The State established July 1, 2020 as the date for cities to begin implementing the new law. However, many cities, including Milpitas, are still in the process of adopting new VMT policy and guidelines. The State recognizes this and allows cities to implement VMT methodology without an established policy after the July 1, 2020 deadline. Without a new VMT policy in place, new development in Milpitas is currently required to measure transportation impacts using VMT methodology on a project-by-project basis and continue to measure Level of Service (outside of CEQA) to comply with the Santa Clara Valley Transportation Authority’s (VTA’s) Congestion Management Program (CMP) and existing General Plan policies. It is anticipated that the new VMT policy will be in effect immediately after City Council approval tentatively scheduled for December 2020.