MbPT: Suggestions & Objections on the Proposed Draft DP

A large land parcel in the island city i.e. the Mumbai Port Trust land, will be opened for development in the coming years. It is imperative that the MCGM takes cognizance of planning in this area.

1. Large scale developments must be provisioned for in the DP. Infrastructure provided by the MCGM must be in sync with any large infrastructural development.

2. Exclusion of slum settlements on Mumbai Port Trust land has gone unnoticed and unmentioned so far. These settlements are mainly across E, F-South and F-north wards. They are places of work and residence to a large number of those engaged in ancillary informal industries. Unfortunately this DP has not taken any cognisance of these settlements. We demand that these areas be mapped and these lands be reserved as “public housing.”

3. The MCGM is the planning authority and must plan for all areas within its jurisdiction. No Special Planning Authority must be made for the MbPT

4. The PLU marks most land as industrial with a few amenity reservations and an FSI as high as 5 in some areas. A detailed land use plan for the MbPT must be made, and these lands must be planned for based on the needs of each of the adminstrative wards of which it is a part.

5. slum residents residing on MbPT land are bereft of basic amenities. It is responsibility of BMC to make provisions for these amenities. BMC should take a serious note of this and should bring them in the ambit of planning.

6. The MbPT can be planned as an area for comprehensive development, provided it is planned for right away and not put away for later.

7. Large vacant plots in the MbPT must be reserved for public housing, and walk up apartments or shell and service housing must be built by the MCGM. Much of this new housing stock can be rented out to residents or handed over to dweller cooperatives. If 45% or (approximately 195 Ha) of newly available land is used as residential for public housing, it is possible to create 75,000 housing units at 30 sqm and 20,000 units at 40 sqm, using a fine-grained mixed-use low rise development with 5 storey walk ups and residential level open spaces, consuming not more than 2 FSI. The entire ground storey of this development can be used for retail shops, small workshops, pre-primary schools, dispensaries, reading rooms, community centres, etc.

8. Health, educational and socio-cultural infrastructure that is accessible to all residents of the city must be created in the MbPT. Basic health and education on the lines mentioned earlier in this letter must be the focus.

9. Adequate open spaces at the residential layout level must be provided in MbPT. The water front could be opened up to the city and provide much needed recreational infrastructure to the city.

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.

Environment and Open Spaces: Suggestions & Objections on the Proposed Draft DP

1. All natural areas like, Mangroves, Mud flats, Salt pans, hills and forest lands should be zoned as natural areas and no construction or infrastructure activities should be permitted on these lands.

2 Special regulations (DCR) for the protection of natural assets and ecological features such as beaches, water bodies, hills, forests need to be incorporated in the DP specifying the nature of activities and type of development permissible in these areas.

3. All Water bodies such as ponds, creeks, streams, Lakes, River, Nalas, bays and estuaries should be demarcated as natural areas in the development plan. Existing open spaces on the sides of water body must strictly be reserved as public open spaces.

4. All existing Natural areas which were demarcated as no development Zones in the development Plan of 1991 should be protected and designated as natural areas in the proposed land use plan.

5. The draft Development Plan 2034 looks at Aarey Milk Colony Lands as an opportunity for creating large scale public infrastructure for the city, with proposed institutions and other uses. A large part of Aarey has been reserved as an open space in the PLU map and uses such as themeparks, recreational grounds, sports grounds and a zoo have been proposed here. We object to these proposed landuses and suggest that all natural areas and open spaces within aarey, which include hillocks, forests, plantations, groves, grassy meadows and farms should be retained and protected. The entire area of Aarey should be demarcated as a natural area in the PLU maps and only certain uses such as adivasipadas or primary activities should be permitted here. No large scale construction or infrastructure should be permitted on these lands.

6. 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.

7. Mumbai’s Coastline consists of various natural features such as rocky headlands, sandy bays and estuaries which support diverse ecological habitats. The natural diversity of the coastline should be maintained by protecting these as natural features. All beaches should be demarcated as a landuse category under natural areas and not under open spaces as has been presently done.

8. Beaches are natural features of the coast and should not be reclaimed for construction of roads and open space or subjected to intensive beautification and construction activity. No new roads should be proposed on rocky and sandy beaches. No construction activity including landscaping or the construction of promenades should be permitted on beaches or in other natural areas.

9. Reclamation in mangroves, estuaries and the sea should not be permitted. Dumping of rocks, tetra-pods and construction of concrete walls and land filling in rivers, creeks, lakes, ponds, nullah’s and seas should be strictly prohibited.

10. The Coastal Road which connects Nariman point to Kandivli in the suburbs and has been shown on the PLU maps will have severe ecological and social impacts and will be disastrous livelihoods of coastal communities. This project threatens to in large stretches cut off the city from the sea, erase and obliterate natural features, destroy coastal ecology, cut off historic sites from the sea, reduce the size of bays, result in the loss of diversity and public access to Mumbai’s waterfront. We strongly object to this project as it threatens destroy what is left of Mumbai’s ecology.

11. Reclamation of beaches and in the sea has been proposed for the construction of the coastal road. These reclaimed areas have been demarcated on PLU maps as open spaces. There should be no open space reservations in areas in areas below the high tide level, or along rocky and sandy beaches.

12. All existing mangrove areas are designated as CRZ I should be protected. No construction activity within mangroves, including the construction of stilt roads should be permitted. Mitigation measures such as Compensatory afforestation cannot compensate for the destruction of these existing natural habitats.

13. Reclamation on the seaward side of fishing villages or areas having primary activities which will cut off access from the sea is a threat to the coastal commons and ancillary activities of the fishing community. The natural shoreline and slope of the beach especially on the seaward side of fishing villages which is often used for the parking or docking of boats should be maintained. This kind of reclamation as is seen near Khar Danda koliwada should not be permitted.

14. No new roads should be proposed on the seaward side of existing fishing settlements.

15. No stilt roads or freeways should be proposed over fish drying areas or areas designated for fish drying or primary activities.

16. Areas in Greater Mumbai such as the Gorai, Manori region, backbay or the portlands have been designated as special planning areas and MCGM has not mapped existing landuses in these areas. These areas which are a part of Greater Mumbai should be planned by the MCGM and existing natural features in these areas should be shown in the PLU map.

17. The Coastal road which connects Versova to the Madh-Marvey coastal belt will act as a trigger for speculative development and destruction of natural areas, such as hillocks, wetlands, plantations in this region. We object to this link as well as to the road widening of the Madh Marvey road to 27m. This will result in all the traffic from the coastal road being diverted to this area opening it up for real estate development and destroying the local ecology in this region.

18. No development zones in the Mud-Marve area have been opened up for development and have been zoned as Residential-Commercial zone. These include natural areas such as hillocks, plantations, salt pans, farmlands and coastal commons. The F.S.I in these areas has been increased to 2 which will destroy the fragile ecology of this area. These natural areas should be demarcated and protected in the proposed land use maps.

19. The Indiscriminate proposed widening of roads or the construction of new roads and freeways shown in the proposed land use plan will lead to bottlenecks and increase in congestion in neighbouring areas and should be avoided.

20. Instead of large freeways for private transport using public expenditure this there is a need to invest in upgradation of existing Public transport, especially Bus Rapid Transport and the suburban train network. The investments being made on new roads are disproportionate and will benefit only a few. The MCGM should instead invest in increasing the frequency and improving the quality of suburban train services.

21. The M.C.G.M. needs to plan and invest in better public transportation networks with emphasis on promotion of comfortable Public transport and higher investment in this sector. Further, the Singapore model for private road transport needs to be followed by restricting registration of private vehicles and adopting cordon pricing.

22. Instead of demarcating NDZ’s as open spaces or reclaiming new roads for open spaces MCGM should propose measures to improve access and quality of existing open spaces. There is no need to reclaim new land from the sea to create more open space. There are many existing open spaces in the city which do not have public access. These could be made more inclusive and accessible to all sections of the population and all income groups bridge the present shortfall.

23. There should be a provision of a hierarchy of open spaces which are integrated within existing neighbourhoods to ensure public use access and safety. Creation of new open spaces such as Bandra reclamation which are spatially isolated from surrounding residential neighbourhoods separated from them by highways or freeways have not proved to be successful

24. Heritage Sites and Heritage Precincts which include open spaces and natural heritage sites should be be marked on the DP maps.

25. There should be special DCR’s to protect and preserve existing tree cover and trees within both private and public properties. A treec count and mapping of existing trees should be undertaken by the relevant authorities to make it possible to enforce this.

26. There should be special guidelines or DCR’s specifying not only the number but also the type of trees and percentage of tree cover in new developments, open spaces and along roads. Guidelines for urban greening should be formulated and there should be an emphasis on promoting indigenous trees that will benefit the environment, improve urban biodiversity and serve as habitats.

27. Water harvesting systems should be made compulsory in every building: commercial, residential or institutional and public spaces to reduce runoff and the load on clogged and overloaded storm water drains. If implemented, this will reduce problems such as flooding. Guidelines and DCR’ s for water harvesting at every building level and plot level need to be formulated which will include reducing the percentage of hard paved area within plots and incorporating interventions to enable ground water recharge and reuse of ground water within plots.

28. Provision should be made in the D.P for decentralized filtration systems or reed beds to purify waste water and storm water in nallahs.

29. The D.P should also incorporate DCR’s for grey water recycling and reuse for gardening and other purposes especially for commercial and institutional buildings.

30. The Development Plan 2034 has considered only risk of flooding under Climate Change risks. Impacts of climate change should include all the factors like Sea level rise, Rainfall, increase in Temperature, extreme climatic events, earthquakes, etc. All new proposed projects must factor impacts of climate change in their study. 

31. Risk assessment for city: We suggest MCGM undertake Risk assessments and Pollution assessment for the entire city before sanctioning new projects.

32. Garbage disposal management: Currently, Greater Mumbai’s environmental health is severely compromised due to increasing air pollution largely caused by vehicular pollution; increasing water pollution due to inadequate sewerage system and industrial pollution along with non-segregated garbage and plastic waste clogging drainage systems. Inadequate and poorly managed landfill sites are yet another cause of environmental pollution. The MCGM must discontinue the dumping of garbage on mangroves and mudflats and ensure that garbage is separated at source.

33. Mandatory water recycling and reuse: We depend on monsoon for water supply. There is no policy for recycling and reuse. Water recycling and reuse should be made mandatory for existing and new buildings. 

34. We suggest that the MCGM examines the “Carrying Capacity” of the city before sanctioning large infrastructure and development projects

35. We suggest that the HTL, LTL, 200 metre line, 500 metre line and the Hazard Line be marked on the DP maps.

36. We suggest that the silent zones be marked on the DP maps.

37. In view of the alarmingly high air pollution levels that our city has been witnessing lately, it is imperative to ensure that the new constructions do not adversely affect the air movements within the city. This parameter should be considered whilst approving new constructions.

38. It will be important to study these models and try to incorporate them in our effort to plan decentralized waste management systems at locality and ward level to reduce the load on landfills and the environment. We recommend that reservations for decentralized composting areas, urban agriculture and farms be incorporated in the D.P. In existing open spaces in the city, an area can be designated specifically for this purpose. Urban farms and agricultural landscapes in the city have a productive, environmental as well as recreational value as opposed to resource intensive ornamental landscapes that are commonly seen in public gardens which usually have no other value apart from being aesthetic.

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.