Solid Waste Management: Suggestions & Objections on the Proposed Draft DP

We appreciate the MCGM’s efforts to encourage the process of citizen’s participation. The initial suggestions were mostly built around the process of decentralized waste-management systems and it is evident that the draft rules have taken a notice of that at some places. We also welcome the initiative taken by MCGM to construct ward wise more dry waste centres. MCGM has also advertised for expression of interest for construction of Biogas plants for promotion of decentralised waste management ,however it does not reflect in proposed DP. Therefore we would like to highlight following points again for the inclusion in the final DP Plan.

1. Decentralized Public Biogas Plant: The draft rules talks about enforcing the processing of wet waste at the source by housing societies and individual establishments. However the plan also needs to consider the need to process the wet-waste coming out from Markets, Hotels and other public waste generation Zones. For that on ward/zone level some land need to be reserved for development of large sized Biogas Plants. The underground digesters of plants can also be constructed at existing pumping stations and cemeteries and a processing rooms for processing of wet waste can be constructed reserved at source like markets, malls, space below flyovers etc.

2. Freeing Up Space by Bio-Mining: The city should recover space from the dumping grounds by using Bio-remediation process.

3. Development of Recycling Zone: Mumbai generates almost 8000-10000 Tonnes of waste on a daily basis out of which a considerable percentage is recyclable waste. However we don’t have well planned, organized, efficient and environment friendly recycling zones close to Mumbai. Most of the recyclables is sent outside of the state of Maharashtra for recycling which adds to the transportation cost in turn making recycling of few items economically not feasible. As a city we need to reserve land for such large scale processing zones. We think bio mining of the dumping grounds like Deonar can free-up the unused lands and provide such place.

4. Adherence to source segregation and processing of wet waste at source: The draft DCR rules guides us to NATIONAL BUILDING CODE OF INDIA which mentions at source processing of wet waste and the importance of source segregation. Though this rule has been around for some time, we hardly see compliance to it. The MCGM needs to detail the plans further to ensure that it surely happens. The need for incentivizing (property tax reduction being one suggestion) and fining for non-compliances need to be put in place.

5. Use of Chutes: The draft DCR rules guides us to NATIONAL BUILDING CODE OF INDIA which suggests apartments touse chutes for waste-disposal. This suggestion is unacceptable and very impractical and dangerous for the health of people working in the waste sector .However chutes often add up to the problem as segregation becomes hard to monitor, many items break at the bottom,. Most important is that waste thrown through the chutes get stuck and contaminated and can become serious health hazard to all concerned persons can even pose a fire hazard.

6. Waste-pickers: While the concept of dry-waste sorting centre finds its mention in the rules. Local waste-pickers can benefit out of it as it can give access to storage space and thus access to markets higher up the supply chain.

Gender: Suggestions & Objections on the Proposed Draft DP

One of the social objectives of a development plan must be the creation of a city without discrimination and exploitation, and ensure equitable access to all the opportunities that a city offers to different social groups. Women, like other marginalized groups in the city have culturally and historically had poor access to the resources of the city, and specific needs of this half of its population must be given special attention in the Development Plan. Unfortunately, almost no efforts have been made by the MCGM to understand and frame rules that can ensure an equitable, safe and enabling environment for women in the city. We object therefore to the basic approach of this Plan, and expect the following objections to be addressed and suggestions to be incorporated in the Draft Development Plan.

1. Specific social infrastructure and livelihood areas for women must be included in housing developments, and these must become part of the DCRs. Facilities such as child care centres, crèches, play areas for children, common work areas, food services, reading and recreational areas must be incorporated in the development control rules.

2. All social facilities mentioned above created within housing developments for women must be detached from residential blocks and built as separate units adjoining residential level open spaces. In case of extreme land constraints, an entire ground storey must be dedicated for these purposes.

3. In slum settlements, up-gradation guidelines that protect and promote women’s livelihoods must be provided. Guidelines that ensure the creation of common work areas outside the home must be provided.

4. Residential typologies that support live and work must be built into the guidelines for slum up-gradation and rehabilitation. Residential only typologies make it impossible for women to regulate their own work environments. As mentioned above, ground storeys, or detached blocks must be provided in residential neighbourhoods.

5. Guidelines for the creation of social interaction spaces outside the house must be provided in the DCRs for housing. Porches, katthas and courtyards that support childcare and provide common recreational facilities are a must.

6. Typologies that make for unsafe environments for women must be avoided entirely. Residential high rises with poorly designed lift and corridor spaces make it difficult to ensure women’s safety. Low rise walk up apartment typologies with external stairs and corridors must be promoted.

7. Educational facilities for women must be given importance and reservations for hostels for women and girls must be made in the DP. These must be built and run by the MCGM or approprite public authorities.

8. Facilities for women only night shelters must be built around railway stations and transit nodes, built and run by the MCGM to ensure safe resting places for working women. At least one such facility must be provided in every ward, and one near every major transit node.

9. A network of toilets for women must be provided adequately at walking distances everywhere in the city. These must be built along with changing rooms for women, and DCRs must be formulated to ensure that these are suitably indicated and signages directing to them are provided.

10. For street vendors, separate storage rooms and rest rooms must be provided for men and women. These must be at walking distances from every “natural market” in the city.

11. As per the National Urban Livelihood Mission draft, one livelihood centre is to be provided for every 100,000 people. We recommend the creation of one additional livelihood centre for women to provide, promote and facilitate livelihoods for women. These facilities must have common work areas for self-employed women, recruitment possibilities and other support infrastructure.

12. For Koli women street vendors, street markets must be equipped with platforms and seating, common washing and cleaning areas, waste disposal facility and temporary cold storage facilities.

13. For women waste pickers, waste segregation areas must have near them changing rooms and women’s toilets with clear indications.

14. Street design guidelines must include regulations for illumination to ensure all public access areas are well lit at night. Guidelines must specify type and frequency of street lights.

15. Street vending must be promoted in residential only areas to ensure activity at all times providing ‘eyes on the street,’ that ensure safe streets.

Social Infrastructure: Suggestions & Objections on the Proposed Draft DP

The UDPFI guidelines state that social amenities and infrastructure are “the basic requirement of urban life and its adequacy and accessibility are two important ingredients and key contributors in the upgradation and enrichment of quality of urban life which is the primary objective of an planned development effort.” However, social infrastructure is nowhere close to being the primary objective of the DP. The inadequacy and inaccessibility to health, educational, socio-cultural and recreational facilities and services is perhaps one of the most urgent crisis in the city, and the DP has done little to address this problem. The Social infrastructure norms for health, education and socio-cultural facilities have been set at extremely low levels. In contrast, benchmarks for residential, commercial and transport are generously prescribed to match national norms and global standards. This selective “pragmatism” is of serious concern, and unacceptable.

1. Area norms, quantity norms and distance norms for health, education and socio-cultural facilities must be benchmarked and provided according to UDPFI or NBCI norms (whichever is lower).

2. Innovative methods of sharing open spaces, intensive development of plots and multiple use facilities may be adopted to overcome land constraints and achieve the national benchmarks – provided a clear methodology is formulated, and guidelines and rules to ensure these function as planned are set up.

3. Considering Mumbai’s land constraints, and the availability of a long coastline, public open spaces in Mumbai could be benchmarked lower, but the NBCI norms of 3.0 sqm of open space at the residential cluster level for low income developments must be ensured.

4. Land exaction for public use through redevelopment must be discontinued – land must be acquired for public use through reservations.

5. Accommodation reservations in the form of handing over reserved lands to trusts and private entities, or by providing incentives to land owners to develop the said reservation must be discontinued. Public facilities must be built by the MCGM after acquiring land from the owner.

6. All public facilities for basic health and education must be built and maintained by the MCGM to ensure universal access. Private facilities, if any, must be built in addition to the national norms, not as a substitute for public facilities.

7. According to National Urban Health Mission norms, the city must build another 199 health centres.

8. The MCGM must build an additional 112 maternity hospitals as per NBCI norms (1 per 100,000 persons) after surveying the distribution of the existing 28 to ensure access and adequacy.

9. At least 49 general hospitals must be built in the city as per NBCI, especially in areas where there is poor access to healthcare.

10. The city needs to build and provide access to 1240 more primary and 1600 municipal run secondary schools as per NBCI norms

11. New categories for socio-cultural infrastructure (markets, public libraries, theatres, cultural centres) built and run by the MCGM must introduced with the aim of creating a diverse and secular public sphere, and to address increasing social polarization and ghettoisation in the city.

12. New categories for social infrastructure to address the needs of the informal sector must be introduced. Facilities for street vendors, naka workers, working women, auto and taxi drivers, waste segregation and sorting, etc. must be built to provide infrastructure and regulations.

13. Social infrastructure must be introduced carefully near and within informal settlements to support and facilitate upgradation and improvements. Basic health and education and socio-cultural facilities must be introduced with the participation of residents of self-built communities.

14. Pavements must be categorised as soci-cultural infrastructure and 1/3rd widths of all non-arterial streets must be provided with pavements. Pavements must also be equipped to support informal street vending as per the Street Vendors Act of 2014.

15. Basic social infrastructure (dispensaries, health posts, primary schools, etc) must not be provided by land pooling. These are necessities, and are part of the welfare responsibilities of the state and cannot be left to local contingencies. These must be reserved in the DP and provided.

16. The suburbs are extremely deficient in health infrastructure as compared to the island city. The city level plan must ensure the equitable distribution of these facilities across in different parts of the city.

17. The DP must articulate and declare clear social objectives with respect to healthcare, education and the development of a secular public sphere, identify the physical components for the achievement of such objectives and make provisions for them in the Development Plan.

Preparatory Workshop #1: Physical Infrastructure

The Preparatory Workshop on Physical Infrastructure was held at TISS on Thursday, March 12th. Waste Management in the draft DP, DCRs and PLU was discussed extensively. Jyoti Mhapsekar (SMS) and Debarth&Jayant (Sampurn(e)arth) will be putting together Suggestions/Objections based on today’s discussion by 19th March.

A preliminary discussion on Water was also carried out. A detailed meeting on water is being conducted by Pani Haq Samiti at TISS tomorrow – it will also put together Suggestions/Objections by 19th March.

The Preparatory Workshop on Slum Habitat will be held on Saturday, 14th March (Saturday) 10 am @ APNALAYA, B/9 – 103 New Jaiphalwadi SRA Co-op Hsg Soc, Behind Police Quarters, Tardeo.

The Preparatory Workshop on Adivasipadas / Gaothans / Koliwadas will be held on 15th March (Sunday) 10 am @ APNALAYA, B/9 – 103 New Jaiphalwadi SRA Co-op Hsg Soc, Behind Police Quarters, Tardeo