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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Slum Habitats: Suggestions & Objections on the Proposed Draft DP

After looking closely at the approach adopted and proposals made in the Draft Development plan for Mumbai, we are shocked and disappointed that the Plan has found no means to ensure that we find a humane living environment and home for ourselves in this city. This despite the repeated suggestions put forth at multiple consultations with the MCGM. We strongly object to the approach of this Plan of awarding development rights to developers as an incentive to produce housing units. We demand a fundamental shift in the way our habitat is conceived in this city, as a place that offers the possibilities for livelihood, growth and improvement, health and education, and creative well-being; and we demand the Plan to be based on this conception. Since the present redevelopment approach has been counterproductive in the creation of such a habitat, here are our bare minimum requirements for this Development Plan:

1. All lands currently mapped as “slums” in the ELU must be reserved as “public housing”

2. The DP must use population data provided by the ICDS or health post data to get a more accurate count of the number of slum households in the city.

3. Incentive FSI to developers for the rehabilitation of slum dwellers must be discontinued.

4. A slum improvement and upgradation program must be set up for all slums. Provision of basic services and social infrastructure in slums must be undertaken by the MCGM.

5. Development Control Regulations (DCRs) for slum upgradation must be made – to ensure mixed uses and adequate environmental conditions.
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