Points specific to koliwadas and gaothans
1. The proposed land use plan in the draft DP does not show boundaries of urban villages i.e gaothans and koliwadas. We recommend that boundaries of gaothans and koliwadas be demarcated in the Proposed Land Use Maps as this will ensure the protection of these settlements.
2. Gaothans and Koliwadas have been zoned as either commercial/residential (C/R) zone or residential/commercial (R/C) zone in the proposed landuse maps. We suggest that Gaothan areas be zoned as “Urban villages” in the Proposed Land Use Map after boundary demarcation.
3. Historical place names of Gaothans and Koliwadas should be retained and mentioned in the proposed development plan to preserve local, memories, associations and to safeguard the historical value of these settlements.
4. Road widening within gaothans and koliwadas threatens to disrupt the existing settlements and destroy the pedestrian nature of these areas and should not be proposed without consultation with local communities and only in cases where it is considered necessary by them.
5. As per DCR 26.2, for the development of any property in gaothans/koliwada areas on plots fronting road width 9.00m and above the permissible development shall be in accordance with the Zonal Permissible FSI. We object to this DCR. Zonal F.S.I should not apply to the gaothans and only DCR’s for gaothans and koliwadas should be applicable to urban villages.
6. The DP must formulate Special Development Control Regulations (DCRs) form based and place based codes for conservation, improvement, repair, restoration and upgradation of urban villages. These should include appropriate height restrictions and building form controls.
7. Special DCR’s to protect and preserve the unique urban form of urban villages should be formulated at this stage of planning itself as opposed to being left to next tier i.e the local area plans as this will take too long and the process is quite ambiguous.
8. There should be DCR’s to control and regulate commercial landuses within predominantly residential gaothans. Only certain kinds of commercial activities which are compatible with these areas may be permitted and only in certain areas which already have commercial uses.
9. Repair and reconstruction should be encouraged as opposed to redevelopment by making approval processes and permissions for self-development, improvement, repair or renovation of gaothan homes, simple and quick. Permissions need not be required for the undertaking of basic repairs or maintenance such as plastering or water proofing.
10. Building heights of structures around gaothans must be restricted to ensure adequate light and ventilation for goathan homes.
11. Existing paths, streets, community spaces, natural resources, ponds, wells, markets and other public amenities within gaothans and koliwadas should be demarcated in proposed land use maps to protect them and safeguard village commons, community access and right of way.
12. Vacant lands near urban villages, should be reserved for amenities like markets, playgrounds, schools, dispensaries for residents of gaothans and koliwadas.
13. Urban villages such as Fishing villages and Gaothans should not be included in SPA (Special Planning Area)
Points specific to heritage gaothans
14. The draft DP does not include several measures proposed by the Heritage Conservation Committee for the protection of heritage structures such as a rebate in property tax, adaptive reuse, grant of transfer of development rights. These should be incorporated in the development plan to ensure preservation of heritage buildings and precincts.
15. Currently only a TDR equivalent to base FSI minus consumed FSI is being offered for heritage propoerties. This is, in most cases, zero. . Monetary and other incentives such as TDR must be provided to goathan residents for preserving heritage structures and for the repair and maintenance of these buildings.
16. Boundaries of several gaothans which have been proposed as heritage precincts in the sanctioned/ draft list have not been demarcated on the Proposed Land Use Maps. All sanctioned heritage sites should be shown as such in the draft development plan.
17. Locations of roadside crosses that are a part of the built heritage of gaothans must be mapped, and shown as heritage .
Points specific to koliwadas
18. Existing Landing centres and Jetties in coastal fishing villages(koliwadas) have not been shown on proposed land use maps. These should be mapped as a separate land use category or as areas with primary activities.
19. In many cases areas which are used for primary activities have not been shown on proposed land use maps. All areas used by fishers for fishing and livelihood related activities should be clearly demarcated on PLU( Proposed Land Use maps)
20. New reservations for fishing and livelihood related infrastructure in accordance with recommendations submitted by local communities should be made on proposed land use maps.
21. All areas with mangroves, wetlands, and mudflats should be reserved as natural areas in the proposed Land Use Plan. No diversion of land use to other uses or activities which involve construction or reclamation should be permitted in these zones.
22. The New Coastal Zone Management Plan for the city of Mumbai which is to be made in accordance with the Coastal Zone Regulation Notification of 2011 is yet to be finalized. We object to the fact that the Development Plan of a coastal city like Mumbai is being finalized without there being an approved and final CZMP in place.
23. All Urban fishing villages/ koliwadas should be demarcated and designated as CRZIII in accordance with the CRZ 2011 notification to protect housing, land and livelihood rights of the fisher community.
24. The draft DP report mentions that the livelihoods of 50,000 Koli fisherfolk are directly dependent on the state of our coastal environment. The proposed coastal oad has been shown in the Proposed Land Use plans in the draft DP. The alignment of coastal road is opposed by the koli community and other coastal communities who will be adversely affected by this proposal.
Points specific to adivasipadas
25. In the Draft DP 2034 the 222 Adivasipadas in the city and 27 adivasipadas in Aarey have not been shown in the proposed Land use maps. Adivasipadas should be mapped and designated on land use maps as urban villages.
26. The area of Aarey has been reserved for recreational use and institutional use in the PLU. Aarey should be reserved as a natural area in the development plan and village boundaries of adivadipadas in Aarey along with areas used for primary activities such as plantation and agriculture in Aarey should be demarcated in the PLU.
27. In the draft development plan an area has been proposed for adivasi resettlements. We object to the displacement or rehabilitaion of adivasipadas. In accordance with the Forest Rights Act 2007, the Adivasi Improvement Act 2008 and the Zameen Adhigrahan Kayda 2013 adivasi lands and resources should be protected and their ownnership/control rights should be given to the adivasi community. Existing locations of the the adivasipadas in Aarey should be retained, and these should not be relocated or resettled in another location.
28. Land used or controlled by adivasi communities for primary activities such as farmlands, plantations, or areas used for cattle rearing should be demarcated as areas used for primary activities in the proposed land use plan.
29. Isolated Adivasipadas such as those located in buffer zones of forests should be protected and conserved and as per special DCR’s formulated for adivasipadas should have a height restriction of G+1.
30. Urbanized adivasipadas should not be considered or declared as slums. They should be designated as urban villages and Development control regulations (DCR’s) applicable to other urban villages such as koliwadas and gaothans should be applicable to these.
31. Special DCR’s should be formulated for the improvement, upgradation and self development of urbanized adivasipadas to cater to future housing needs while improving light and ventilation conditions. These should include appropriate built form controls as well as height restrictions
32. Amenities such as health centre, anganwadi, primary school, toilets, community and cultural centre, parks or maidans provided to other citizens of Mumbai should also be provided for adivasis and reservations for these should be made in vacant land near or adjoining these villages.
33. Existing natural features such as waterbodies, wells, and tanks in and around the adivasipadas should be demarcated on proposed land use maps to ensure their protection.
34. In the Proposed land use plan in the DP Land should be reserved for an adivasi bhavan for the socio-cultural activities of the community.
35. There should be special livelihood related reservations for the adivasi community at the ward level. Existing hawking areas and natural markets used by adivasis should be demarcated on land use maps and new reservations for such hawking areas as per the provisions of the Protection of Livelihoods and Regulation of Street Vending Act, 2014, should be made.
We expect the MCGM to incorporate these suggestions and objections in the Development Plan.