Technically that is true. The citation (Notice to Appear) is simply a document the arrestee may sign in order to be released from custody. Vehicle Code DIVISION 17, ARTICLE 2 is titled Release Upon Promise to Appear; If the person is not under arrest and in custody, what are they being released from?
VC 40302 "Whenever any person is arrested for any violation of this code…the arrested person shall be taken without unnecessary delay before a magistrate…in any of the following cases:
(b) When the person arrested refuses to give his or her written promise to appear in court."
40500(a) "Whenever a person is arrested for any violation of this code not declared to be a felony, or for a violation of an ordinance of a city or county relating to traffic offenses and he or she is not immediately taken before a magistrate, as provided in this chapter, the arresting officer shall prepare in triplicate a written notice to appear in court…"
PC 853.5(a) "Except as otherwise provided by law, in any case in which a person is arrested for an offense declared to be an infraction, the person may be released according to the procedures set forth by this chapter for the release of persons arrested for an offense declared to be a misdemeanor."
A Notice to Appear is ONLY issued to persons under arrest.