Stanford University pushed back this week against Santa Clara County's proposed housing requirements as part of the university's ambitious campus-expansion application by arguing that the university deserves credit for graduate housing already under construction.

In a letter that Stanford staff submitted to the county on Tuesday, administrators pointed to the 1,300 units for graduate students that it plans to open at its new Escondido Village next year and the 215 units it plans to build at Middle Plaza, a development in Menlo Park. These projects, the university is arguing, should be counted toward satisfying some of the county's demands for new housing as part of Stanford's new general use permit.

In addition, Stanford is opposing the county's proposed changes to the long-standing "no net new commutes" policy. The county is recommending the new policy also take into account reverse commutes and automobile trips throughout the day, in contrast to the current policy that only measures traffic volumes during peak morning and afternoon commute hours.

The topic of housing has become the biggest sticking point between Stanford and the county, which is now reviewing Stanford's application for the general use permit. The university wants permission to construct 2.275 million square feet of academic space, 2,600 student beds, 550 housing units for faculty and staff and 40,000 square feet of child care space and other supporting facilities.

The county planning staff has requested that Stanford provide an additional 1,622 housing units for faculty and staff, for a minimum of 2,172 units. The new housing number is included in the conditions of approval that staff released last month and that the county Planning Commission is currently reviewing. Its next meeting is scheduled for Thursday afternoon in San Jose, at 70 W. Hedding St.

In its letter, Stanford is proposing to change these conditions to dramatically alter the requirement for new housing.

Specifically, Stanford is requesting a credit of 650 units from the Escondido Village project, which is devoted to graduate students. The new development, Stanford maintains, will allow about 2,000 graduate students to move out of the surrounding community and onto campus in 2020, freeing up community-based housing.

"Opening Escondido Village Graduate Residents will increase off-campus housing that could be utilized by workforce in the surrounding communities," the university's Associate Vice President Catherine Palter wrote in the June 11 letter.

The letter makes the case that the county should seek to encourage housing construction on all of its residential lands, rather than place the burden on Stanford. The university, Palter wrote, did not cause the region's housing shortage. Stanford recommends that the county revise its zoning code to increase permitted residential densities, reduce cost burdens associated with housing construction and create an "efficient, predictable approval process" for housing already zoned for residential development.

"These actions would encourage the development of housing that is so needed throughout the region," the letter states. "Without them, the same impediments to housing development that contributed to the region's housing crisis will continue."

Stanford is also firing back against the notion that an employer should provide housing for every person it employs. That notion is the basis for the county's proposed requirement to accommodate the more than 9,000 students and faculty members who would be added to the campus by 2035 under Stanford's proposed expansion. While it is consistent with county Supervisor Joe Simitian's position that Stanford should be required to provide "full mitigation" for its expansion, Palter argued that — taken to the extreme — the policy "conjures up failed company towns and may be at odds with the longstanding and deep-rooted constitutional principle to foster and protect labor mobility."

"Losing a place of residence at the same time a person changes their employment could create an impediment to mobility," Palter wrote.

She also underscored Stanford's commitment to address the housing shortage, in recognition of the region's urgent need for more workforce housing.

"Stanford understands we are in extraordinary times that require extraordinary thinking," Palter wrote. "We also recognize that Stanford has land resources that could be made available for housing. That is why, with some important adjustments to the conditions of approval, Stanford is willing to rise to the challenge and take a leadership role by embracing the opportunity to build more housing."

While Stanford says it is willing to meet the proposed condition for at least 2,172 units of workforce housing, it is requesting changes in how these units are counted as well as more flexibility when it comes to the location of housing and mitigations for traffic impacts. Palter noted in the letter that the Escondido Village and Middle Plaza projects, which were approved before the general use-permit application was filed, signify the urgency that the university felt in solving the housing needs of its graduate students.

"It would make no sense to the university if Stanford's accelerated delivery of these units is effectively punished by imposing new housing requirements that do not recognize this early housing," Palter wrote.

Stanford is also requesting that the county reconsider its proposed condition that at least 70% of the new units be constructed on campus (the remaining should be built within 6 miles of the campus, unless county planners grant an exception). Rather, the university is requesting that the 70% requirement apply to an area within 6 miles of the campus, or along transit corridors.

Many workers, the letter argues, would rather not live on campus.

"Many prefer to remain in their existing communities when they change jobs, or to live near relatives, friends, a place of worship, an ethnic or cultural center, a school, or in an urban center or rural setting," the letter states. "Many Stanford employees prefer to live closer to another household member's workplace or want to ensure separation between work and personal life. And most of our workforce prefer to live in single-family homes. In addition, many employees prefer that their employer not also serve as their landlord."

County planners, meanwhile, note that their proposed conditions of approval already give Stanford plenty of flexibility when it comes to housing, both by allowing up to 30% of the housing to be off-campus and by allowing Stanford to pay fees instead of actually building housing. Geoff Bradley, the county's project manager for the Stanford permit process, said at a May 30 meeting of the county Planning Commission that of the 933 below-market-rate housing that Stanford would be required to build, 560 can be satisfied through paying a fee.

The county acknowledged that the additional housing will create some problems, including traffic. Even so, the requirement is intended to "ensure that Stanford fully addresses housing demand from construction of an additional 3.5 million square feet of development.

"If the county does not require Stanford to provide sufficient housing to address housing demand, ongoing development at Stanford would exacerbate the housing-affordability crisis that acutely impacts the areas around the University," a report from Deputy County Executive Sylvia Gallegos and Planning Director Jacqueline R. Onciano states.

Stanford, for its part, argues that the county's direction to nearly quadruple the proposed new housing units without expecting a commensurate increase in reverse-commute traffic or all-day vehicle counts is unreasonable and unachievable. The cap on reverse commute-direction trips will "prevent Stanford from building more workforce housing on its academic campus." Ultimately, the letter states, no one will benefit.

The university is also "not willing to accept a condition that requires mitigation for all-day trips."

"Like the (county) administration's proposed reverse commute-direction trip cap, this cap will prevent Stanford from constructing more workforce housing on its campus," Palter wrote. "This cap also will have the unintended consequence of preventing Stanford from expanding the many programs that it offers to the surrounding community — concerts, dance and theater performances, museums, sporting events, lecture series, and other special events."

It will now be up to the county's Planning Commission to weigh the merits of Stanford's arguments against the recommendations of county planners and consultants. The commission is scheduled to hold two hearings on the application this month before it forwards its recommendation to the Board of Supervisors for final review.

IF YOU'RE GOING

The June 13 county Planning Commission meeting will be held at 1:30 p.m. in the Issac Newton Senter Auditorium at the County Government Center at 70 W. Hedding St., San Jose. Another hearing will be held on June 27 at the same time and in the same location.

Related content:

• Santa Clara County Supervisor Joe Simitian sits down with Weekly staff to discuss the key areas of contention around Stanford University's proposed expansion on "Behind the Headlines." Listen to the discussion now on our YouTube channel and new podcast.

• Guest Opinion: I feel sorry for Stanford University