's authorization or execution of an agreement for development constitutes a 'decision ... which commits the agency to a definite course of action in regard to a project.' (Cal. Code Regs., tit. 14, 15352.)" (Save Tara, supra, 45 Cal.4th at p. 139.) Applying that general approach to the circumstances in Save Tara, the court concluded that the "circumstances surrounding City's approval of the draft and final development agreements confirm City's commitment to the ... project." (Save Tara, supra, 45 Cal.4th at p. 141.) Despite the final agreement's inclusion of a condition granting the city complete discretion over CEQA matters, the city's "public announcements ... , its actions ... preparing to relocate tenants from the property, its substantial financial contribution to the project, and its willingness to bind itself, by the ... draft agreement, to convey the property if the developer 'satisfied' CEQA's 'requirements, as reasonably determined by the City Manager,' all demonstrate that City committed itself to a definite course of action regarding the project before fully evaluating its environmental effects. That is what sections 21100 and 21151 prohibit." (Save Tara, at p. 142.) Accordingly, the court returned the matter to the superior court: (1) to order the city to set aside its prior approval of the project; (2) if the city decides no subsequent or supplemental EIR is required, to review that decision; (3) to make any other order necessary and proper under section 21168.9. (Save Tara, at p. 143.)