Palo Alto is hoping Stanford University will help pay for the realignment of Caltrain rail crossings so that tracks and roadways will no longer intersect.

Mountain View is calling for the university to pay its "fair share" for future improvements to local intersections.

Menlo Park is requesting that the university consider creating new satellite lots with new shuttles or a "gondola" moving people from these lots to the university's growing campus.

These transportation-centered requests, as well as dozens of others pertaining to housing, schools and more, were submitted by Peninsula cities, agencies and residents as part of a new environmental analysis for Stanford's proposed expansion. The Final Environmental Impact Report, which Santa Clara County released on Dec. 21, pertains to Stanford's application for a "general use permit" (GUP), which would allow the university to build up to 2.275 million square feet of academic space, 3,150 new housing units or beds (this includes 550 that would be available for faculty, staff, postdoctoral scholars and medical residents), and 40,000 square feet for child care centers and transit hubs by 2035.

Publication of the voluminous document marks a key milestone for the county's review process of a project that Joe Simitian, president of the county's Board of Supervisors, has described as the largest development application in the history of the county, which has jurisdiction over land not governed by the cities. But while the new analysis devotes hundreds of pages to analyzing traffic impacts (as well as everything from noise and water quality), it is unlikely to satisfy city leaders who for months have been calling for the county to require stronger action from Stanford to mitigate the consequences of its growth.

The thorny issue of traffic

In the new report, the county is noncommittal on most proposed solutions, including requiring Stanford to chip in for Caltrain improvements or to roll out more Marguerite shuttles. County officials have also rejected calls to encourage more satellite parking lots and to revise Stanford's existing "No Net New Commute Trips" policy, which currently applies only to campus-related trips in the commute direction during peak hours (8-9 a.m. and 5-6 p.m., the busiest hours of the morning and afternoon commutes).

The policy, which was introduced under Stanford's last GUP in 2000, has been the county's strongest tool to ensure Stanford's growth would not result in overwhelming traffic. It has spurred Stanford to, among other things, expand its Marguerite shuttle program, increase parking fees and introduce car- and ride-share programs. As a result, Stanford's rate of solo drivers has dropped from 69 percent in 2003 to 43 percent today, according to the county.

But while Stanford's traffic-reduction programs are generally viewed as a gold standard in the region, many are skeptical that the policy will continue to hold up in the face of millions of square feet of new development.

Palo Alto and East Palo Alto are among those cities that have argued in favor of a more expansive definition of "peak hours," which they say does not currently reflect actual travel patterns. A letter from East Palo Alto, signed by former Mayor Ruben Abrica, states that the city is "gravely concerned about traffic," especially given that 84 percent of the peak-hour traffic on University Avenue are commuters and that Stanford's proposal would add about 5,000 new jobs.

"Off-peak traffic is a concern, given that East Palo Alto residents are experiencing significant traffic at all times," the letter states.

Palo Alto expressed similar concerns and pointed to "a recent trend of peak spreading," the tendency of Stanford commuters to drive just before or just after the "peak period." To support this position, the city hired a consulting firm, Hexagon, to review data from Stanford's cordon counts. The consultant noted that even the county's environmental analysis uses the broader "peak period" times of 7 to 10 a.m. and 4 to 7 p.m. in analyzing intersection counts.

Hexagon cited its own count data as evidence that the morning peak hour frequently occurs after 9 a.m. and the afternoon peak frequently occurs after 6 p.m.

"One of the likely reasons why there appears to be a disconnect between Stanford's achievement of the 'no net new trips' standard and the community's experience of increasing level of congestion may be that there are higher levels of Stanford-related trips throughout the day or during much longer periods during the morning and evening than was true in 2001," the Hexagon letter states.

The county, however, was not swayed. It offered its own data, measured twice yearly, which showed the number of cars entering and exiting Stanford during the 8-9 a.m. and 5-6 p.m. hours decreased between 2012 and 2016. The data also showed that in every year since 2014, the pattern of traffic during the broader peak hours remained consistent, directly contradicting the Hexagon assertion.

"Focusing the no-net-new-commute-trips standard on the peak hour has not pushed trips to the shoulder hours or encouraged peak hour spreading," the county's response states.

Palo Alto has also urged the county to demand more details from Stanford about how it plans to ensure traffic does not get worse. The FEIR, the city had argued, should "explicitly identify the current and future transit and TDM (transportation-demand management) programs that will be relied on to meet the No New Net Commute Trips goal."

Accountability without the specifics

The new analysis does no such things. Instead, following the theme of "flexibility with accountability" that was the bedrock of the 2000 permit, county officials have indicated that they are generally amenable to Stanford establishing its own programs, provided that they meet the goals of not adding new commute traffic during peak hours.

"This framework gives Stanford the flexibility to change the TDM program to meet the no-net-new-commute-trips standard as the campus population changes and technology advances."

That said, the FEIR identifies several transportation-related programs that Stanford has proposed to implement as part of its growth plan. These include new dedicated bus lanes and express bus services, dynamic real-time carpooling apps like Scoop, the use of parking rates to discourage driving, financial incentives for non-drivers and increased use of telework and flexible work schedules, according to the FEIR.

Mountain View, for its part, requested assurances that Stanford would contribute its "fair share" of funding for improvements to "any intersections under the jurisdiction of our city" affected by Stanford's growth. The FEIR does not go that far, though it identifies as mitigations Stanford's contributions of funding toward the proposed closure of Castro Street near the rail tracks and toward the creation of a second southbound left-turn lane from Central Expressway to Moffett Boulevard.

These improvements are part of a broader list of infrastructure improvements that Stanford would be required to make if it does not meet the goal of no net new commute trips.

The one change that the county did institute in response to community concerns was a requirement that Stanford pay a "fair share" for improvements at intersections that are expected to see an increase in reverse-commuters. These include the El Camino Real and Ravenswood Road intersection in Menlo Park and the Alma Street and Charleston Road intersection in Palo Alto. The precise share is based on the number of reverse-commute trips that would be attributable to the Stanford project.

County pushes for support of housing

While the county analysis did not go as far as some cities had wanted in considering Stanford's impact on traffic, it has been largely responsive to concerns related to housing. In June, the county released two new alternatives that would go well beyond the 3,150 housing units Stanford proposed. One would include 5,699 units, while the other calls for 4,425.

The county Board of Supervisors has also been aggressively pursuing new policies, independent of the environmental-analysis process, aimed at requiring more contributions of money from Stanford for housing. These include a new policy that raises the "affordable housing fee" that Stanford pays for each square foot of new development from $20 to $68.50, effective July 1, 2020. The other requires Stanford to designate 16 percent of new units to affordable housing.

Stanford last month filed lawsuits in federal and state courts challenging the new inclusionary-zoning requirement, which it argues violates the "equal protection" clauses of the U.S. and California constitutions. It also plans to legally challenge the new impact fee.

Palo Alto argued that the county should go further and require Stanford to actually build housing and transportation improvements before it constructs new academic space. The environmental analysis does not propose such a policy, noting that the issue is better suited for a policy debate than an environmental analysis.

"Whether development under the project should be contingent upon (i.e., linked to) the implementation of certain transportation solutions is an issue for the county Board of Supervisors to consider when it determines whether, and under what conditions, to approve the project."

Contributions to the school district

One topic on which the new analysis is bound to disappoint many Palo Alto residents is Stanford's responsibility when it comes to Palo Alto schools. In recent months, Palo Alto Unified School District board members, staff and parents became increasingly vocal about the need for Stanford to commit funding to educate the additional students who would result from the university's expansion.

During a community meeting in late November, then-school board President Ken Dauber was one of many residents to request Stanford contributions to local schools, noting that the district is funded based on property taxes and does not get state funding on a per-student basis.

Dauber called the financial impact of accommodating new students from Stanford's population growth without any funding from Stanford "an existential threat to the quality of education in Palo Alto."

The school board also passed a resolution in November asking the Stanford be contractually required to pay the district on a per-student basis and to set aside 4 acres or more near the Sand Hill Road/Quarry Road corridor for an elementary school. It also asked that the university contribute to the cost of building the school.

The final EIR makes no such recommendations. Instead, it states that existing district schools could accommodate the new students.

Furthermore, it asserts the district has "multiple options to explore before building a new school, including reactivating existing school sites such as Cubberley, Greendell and Garland, and utilizing properties currently leased to private school providers."

"Given all these circumstances, construction of a new PAUSD elementary school appears to be speculative."

In addressing school impacts, the final EIR recognizes its own limitations: The county "does not have authority to require Stanford to pay additional fees, dedicate land or comply with any other requirements associated with increased school enrollment."

That said, supervisors have one tool that they can use to require Stanford to contribute to local schools. The board recently kicked off negotiations with Stanford on a first-of-its-kind "development agreement," which is giving both sides the opportunity to request concessions and amenities that fall outside the purview of the environmental-review process.

Simitian last month told the Weekly that the school district will be a key topic of negotiations.

"In the development agreement we can have the opportunity to say, 'Can you help in this or that way?'"

Stanford staff lauded the new analysis, which the county Board of Supervisors expects to review and approve by this summer. Catherine Palter, Stanford's associate vice president for land use and environmental planning, said the FEIR confirms that "almost all environmental impacts of new academic and residential facilities can be appropriately prevented or mitigated."

"The result of that process is a proposal that balances the needs of the university and the community while addressing potential impacts over the life of the permit," Palter said in a statement that Stanford released just after the report was issued.