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.

R&R Colonies: Suggestions & Objections on the Proposed Draft DP

A decade has passed since R&R colonies began to grow at an unprecedented rate across the city. Meant for Project Affected Persons (PAPs) of urban infrastructure projects, it is a known fact today that a large percentage of homes in these colonies have been given on lease and many have been sold. Many PAPs who have rented or sold the houses allotted to them, have gone back to living in slums thereby negating the very reason for which the policy was initiated. Nearness to livelihood, schools and other essential services have pulled them back; while lack of services, high cost of living and increased expenses in R&R sites have pushed them away from these colonies. Though the failure of this R&R model implemented by the MMRDA is evident and widely reported, the MCGM draft DP (2014-34) has provisioned land for many more such colonies with many more people to be affected by infrastructure projects. The tussle between the MCGM and MMRDA over the maintenance and service provisioning of R& R colonies is well known. However, since the draft PLU has allocated reservations in many existing R&R colonies we are glad that the MCGM is taking ownership in the development these large colonies. With regards to the draft DP, we suggest the following be incorporated with regard to existing R&R colonies:

1. Existing areas often face overcrowding of basic amenities when hundreds are shifted into an area. The new population influx must be accounted for within the ward through provision of basic amenity reservations. In this regard there has to be provisioning of government educational institutions within each R&R colony in proportion to the population and tenements constructed. Merely provisioning one educational reservation is not enough.

2. There has to be a reservation for a government hospital and health post with each R&R colony.

3. There must be provision of natural markets/ hawking zones within each R&R colony. There has been massive loss of livelihood in case of resettlement and most PAPs find it extremely difficult to sustain livelihoods post resettlement. Hawking within the colony to cater to the needs of residents thus becomes a major livelihood option. A secure livelihood space is thus a necessity.

4. There must be livelihood centres earmarked within each R&R colony. As stated above, livelihood is one of the major concerns of people displaced from their homes. Livelihood regeneration must be an integral part of R&R and a spatial reservation must be made for the same.

5. There must be solid waste sorting sheds. The waste generated from large colonies should be sorted at source – at present the condition of waste management in these colonies is appalling.

6. There has to be adequate provisioning of open spaces. Open spaces must be provisioned with the colony in proportion to the population and tenements constructed.

7. Community spaces must be provided. R&R colonies are places where communities from various parts of the city are made to live together – there is a need to reserve public community spaces to provide for community programmes and festivals.

For proposed R&R:

8. Incentive FSI and TDR that leads to creation of high density R&R housing must be scrapped. Resettlement, if necessary must be provisioned for within a 5 km radius from the original site of habitat.

9. DCRs on light, ventilation, fire safety and space between buildings must not be compromised on within R&R colonies. These compromises have lead to R&R colonies being unsafe, inhabitable spaces. Women’s safety is at stake within these colonies.

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.

Affordable Housing: Suggestions & Objections on the Proposed Draft DP

The Draft Development plan report admits that there is a serious crisis of affordable housing in the city. Despite this, the DP has done away with public housing reservations, except for government staff housing and R&R housing. The DP also fails to assess shortfalls and demand for affordable housing over 20 years. It also fails to evaluate the factors that affect affordability in housing. What follows is our suggestions and objections keeping in mind the question of affordable homes in Mumbai.

1. All lands that are currently occupied by slums must be declared lands reserved for “public housing” and the MCGM must acquire them for the purpose.

2. Self-built housing must be considered a legitimate housing option, and adopted as one of the modes for the production of affordable housing stock in the city

3. Redevelopment of slums based on monetization of land must not be permitted. Self-development on slum land, after being reserved for public housing must be encouraged.

4. Special DCRs for various housing types in the city must be made – chawls, site and services, self-built houses, gaothan houses, inner city fabrics, etc. The ELU mapped some different housing types in the city, but the PLU completely overlooks possibilities of conserving and improving the housing types and precincts in the city – many of which provide affordable habitats. Special DCRs or place based codes must be formulated to protect these.

5. Cap building heights for lands occupied by slums to 15 meters. Development rights awarded as incentives to developers produce un-liveable homes for the poor. 1.5 FSI is sufficent to provide 7.5 sqm per capita for all slum dwellers in the city for live and work. High FSI incentives only make slums areas more dense, and conditions worse.

6. Slums must not be allowed to redevelop to more than 500 dwelling units per hectare. The unit size for tenements created for sale must be capped at 45 sqm. The unit size for rehab must not be less than 30 sqm.

7. Rehabilitation units for slum dwellers must be in walk ups with the ground storey designed for commercial units, small industrial workshops and social infrastructure.

8. In Transit Oriented Development areas, tenement sizes must be limited to 40 sqm and parking must not be permitted. This will ensure affordable housing construction in TOD areas.

9. DCRs for RC and CR must be made such that they clarify how commercial activities may be integrated in residential areas, and vice-versa. Controls over percentage of commercial and residential floor space, the location of commercial activities within residential buildings and the relative sizes of commercial and residential units, etc. could be the basis for regulations.

10. Criteria for implementation and monitoring must be specified. Distribution of new housing stock among various social groups, consumption of existing and new stock, and success or failure of programs – all of these must be set up for 5 year monitoring and evaluation.

11. Vacant housing in the city must be monitored and taxed – and revenue generated must be used for up-gradation and improvement of self-built housing.

12. The 10% inclusionary housing must be increased to 30 % BUA of consumed FSI or 50% of units (which ever is more). considering the disparities, and the proportion of low income population in the city. The units must not be smaller than 30 sqm.

13. About half of the available vacant lands in the city must be reserved for public housing, and homes must be constructed on them by using 50% of land for housing layouts and rest for open spaces and social infrastructure. In the housing layouts, walk-ups with 60% ground coverage can be constructed with the ground storey reserved for workspaces and small amenities. These can also be delivered as ‘shell and service’ units, to be incrementally completed by dwellers.

14. In urban renewal in the inner city, the existing street structure and existing building height line at the street must be preserved (allowing only for maximum three additional storeys with minimum 5 meter offset from the street line). The buildings could be reconstructed as a continuous long building that wraps around the block, without street setbacks, with up to 75% ground coverage permissible.

15. For MHADA layouts, allow for reorganization of the buildings without adding any new apartments – cost of reconstruction can be financed by introducing commercial functions as small shops at the ground level that can be rented out by the society. The rest of the cost can be financed through low-interest loans.

16. The share reserved for mill workers housing should at least be increased to 10 percent instead to proposed 7.5 percent under DCR 11.4. The share between MCGM and Mill workers housing should be equal.

17. We welcome the decisions proposed in the draft development plan mentioned in 5.2 (c) – where the share of MCGM and MHADA under regulation no 11.4 will be as if the entire gross land will be redeveloped. We suggest that this provision should not be deleted in the Final DP.

18. The DP must have special provisions and reservations to create hostels for working men and women and migrants as an housing option for transient populations.

19. In housing projects, make the provision of amenities such as crèches, laundromats, welfare centres, etc. mandatory.

20. DCRs to ensure that inclusionary housing units are integrated within the regular developments, and not as separate blocks, must be made. The number of units must be increased to 50% of the total units produced, and these units must be allotted to applicants and PAPs by lottery, to ensure that neighbourhoods do not get ghettoised.

21. “Public housing” areas must be identified as a social infrastructure reservation, and benchmarks must be created for it. The 1964 DP reserved about 2.2 sqm / capita land for public housing. A minimum benchmark of 2.5 sqm / capita at every planning sector level must be introduced, and measures must be set up for their achievement.

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.

Hamara Shehar Vikas Niyojan’s Letter of Objections and Suggestions


Date: 18th April 2015

The Chief Engineer – Development Plan
5th Floor, Municipal Head Office, Annex Building
Mahapalika Marg, Fort,
Mumbai-400 001

Subject: Suggestion /Objections and Request for Hearing for the Proposed Draft Development Plan for Mumbai 2014-34. No. ChE/32596/DP/GEN/dtd 25.2.2015.

As a collective of more than 50 academic, community based, and non governmental organizations, the Hamara Shehar Vikas Niyojan Abhiyan (HSVN) has engaged with the MCGM over the past few years to help provide constructive criticisms and suggestions to help achieve MCGM’s aims of creating an inclusive, sustainable and competitive city. The collective has organized stakeholder consultations for the MCGM and also presented alternative plans and proposals at every stage in the Development Plan process.

The HSVN welcomes the innovations that the new DP has attempted such as participatory planning at the planning sector level, the introduction of inclusionary zoning for housing, variable FSI norms, identification of areas for comprehensive planning, and MCGM control of land released for public purposes. However, we are disappointed that these ideas have not been fully developed and haven’t been taken far enough to be effective.

Furthermore, there are very serious limitations and problems in the Draft Development Plan as it stands today. Many of these problems are regarding the approach and methodology of the Plan itself, and the following are some of our core concerns:

1. The Development plan is a highly technical document, and it requires careful reading and understanding for people to make suggestions and objections. We demand an extension of this period of suggestions and objections by at least 3 more months for more constructive feedback from the residents of this city.

2. It is also imperative that the MCGM organize ward and city level sector based workshops to facilitate understanding of the DP and invite suggestions and objections to its proposals. The DP report and presentations must be made in English, Hindi and Marathi to ensure that every resident of the city can comprehend and contribute to the process.

3. The plan must formulate clear aims and targets for inclusiveness and sustainability. The absence of such targets is unfortunate, as without them each of these concepts remain empty phrases rather than assessable objectives. A development plan must identify clear social goals for the next 20 years – such as, for example, literacy, healthcare, standard of living, etc; or reduction in carbon footprints, pollution levels, etc; and make the physical development plan one component of this larger development program. In the absence of such an approach, the DP will remain a broad framework for real estate development, and nothing more.

4. The Development Plan has overlooked the needs and concerns of the informal sector in the city. It is surprising how the city government assumes that just by pretending that Mumbai is a fully regulated, formal city, it will eventually become as such. The plan has no provisions for street vendors, naka workers, informal settlements, pavement dwellers and informal manufacturing. The plan does not even begin to formulate some norms or guidelines for these. The DP must attempt to understand and formulate proposals for the informal sector.

5. The development plan has severely diluted norms for social infrastructure and services in the city, while it has made generous allocations for private residential, commercial and transport infrastructure. This is highly objectionable, and the plan must make publicly built and run health, educational, and recreational facilities its primary priority, and do everything possible to provide these based on national norms.

6. The DP has left large areas requiring special care and careful planning out of the process by calling them “areas for local area planning.” Though it is understandable that these areas require comprehensive planning, it is imperative that they are planned at this stage itself, rather than being passed on to a “next level” that may be uncertain and/or unaccountable. Who will make these local area plans, how they will be made and when will they be taken up are questions that find no answer in the DP report. We demand that these areas be planned right away, and the DP not be sanctioned till comprehensive plans are made at this stage itself. Similarly, secoral plans must be made and presented with the DP itself and not left for later.

7. The planning sectors for the Draft DP are based on physical features and do not correspond to electoral ward boundaries. The rationale for this is incomprehensible. One of the key purposes of planning sectors is to enable local level participation, and the most logical arrangement to facilitate this is the electoral ward. Yet the DP does not use these boundaries, but creates new sectors, and it is unclear what the mechanisms for participation will be in these new spatial units. We demand that planning sectors must correspond to electoral wards in the DP.

8. Areas left out of the DP as Special Planning Areas (SPAs) are unacceptable. The MCGM must plan for the enire area under its jurisdiction, and not leave out areas from the DP.

9. For ensuring affordable habitats in the city, we demand that all lands that are currently occupied by slums in the city be declared as areas reserved for “public housing.” These must be acquired by the MCGM from the land owners. Up-gradation and improvement guidelines must be formulated for self-built settlements in the city.

10. Boundaries of all urban villages in the city must be demarcated in the DP and special DCRs must be formulated for the upgradation of urban villages

In the following pages, we have also presented more detailed sector level suggestions and objections to the Development Plan. We expect the MCGM to consider each of these suggestions, and the concerns on which they are based. We also request a personal hearing to ensure a proper understanding of these concerns.

Hamara Shehar Vikas Niyojan
A/4, 495, Sahakar Nagar No.2
Road No.1, Shell Colony, Tilak Nagar (East)
Mumbai – 400 071
+ 91 9619519231 | +91 9833252472 | +91 9819987998

Copy to:

1. Shri. Sitaram Kunte, The Municipal Commissioner MCGM,
Municipal Corporation of Greater Mumbai
Municipal Head Office, Mahapalika Marg
Mumbai-400 001.

2. Shri Yashodhar P. Phanse, Chairman
Municipal Corporation of Greater Mumbai
Municipal Head Office, Mahapalika Marg
Mumbai-400 001

3. Shri. Devendra Fadnavis, Chief Minister,
Government of Maharashtra,
Mantralya, Mumbai – 400032

4. Shri. Swadheen Kshatriya, Chief Secretary, Govt. of Maharashtra
Mantralaya, Mumbai – 400032

5. Shri. Nitin Kareer, Principal Secretary,
Urban Development Department,
Mantralya, Mumbai – 400032

Street Vendors: Suggestions & Objections on the Proposed Draft DP

We propose the following suggestions and objections to the Draft Development Plan keeping in mind the specific needs of street vendors in Mumbai.

1. The Protection of Livelihood and Regulation of Street Vending Act (PLRSV) of 2014 requires the Development Plan to reflect vending zones based on a “plan for street vending” prepared by the local authority.

2. Only few of the existing “natural markets” were mapped by the MCGM in the Existing Land Use (ELU) maps. These maps must be updated to show all “natural markets”

3. The Development Plan report must include data on street vendors based on surveys undertaken by the town vending committee, the MCGM and comparative studies by other organizations.

4. The Development Plan should formulate spatial planning norms as required by the PLRSV, and the method must be explained in the Development Plan report.

5. The spatial planning norms must be based on existing usage patterns and needs. Based on a TISS & YUVA survey, a norm of 2.2 square meters per vendor was suggested to the MCGM during the stakeholder consultations.
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Urban Villages: Suggestions & Objections on the Proposed Draft DP

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.
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