Notes On The Draft Development Plan Summary (23rd February 2015)

After multiple delays in the revision of the Mumbai Development Plan (2014-2034) and an official two year extension granted in October 2014 – the draft Development Plan (DP) was presented to the Mayor and group leaders last week. While MCGM officials maintain that the draft DP has not been made public, unofficial versions of the summary and draft DP have been widely reported on by the media.

Hamara Shehar Vikas Niyojan Abhiyaan, the city wide campaign of NGOs, academic and other institutions, CBOs, unions and communities has, over three years, advocated for a participatory approach to urban planning that takes into consideration the fundamental needs of Mumbai’s majority and a people-centric approach to the city’s biggest challenges. The Campaign has played an active role at various stages of the DP preparation. It was active in the extensive corrections made to the Existing Land Use Plan (made public in 2012); it developed and submitted to the MCGM a ’People’s Vision Document’ that highlights fundamental issues in the city from a people’s perspective; it hosted a majority of the MCGM-initiated sectoral consultations through institutions involved in the campaign; the campaign was also active in garnering participation at the ward level consultations. It has also submitted to the MCGM a ‘People’s Plan for Malvani’ drafted by Kamla Raheja Vidyanidhi Institute of Architecture (KRVIA) and Youth for Unity and Voluntary Action (YUVA) – a model local area plan that aims to achieve comfortable living and working conditions, sufficient amenities and social infrastructure in high density low income settlements.

The campaign met on Thursday evening at Bhupesh Gupta Bhavan in Prabhadevi to discuss the way forward. The issues discussed at the meeting included – the proposed variable FSI & TOD and what it meant for the city’s working people, removal of no development Zone reservations, and Aarey Colony being seen as opportunity for an emerging growth centre, inclusion of the the coastal road into the plan, and multiple issues that will directly affect the liveability of the city for the next 20 years.

Some of the main observations regarding the shortfalls and contradictions in the DP 2034 which emerged through this discussion are as follows:

A] No Social Goals or Objectives

1. Undermining the efficacy of “prescriptive” and “deterministic” tools such as reserving lands for public purpose, the DP 2034 makes a drastic paradigm shift and the entire the entire Development Plan framework is focused on allowing “the market to operate in a competitive manner” assuming
that the market is the best determinant and guide to the needs and priorities of the city.

2. The DP does not identify any clear social goals or objectives, and as market-oriented plan, it turns to the private sector even to fulfil public ends.

3. Planning for development ought to be one small component of a larger program to achieve
social and human development. The DP holds a very narrow view of development, equating it with economic and physical growth and modernisation.

4. The DP’s vision talks about making a “competitive, inclusive and sustainable city,” there is hardly anything in the proposals that might help achieve the last two objectives.

B] Facilitating Production as Opposed to Encouraging Redistribution

5. By switching to a “non-restrictive regulatory regime” through a relaxation of FSI
norms, the DP envisions a city-level urban renewal and redevelopment that will
be have extremely disruptive effects.

6. Setting up an FSI regime is supposed to remove “artificial scarcity,” thus overcoming the problem of un-affordability. Presently, there are about 4.79 lakh vacant houses in the city – which means that homes are unaffordable despite there being surplus built up space.

7. The DP falsely assumes that just by producing more built up space, the problem of disparities
will be addressed. Higher FSI may produce more space, but it will hardly produce more affordable space.

8. The DP thus fails to adopt up-gradation and improvements as a way to secure affordable housing
for slums and inner city areas. Instead, it continues the policy of stuffing the poor in high rises through redevelopment and renewal.

9. The DP does not seek to understand the relationship between built form types and affordability.
It focusses on the amount of space created as opposed to the kind of space created. This is flawed methodology for creating humane affordable homes.

10. The DP does not reserve land for public housing (except for rehabilitation) and does not
consider public means for providing good quality homes. One of the central tasks of public policy is to find progressive means to remove disparities – the DP envisages no such role for itself.

11. The only way affordable space may be found is if less space is consumed per person (high
densities) or if space in low value areas are sought (urban peripheries). The poor will be pushed closer together, or away from the city. In other words, overcrowding or gentrification, or a combination of both.

12. The 10% inclusionary housing is inherently iniquitous – small tenements built through redevelopment in a city where the average house size will be close to 1200 sq ft, are imagined more as servant quarters than respectable homes for the working poor.

C] Methodological contradictions

13. There is a good bit of work by well known planners that suggest that an indiscriminate increase in FSI will result in a) high population densities and overcrowding; b) hence reduce the per capita access to amenities; c) as well as overloading physical infrastructure.

14. However, increase in FSI has variable effects – in richer areas it tends to increase per capita space consumption, while in poorer areas it tends to increase densities. This means that a high FSI policy without protections will most certainly result in increasing disparities.

15. The preparatory studies as well as the DP Summary insists that there is “little correlation between FSI and densities.” Despite this claim, it provides high FSI in transit nodes under Transit Oriented Development (TOD), expecting them to develop into high-density areas. What explains this contradiction?

16. The DP chooses different set of benchmarks and planning norms for different kinds of uses – for residential use, the DP hopes to achieve 27 sqm per capita built up space (Mumbai average is about 9 sqm), that is 3 times what the National Habitat Policy prescribes as minimum. For commercial and industrial uses, it uses the UDPFI guidelines that suggest 11-12 sqm per capita space. For transport, it decides that Delhi (a car centric city) norms of 18% land area for transport at the ward level is suitable for Mumbai. However, for health and education we are told, it is “pragmatic” to use the 1991 Mumbai DP norms, as any other norms (such as UDPFI or NBCI) would be unrealistic. This means that we have to be “pragmatic” about basic needs such as public health and education, but indulgent in our efforts to promote private gain.

D] Facilitating Private Activity, Undermining the Public Realm

17.High FSI values will incentivize plot amalgamation in order to consume all the permissible FSI. This will mean two things: many of the fine-grained old precincts and neighbourhoods that are run-down support systems for millions of people would be completely obliterated in favour of large footprint developments.

18. Secondly, large plot re-development through amalgamation requires big capital and big investments; the FSI regime would place large firms at an advantage over smaller ones, and eventually the real-estate industry will be dominated by a few big firms.

19. The DP links the creation of smaller amenities to these larger developments. Which means that,
if for whatever reason, the area does not undergo re-development, it cannot have local level amenities, even if these are in short supply. The creation of amenities is no longer a matter of right to be provided by public action, but contingent upon redevelopment led by private enterprise.

20. Despite extensive discussions in the stakeholder consultations, where the MCGM was repeatedly informed about the multiple economic and social barriers that restrict access to social infrastructure, the DP still understands access to amenities only as physical distance.

21. The fact that the DP can claim the medical amenities are sufficient itself is shocking, considering the scandalous state of public healthcare in the city. Furthermore, it calculates both public and private health and educational infrastructure as though they are equally accessible to every resident of this city, which is obviously false.

22. On one hand the DP 2034 acknowledges the important role of environmental features and states the preservation of natural areas including forests and mangroves to prevent their further deterioration as being one of the major objectives; on the other hand it perceives public lands and NDZ’s such as Aarey as the only spatial option for “capturing new economic impulses” for “catalyzing development.”

E] No Participatory Planning

23. Though the MCGM helped organise the stakeholder consultations, very little of the suggestions seemed to have informed the DP. However, the stakeholder consultations were themselves quite limited as a participatory process – the MCGM did not set up and carry out a detailed bottom up process for arriving at a larger plan for the development of the city.

24. One of the serious criticisms during the stakeholder consultations was the fact that the
electoral wards do not correspond to the planning sector boundaries. How will participation work at the planning sector level?

25. About 10% of the area of the city falls under Special Planning Authorities (SPAs) that is not
planned by the MCGM. How can a city be planned with various authorities nibbling of parts of the city and making plans for them in isolation? How does it facilitate democratic control over the planning process?

Academics, activists and citizens engaged in the Mumbai DP Campaign fear that the general principles, approach and paradigm shift described  and enunciated in the executive summary of DP
2034 tend to undermine most of recommendations and demands- an outcome of an extensive public consultation process that the MCGM undertook earlier last year. The participatory process initiated by the MCGM and people’s demands that have been voiced through the process cannot be silenced at the final stage, only to benefit a minority of builders and corporations in the city. The extensive efforts of the campaign over nearly 3 years in bringing to public debate the needs of multiple groups in the Mumbai DP will continue. The campaign has in the pipeline workshops for a detailed sectorwise analysis and understanding of the draft DP, ward/community level meetings and mobilization across the city.

This is the Mumbai DP Campaigns initial response which challenges the DP on fundamental grounds. Detailed responses to important issues in the city (slums, housing, environment etc) will be made available over the coming weeks after the final DP has been published. Given the multiple issues the draft DP has ignored, the 60 day period for suggestions/objection to the draft DP (slated to begin next month) is bound to meet with much opposition.