The Mumbai Development Plan 2014-34, which will affect the lives of 12.5 million residents of Greater Mumbai, has to be an all-encompassing document that protects the interests of the disenfranchised while providing an opportunity to re-imagine the city. While workshops were held with key stakeholders as a part of public consultation on the plan, crucial suggestions on Affordable Housing, Water and Sanitation, Health and Transportation among others have been ignored. The plan is also disconnected from larger issues of sustainability and affordability by not responding to challenges of urban poverty, climate change and heritage conservation therefore excluding a significant percentage of the population and disregarding these urgent concerns.
As a 20 year plan, the DP has long-lasting consequences with implications for an entire generation. We have only till the April 24, 2015 to provide suggestions, objections or comments to the concerned authority. Legal action post the notice period may be dismissed by the court as the MCGM has provided this opportunity for responses and feedback. The time for action is now. And so we request you to browse through the reasons listed below, following which the petition page will provide you with the information on how you can register your suggestions or objections to the appropriate authorities.
As a 20 year plan, the DP has long-lasting consequences with implications for an entire generation. We have only till the April 24, 2015 to provide suggestions, objections or comments to the concerned authority. Legal action post the notice period may be dismissed by the court as the MCGM has provided this opportunity for responses and feedback. The time for action is now. And so we request you to browse through the reasons listed below, following which the petition page will provide you with the information on how you can register your suggestions or objections to the appropriate authorities.
GENERAL PRINCIPLES
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CRITICAL
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AFFORDABLE
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ENVIRONMENT
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URBAN
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WATER & SANITATION
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PROPOSED
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DCR
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AMENITIES |
DIGITAL
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TRANSPORT |
LIVELIHOODS |
OPEN
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GENDER SENSITIVITY |
SPATIAL DEVT. STRATEGY |
SOLID WASTE MNGMT |
GENERAL PRINCIPLES
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- Vision for 2034 DP sees Greater Mumbai as a “Competitive, Inclusive and Sustainable City” although, very little really aims towards enabling the proposed transformations. The Development Plan (DP) is planned as if for the upper and middle class and the issues of the urban poor are totally unaddressed.
- The DP should state clear principles and non-negotiables and make them quantifiable.
- The DP proposal expects to transform Greater Mumbai into a Healthy and Liveable city. However, these expectations seem to have been given a short shrift in the details.
- The Public Consultation that the MCGM have conducted seems to have been only a lip service and nothing more as it had no effect on the proposals made in the DP.
- Issues of cluster development and dilution of standards had been struck down at the ward wise public consultation however the same have continued to exist in the development plan.
- The planning is expected in two tiers; one the broader scale of Development Plan and the second is through the local area plans. However there is no strategy or timeline mentioned for completion of the local area plans.
AMENITIES
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Stakeholder meetings organised by MCGM for Mumbai development Plan conducted in January 2014
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OPEN SPACES
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- In the radar graph assessment, it is mentioned that in Greater Mumbai, availability of open spaces requires the highest level of prioritization. This seems to be just a formal obeisance to the ideal because it is not reflected in the planning proposals.
- The open space standards are proposed to be only 2.0 sqm per person as against the 10.0 sqm per person recommended by the UDPFI. Existing 1.24 per capita open space includes private clubs and gymkhanas which have limited access to general public but are still counted under Open Spaces.
- Moreover, Even Traffic Islands, Intertidal areas of beaches, promenades, private layout RG (Cusrow baug) are included in public open spaces. Natural areas such as Mangroves, Mud Flats, National Parks, Creeks, etc. are clubbed with the available Open Space to meet the standards of UDPFI. This is trickery with number.
- Large urban green inaccessible areas such as Raj Bhawan, Doongarwadi (Tower of silence), JJ Hospital, BARC, TISS, Aarey colony, Film city, KEM Hospital, Nehru Science Centre, AAI receiving station, IIT are proposed to be made accessible and counted under open spaces.
- The layout open space in residential development has been reduced to 10% as against DCR 23 of the DP 1991, which suggests RG of 15% to 25%.
- There is a further diminution of open space available to the public as the parking areas, electric substations, storage of harvested rain water, grey water harvesting plants, sewage treatment plant etc. are permitted below open spaces in residential development. (The DCR 1991 was amended to state that parking spaces and basements are not allowed under reserved Open Space).
- The DP should have a clear strategy to increase Open Spaces Open green spaces must be easily accessible. The health benefits of green spaces are clearly proven, particularly for the lower income groups. There must be at least one small park (between 500 and 1,000 sq. m.) within 500m of every residence, and at least one large park (exceeding 1,000 sq. m.) within 1 km of every residence in the city.
- Aarey Land should not be used for development. The no development zone designation of Aarey should be made further stringent and be marked as protected green area or as open space.
LIVELIHOODS
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- The key economic drivers considered in Employment Projections in proposed Development Plan 2014-34 are financial services, insurance, IT, media & entertainment, retail, logistics & export-oriented manufacturing. “A city that focuses only on service sector i.e. Tertiary Sector of employment it bound to be a city of extremes. Existing share of tertiary sector is 68% of the total NDDP of Mumbai”. This invariably will split city into ‘haves’ and ‘have-nots’. Recognize all patterns and types of livelihoods and provide basic services like toilets and facilities for Naka workers and construction workers, segregation centres for rag pickers and clearly demarcated hawking zones for street vendors, community spaces for home based industries, night shelters for women and street children etc.
- The DP should allocate land for medium scale non-polluting manufacturing centres in Mumbai. The large amount of territory sector share in economy of Mumbai clearly shows the need of developing secondary sector like small manufacturing industries and entrepreneurship zones etc. ·
- Create open innovation clusters within informal neighbourhoods as special livelihood innovation zones. These special livelihood zones shall be accorded the benefits made available to Special Economic Zones or Special Industrial Areas.
- Plan spaces for the concerned agency to set up comprehensive skill up-gradation in informal settlements.
- It is estimated that employment for Greater Mumbai would range between 6.25 and 7.35 million, with unaffordable rents of commercial spaces the majority of the employment will come through informal sector.
- There is no consideration of informal sector economy (constituting 70%) in the draft DP. Even when the Hon’ble Supreme Court Judgement of 9th December 2003 permits 3 to 4% hawkers in hawking zone in terms of the The Street Vendors Act, 2014 (protection of livelihood and regulation of street vending).
- No clear provision or policies for:
- Road Hawkers
- Weekly Markets
- Small manufacturing industries
- Medium scale non-polluting
- Entrepreneurship zones
AFFORDABLE HOUSING
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- The household size of Mumbai has reduced from 4.9 to 4.5 persons per household i.e. smaller families, which is a general urbanizing trend. However this number has been used to virtually justify the need for rise in FSI, and the increase in car ownership.
- Average per capita consumption of 27 sq.m. has no rationale. In calculating space demand the National Habitat Policy has aimed at min 25 sq.m. carpet area per household (35 sq.m. built up area) which should be 30 sq.m. adding 20% of Built up. Hence for a household size 4.5, per capita carpet area will be 6.67 sq.m. instead of 7.8 sq.m. The proposed land use demand for built up area leads to higher mean FSI which resulted in irrational FSI distribution of 8, 6.5, 5 & 3.5.
- The increase of almost 400% of BUA in city is objectionable considering provided amenities and infrastructure.
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- Inclusionary housing policy stipulates 20% of land for housing for EWS housing in DP 1991 however the proposed Development Plan has reduced the percentage to 10%. It also provides that plots bigger than 2,000 sq.m. will have to hand over to MCGM 10% BUA in the form of small tenements. When more than 70% of the population lives in one room tenements, this proposal can only be seen as a form of tokenism. Ensure that in each planning sector at least 1/3rd of the housing is for people below the Median Income. This may be for ownership or rental, but with security of tenure.
- The only strategy that is recommended to solve the housing crisis is -“New Generation Built up spaces” by adding FSI in already crowded areas. Mere increase in FSI does not translate into affordable housing as the increase in FSI is at the cost of 70% to 100% ready reckoner rates hence cost reduction would not be possible. The ready reckoner rates are not going to correct to lower figures hence affordability is a misnomer in this Development Plan. FSI is inherently an incomplete tool for allocation of built up area as higher FSI does not automatically mean higher densities and vice versa (For e.g. Densities in D ward are much lower than densities in M-E ward FSI remaining constant). A better tool would be density in a locality and the per capita availability of amenities. The MCGM through this Development Plan should have generated a matrix of available amenities and densities in each planning sector and future development would only be permitted if matrix allows it to. This will ensure equitable distribution of amenities.
- Starting rate for a single bedroom public housing unit is several times higher than the affordable range or 4 to 5 times a family’s annual gross income. In such a situation any new construction is unlikely to be within the reach of the common man. Increase in FSI is utilised for adding luxury tenements by developer. It does not merely translate into affordable housing.
- It is stated that even if only 35% of the BUA provided by the FSI regime is built over next 20 years, we could generate adequate resources for implementation of the DP. What this statement does not take into account is the lag between the investment and the return from the investment. Secondly, if it is so, then why not plan only for the required 35% of the current proposed DP.
- The area of Mumbai Port Trust should be included in the larger planning context of the city.
Slums
- No fine grain analysis of Slums has been done and no clear strategies have been recommended to incorporate holistic development of Slums and the SPA areas. As per the Development Plan only 8% of land area is occupied by slums. Higher FSI in slum rehab schemes will only increase existing densities, leading to further decrease in per capita availability of amenities. Hence the solution should be to give tenure to all tenable slum residents and reserve all areas under slums for affordable housing only.
- The human development index report states 6.4 million as the slum figure however the Census and in the Development Plan 2014-34 the number is 5.2 million. It seems that there is a reduction of 1.2 million of slum population. There is no accountability for drop in slum population from 52% (2001, excluding areas under SPA) to 48% (2011, including areas under SPA), questions the need for re-working our definition of a slum and challenges in obtaining accurate data on informal settlements.
- If 43% of the city’s population is left out of the planning purview and the SPA areas are excluded from the planning then 2/3rd of the city population is not catered to in the proposed Development Plan 2034.
- While SPA areas not included in planning, these areas are serviced by MCGM and people are electing representatives in municipal elections from these areas. Their exclusion would be a violation of the 74th Amendment of the Constitution. We suggest to include the people who vote in BMC elections.
- Mere increase in FSI does not translate into affordable housing as the increase in FSI is utilised for adding luxury tenements by the developer. No schemes are currently available in the affordable section in Mumbai. Barely any MHADA schemes are available. DP 2034 does not recommend anything beyond incentive FSI and TDR as tools for rehabilitation despite being critical of free housing and SRA in the analysis. Mumbai needs significant chunk of rental housing. Hence the MCGM should construct and reserve areas for rental housing which could be given to low income groups on leave and license basis.
URBAN FORM
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Stakeholder meetings organised by MCGM for Mumbai development Plan conducted in January 2014
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WATER SUPPLY & SANITATION
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- No plans for Storm Water Management in Mumbai and no reference to the recommendations of the Fact Finding Committee Report (Chitale Committee Report)
- 600 MLD reduction in demand for water from 4600 MLD to 4000 MLD when compared to the Environment status report 2013-14 by MCGM is questionable. The short fall of 600 MLD as considered by the Development Plan 2034 should be reconciled. There cannot be different set of figures published by the same authority. (The Environment status report 2014-15 vis-a-vis the Development Plan 2034 Document).
- There is no reference of any sewage treatment plant for sewage disposal and storm water disposal in proposed Development Plan 2014-34.
CRITICAL NOTES
- There is a 2260 MTPD Reduction in solid waste generated from 10060 metric tonnes per day to 7800 metric tonnes per day in the base year itself, as compared to the Environment status report 2013-14 by MCGM which is questionable, and will have serious implication on land use and utility provision apparatus. The short fall of 2260 MTPD as considered by the Development Plan should be reconciled. There cannot be different set of figures published by the same authority. (The Environment status report 2014-15 vis-a-vis the Development Plan 2034 Document).
- Garbage separation and disposal.
- In the developed world garbage is being separated at source and each type is disposed of differently, maximizing the potential of recycling and composting. We should do this too, as well as ensure that every household is reached by a garbage collection service.
- Waste segregation centers and Recycling units should be provided for in Land use at community/ neighborhood level.
- Ensure basic facilities for rag pickers, by their meaningful integration into the Garbage collection system and by creating designated pickup points for dry garbage.
- Minimize transport of garbage.
ENVIRONMENT
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- The DP envisions Mumbai as a Green City however Aarey Colony has been marked as a potential location for development. This is a big axe on an environmental asset of the City. This goes against the objective of ensuring a healthy and liveable city. 377 ha of Aarey land are already committed to various projects like the zoo and the Metro III coach depot. Opening up 1009 ha of land will lose another large amount of green cover of which the city is in desperate need already.
- Aarey Colony is demarcated as No Development Zone in the 1994 DP but has been converted to Public open space (ROS1.1) in DP 2034 with land use zone marked as RC. Such outrageous proposals should be weighed against the falling standards of Opens Spaces in Mumbai. The justification given is that there have to be some spatial options for capturing new economic impulses without considering the possibilities and opportunities which can be availed of in the metropolitan region. Inability to protect open spaces from encroachment should not be a justification for opening up the area for further development.
- Large areas of mangroves are considered out of MCGM territory and hence may be open to exploitation. Plots have already been marked on mangroves at Versova. All contiguous areas which are covered by mangroves should be incorporated in the planning area of MCGM. Such a recommendation should be made to the authority which currently owns such excluded areas covered by mangroves.
- No policy, strategy or methodology has been defined for the following:
- Mitigation of noise, air, water (coastal and inland) and landfill pollution.
- Conservation of estuarine hill slopes, nallahs, lakes, mangroves, mud flats and salt pans.
- Flood prone areas.
- Areas prone to landslides.
- Livelihoods of 50,000 Koli fisher folk that are directly dependent on the state of our coastal environment and adivasipadas that are dependent on forest lands.
- The DP should ensure the protection of flood prone areas and conservation of environmentally sensitive areas such as Mudflats, Mangroves etc.
- All areas affected by 100 year flood plain line should be clearly marked on the Development Plan and evacuation routes should be marked for such areas.
- Recommendations of Fact Finding Committee Report (Chitale Committee Report) should be stringently adhered to.
TRANSPORTATION
- The DP suggests that there would be a rise in per capita income in the future years and that this would add to vehicle ownership, but it should be restricted in order to have successful Transit Oriented Development. We see these contradicting ideas on one hand to have TOD and on the other to aspire for higher vehicle ownership. Excessive provision of parking spaces leads to congestion on the streets and the failure of TOD, as does free or cheap on-street parking. Parking charges could be used to subsidize public transport, especially for short journeys.
- 51% of the trips are pedestrian in Mumbai but the scenarios do not address pedestrian issues. Large infrastructure projects seem to take precedence over pedestrian needs. The transport strategy is centered on development of new roads (1860 Ha) and off street parking policies. We should ensure that every street has footpaths, on both sides. The overall footpath width should be not less than 1/3rd of the full width of the street, between compound walls. Ensure street furniture and adequate public toilet facilities.
- There is no plan for comprehensive augmentation of multimodal transportation system however the increase in FSI has been indexed only to Railway/ Metro networks which are inherently not under the control of MCGM. The Western Railway and the Central Railway, carry an estimated 7 million passengers every day while the public bus transport system accounts for 5.5 million passengers. To prioritize and encourage transit ridership we need to make public transport journeys more comfortable, attractive and faster than private transport. The ease and simplicity of inter-modal transfers is an important element in this.
- There are several FSI incentives provided for parking lots which will create congestion on the streets of Mumbai. GDCR has also allowed entire plots to be used for commercial parking, which would be permissible in both RC and CR zones. It could be in the form of Multi Level Car Parking, Mechanized Parking or Puzzle parking where volume to plot ratio will be considered where the maximum allowable ratio would be 12.0. All plots fronting 18.30 m of road could be developed for parking, where 15% of the plot would be used for other commercial purpose as an incentive. All parking spaces should be considered in FSI area calculations.
- Coastal Road: The proposed Western Coastal Road extends from Nariman point via Bandra to Charkop Metro Station.
- The Coastal road should not be a vehicle to circumvent CRZ regulation. CRZ regulations are to protect the environmental assets.
- The Coastal road if the feasibility permits so, should be extended way north along- Metro Line -1 and Metro Line -2 to connect the areas of Manori, Gorai, Madh, and Malvani; to serve its purpose effectively, as this will open up 10000 Acres of land for affordable housing.
- Coastal Road should have a rail corridor otherwise the entire investment is for private vehicles whose mode share is only 4%. ·
- Trans Harbour Link again is missing the rail corridor that citizens had demanded in the various consultation workshops conducted by the MCGM.
DIGITAL INCLUSION
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GENDER SENSITIVE PLAN |
Stakeholder meetings organised by MCGM for Mumbai Development Plan conducted in January 2014
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- No scenario covers the issues specific to welfare of women and children in Mumbai and is completely a technocratic exercise.
- The spaces in the city are used differently by women and children. Their commute patterns are also different. Safety is another concern faced in the city. Concrete plans for safe streets, footpaths, adequate lighting, and access to amenities etc. should be stated in the Development Plan 2034 document.
PROPOSED ZONING
- Is there really a need for mixed used zones to be specified separately? It is significant to note that among the residential land uses, only 58.74% were purely residential while 41.25% are mixed uses (40.43% were commercial-residential, 0.8% were industrial-residential).
- By specifying these zones (CR & RC zones) how does one maintain the ratio between the two and the clashes that occur amongst these land uses. There is no mechanism to ensure that the ratio remains the same over years.
- The CR zone where commercial proportions will be higher, will have certain uses which will be polluting such as plastics, rubber, metals and electrical manufacturing etc. This is very dangerous and we may be forcing disenfranchised populations into accommodations that are unfit for human habitation.
- The transformation of an industrial land cannot happen without any remediation as the land is polluted with heavy metals etc. Without suggesting any such strategies how can the land be permitted to be converted to an R-C or C-R zone where a residential population would live? When an industrial land use is converted into a residential/commercial land use proper remediation strategies should be incorporated in the DCR.
- It is stated that the Residential-Commercial zone will occupy around 11,775 hectares. However, this does not tally with the areas given under the existing land use where total residential area is mentioned as 10,327 hectares and total commercial area as 911 hectares.
- Large NDZ Areas are shown as Residential-Commercial and Commercial-Residential. All NDZ areas should be protected and if opened then only be proposed as open spaces.
CRITICAL NOTES
- As per DCR specified in section 10.6 stating required width of road in relation to building height, allows the accessibility of wider road within the distance of 250m from building for FSI of 5 and above. However this will not ensure the fire safety to the building in congested areas like C ward and D ward. Higher FSI could be allowed only to the plot abutting the required road width provided all other amenities are provided for.
- Marginal set back as mentioned in section 18.3.1 allows set back of only 3 m for building height 70 m and above. These high-rise buildings will not allow fire engine movement around the building during disaster. Minimum set back of 9m on ground should be given on all 4 sides to ensure fire safety for high-rise buildings. This should be provided irrespective of other mandatory fire fighting equipment to be provided in high rise buildings.
- As per SDCR section 6.1 the regulations will be applicable to the listed buildings as marked on Land Use plan. However there is no clear demarcation of the buildings or their grades on the plan. The Heritage list should be incorporated in the SDCR document. All building modification/development permissions should be referred to the Heritage Committee and the Municipal Commissioner should take due note of the recommendations.
SPATIAL DEVELOPMENT STRATEGY
- Development pattern is clearly visible to be ribbon like as against proposed polycentric development. It has talked about existing structure of multiple employment nodes. It is also stated that the proposed zoning and the proposed FSI allocation reflect concentration of employment. However, no figures are given to indicate employment concentration in different employment nodes.
- No consideration of bringing land into the city domain. The Development Plan should look at including areas under SPA in the planning process.
- The document does not mention the likely availability of land from restructuring of the Mumbai Port Trust activities.
- Connection to the MMR Region to bring in land has not been thought of. The major advantage that Manhattan has over Mumbai is the 24 connections to the hinter land. There are no new connections proposed in the Development Plan to the areas in the MMR. Also high speed connectivity to such areas needs to be incorporated in the Development Planning process.
- Manori Gorai Uttan: 10,650 acres gross area, marked only as a tourist zone.
- The area should be included in the MCGM planning area and this area should be developed for affordable housing restricting only some part for tourist zone.
- The proposed transport linkages should be extended further up to Manori Gorai to enhance the connectivity from other parts of the city.
CRITICAL NOTES
- The Development Plan points to having sectorial plans for effective service however there is no legal framework to accept them as the final plans for the area. Section 33 of MR&TP act 1966 has not been used ever.
- DP has been released but the Local Area Plans have not been released. LAP to follow same process as DP. DP itself took more than 5 years. LAP will take same if not longer time. Section 33 of the MR&TP act 1966 was never used for the past 49 years. All local area plans should be prepared simultaneously with process of revision of Development Plan 2034 and put for public suggestion and objection along with the publication of this Development Plan 2034. This will ensure that any major change required in a local area plan is easily incorporated in the Development Plan 2034. FSI should NOT be increased until and unless detailed local area plans are prepared and sanctioned.
- The Census data shows that the population of Mumbai is showing a stabilizing trend. The population in Island City has reduced by 7.57% and the population in suburbs has increased by only 8.29%. These conditions could be attributed to the fact that Mumbai is no longer a lucrative city of people to live in.
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