method for comments
CONTEXT #
Dear All,
We are pleased to inform you that the Development Plan of Mumbai has been presented to the Mayor and Group Leaders at MCGM yesterday, 16th February 2015. We request you to download it and kindly analyze the same. We shall convene a meeting next week of all stakeholder organizations for collating suggestions and their views. We are also in the process of scheduling meetings with statutory committees of MCGM for appraising our elected representatives about the same.
_ UDRI February 17th, 2015
Zindabad Sathiyon,
Yesterday the DP was presented in front of the group leaders in BMC. As HSVN campaign members, who have contributed constructively and decisively to give a people’s face to the DP revision process, we urge each and everyone to read the document and assess the plan, and what it means for us and our city. There is a threat that debate might revolve around FSI and the open space provisions, diverting everyone’s attention from more pressing needs of housing and basic services. We are right now in the process of studying the document and by evening we shall share with everyone the major points in the summary. We as a campaign need to come together and ensure that we lend our best efforts to claim Mumbai as an inclusive city via the ongoing DP process.
_ YUVA URBAN February 17th, 2015
Text is an address of requests to analyze the dispatched document titled: The Greater Mumbai Draft Development Plan 2034 [Executive Summary]. To take into consideration is the assumption that the file is an official document and not produced by either of the agencies. Neither states origin of the dispatched file nor does the contexts have any indications of author/s who may have produced it. At the moment of writing the file isn’t available for download on either the municipality website or those of the said agencies. Result of lack of authorship, or information about source of the file, propose of the work is to use the document to devise a method in possible commenting process with both the citizens groups and the municipality should undertake in any future public participatory planning discussions. Quest for a method tries posing a few impending questions such as what is a comment? how is its mechanism of acceptance and what becomes of said comments either cases of acceptance or rejection? These questions introduce the necessity of formalizing the comment such that there isn’t any concerns on how participation is programmed and subsequently conducted. At this instance, the document in its basic form becomes a template for the review system. Contents therefore, are considered as a list of 21 sections with subsequent details of each of the items elaborated within each of them. Two immediate propositions is arrived at by this, is firstly all documents for discussion needs a set of guidelines to direct their narrative and second in this earmarked framework is the field to accept all formats of conversations.
OBJECTIONS & SUGGESTIONS #
List follows given content heads of the document. Under each item of the list suggestion if any or objection to a specific aspect of the item is mentioned. At this instance suggestions and objections operate independently for most clauses. A pointwise mode of identified objection and the suggestion to the point is ideal to the form. This draft takes mode of laying out some immediate concerns which seem evident or need address.
1] Introduction to Greater Mumbai, Draft Development Plan 2034
suggestion _ A relation isn’t evident between the Set of Plans and part III, proposals from Volume I extending these again to the development control regulations. Set of Plans be considered a part of the volumes or the third volume can be read as proposed land-use plan. The three final deliverable are thus Volume I: Report on Greater Mumbai Development Plan 2014-34, Volume II: Development Control Regulations and Volume III: Proposed Land-Use. Proposals presented is via identified strategy linked to the submitted plan within comprehensible limits. Applicability of development control regulations as per areas can also be demarcated both at plan and document level. Objective is when broader review is requested all the three are read in reference with each other.
2] Past experience
objection _ Experiences stated are speculative, a) Affordable housing was a challenge that both plans sought to address and b) scarcity of development rights might have reflected in the housing prices and the affordability. Plan is in principle required to address these.
suggestion _ To present merits alongside the demerits as they may be recommended as benchmarks of aspiration if desired. If found data gaps are present between the plans what they are, have to be mentioned. Definitions such as affordability and how that have transformed over the period of implementation are required consideration.
3] Approach and Methodology Adopted for Plan Preparation
objection _ Which parameters to be applied for urban analysis is unclear. The same is extended to methods mentioned against stated consultative process. What was the need by the planning agency to conduct the same? or what where the anticipated data gaps which needed filling in which consultations was required and these thus addressed?
suggestion _ It seems like planning sectors and ‘Places’ in Greater Mumbai are two different scenarios looked at. In principle, if they are integrated then there can be the creation of type in planning sectors whereby varying sectors are accommodated and addressed under collective or idiosyncratic characteristics.
4] Challenges Ahead of Greater Mumbai
objection _ In case of shifting industries, the spaces occupied by them isn’t adequately addressed towards recycling their premises. Same implementation is stated when it comes to stabling population and smaller family sizes to issues of future housing type proposed in the plan.
suggestion _ If there is a space crunch the city is seen facing, not all activities is necessary of required location in city limits. Selected industries and other identified programs can be moved, similar industries in the region upgraded, therefore catering to more pressing activities for which land is demanded. Expansion of city boundaries is also a viable case to consider.
5] Vision 2034
objection _ Terms of competitive, inclusive and sustainable come off as isolated and not linked to the larger planning exercise. What they can be further confused when a more group of terms namely - inclusive, healthy, livable, efficient - are added into the mix.
suggestion _ It can help if the three terms are associated with some kind of benchmarks so as to be useful as statement in the overall plan. Something like what are the associated standards of Competitiveness, Inclusion and Sustainability aspired against a result of which proposals and area plans are presented. The terms if elaborated can also be used as measure in how development and changes in any form can be aspired against.
6] Need for a Paradigm Shift: The DP as a Broad Framework
objection _ As section it concentrates in majority on past conducted consultation as only process or a probable example of an imagined shift. Consultation was introduced at a stage where it didn’t exit against what was mandated against. How consultation has impacted the outcome of the presented plan is the probable shift to concentrate against. Future role of what it can be understood as citizens participation in the implementation of a plan needs required address.
suggestion _ However broad the frameworks are they are required to be stated towards a certain level of clarity. An ever probable accommodative scenario can also be a hindrance to measure development against. Understanding and application of FSI is one such condition. To what extent liberalization is deemed beneficial and for whom, is to be addressed in light of objectives of the proposed plan. Basis of how sectoral heads are introduced needs mention along with methods of enabling other avenues such as culture which are absent in the proposed set.
7] Planning Area and Existing Land Use 2012
objection _ Slum is slotted in the residential category. Most slums play the dual role of accommodating both industrial and commercial activities or are predominantly commercial. This error will lead to inadequate provisions at the time of redevelopment. Urban villages such as koliwadas also support spaces of sector-specific activities. These when compared in a context, vary distinctly from urban villages surrounded by the dense city fabric. Distinctions as mentioned need case to case address. No brown-fields or uninhabitable/ toxic land is mentioned.
suggestion _ Two existing land-use dates (2012 & ‘13) are mentioned [Map 1 shown doesn’t have a date on it]. Clarity on what the most recent applied land-use can be decided on and the particular state disseminated for a given period. A systemic review of land-use is required and made available for use as reference to the process of plan implementation over the course of an implementation period. At every five years, a land-use map needs commission to audit status and ongoing development trajectory of the city.
8] Delineation of Planning Sectors
suggestion _ Planning sectors have added a new dimension to access regions in the city. There are other regulatory boundaries such as the CRZ, census and the electoral boundaries the city has to deal with. Can the planning sectors replace these other delineations in providing a bit more clarity/ simplicity in governance or does it add to the other list in a way that every mechanism of governance has their own idea of a boundary? MBPT and BARC land as they form singular large public sector lands delineated as special planning areas.
9] Population
objection _ With 41% of its cities population living in slums the primary goal of the planning exercise should reduce this percentile by the next DP event. Any inclination to this aims seems absent.
suggestion _ The presented analysis is only for households and doesn’t present any projections against industries or commercial indicators which are responsible for the population within city limits. Instead of just representation of available information extended factors need discussion.
10] Economy
objection _ Its only stated that real estate is a problem as the median household income is lower the available stock. It’s unclear on how the plan is positioning to address this found disparity. Stating common knowledge is extremely inadequate in light of long-term planning. Either some policies/ devices to lower the rising real estate costs are required investigation or increase in the production of rental stock and revising mechanism of rent control within the present economic environment.
suggestion _ There is a contradiction between the two heads since there isn’t any argumentative linkages between stating - it is apparent that nearly half of the population is unable to afford to own a house, even of minimum standards - to - would convert into higher aspirations, a lifestyle of greater consumption, demand for more space, in terms of higher per capita area, for residential use, commercial use, amenities, utilities and open spaces. The pointers look like they are addressing two different economies in the same city. For one, there is a solution while for the other it’s simply “we are unable to provide a solution”. This disconnect should be avoided in the narrative.
11] Spatial Development Strategy
objection _ Mentioned areas are predominately business districts, therefore seeing development only on the basis of a particular aspect of the economy is an error when equitable growth scenarios are required. Role of special planning areas in the city hasn’t been questioned and how they can add to the conversation. As a polycentric model, concentrated development is recommended only in one other region. When compared to the earlier zones simply at scale of its proposition undermines the core principles of the proposed multi-nodal city. Reconsidering the scope at the location other centers/ nodes need identification and considered. Factor of the city being surrounded on all three sides by water hasn’t been taken into consideration at all. The nature and status of its elaborate waterfront towards equitable access is required to be an essential part of the proposal.
suggestion _ To enhance clarity its proposed that planning sectors be made available alongside place names so a better context to the places is reached if parallel plans need consultation. Sector G of Bandra Kurla Complex or the International Finance and Business Center (IFBC) is indicated as BKC. As planning sector, the region is much larger as seen on the map and the error needs a redress. The same issue persists at Fort and Ballard Estate. City’s industrial past in terms of mill lands can be added to the list on the map.
12] Proposed Zoning
objection _ The concept of mixed use is problematically ambiguous. It virtually suggests program in city limits can be interposed anywhere and not limited to any specific area or place in the city. Residences can be converted into commercial establishments and these further to industrial uses. Reverse of the concept too is enabling from industries and back to residences. The lack of any institutional/ amenity areas for the city questions the seriousness of the zoning presented.
suggestion _ With facilitating mixed use at a city-wide level, what it means to travel in the city needs questioning. All proposal are centric for a city dependent on its transportation system. Given new found planning sectors, the possibility of enhanced neighborhood-level design incorporated with universality of mixed use at the city level facilitates an scenario wherein travel can be avoided or just limited by design in a planning sector or to ward limits.
13] Floor Space Index
objection _ Station areas are in urgent need of restructuring as they are already congested areas. Adding the possibility of concentrating more development onto these nodes will only complicate navigation from and to these spaces. Proposed floor space index map displays a keen interest in consolidating and building on the existing network instead of even presenting an imagination of an aspiration to move to the proposed new center/s.
suggestion _ It seems unclear on what kind of commercial development is encouraged but provision to accommodate institutional preferably cultural areas are recommended. Scenario modeling on the availability of buildable area within each planning sector can be proposed.
14] Land for Public Purpose
objection _ Amenity provision is required to be made available at the zoning level and earmarked on map as single use land allocation. This as tactic brings about a level of clarity at the various levels of neighborhood, planning sector, ward and the city. Cultural amenities are not mentioned in adequate detail. Shopping, theaters and religious areas in the city are not clear among the rest how they are catered to. Dependence of plots of 2000sqm and above to take on any missing public amenity is misleading as even housing for the dis-housed/ low-income housing too is purposed for reservation on these plots.
suggestion _ Process of simplification looks like it’s taken out a section of amenities which in addition to serving social needs add significant value to the economy. Entertainment and nightlife of a city are integral part of urban living and these are required discussion in the plan. Tourism which the city attracts brings along an ecosystem of its own. Cultural industries of advertising, music, film and the like are public consumption program cannot be completely treated as commercial land-use as they serve a dual purpose. Sports definitely are missing in the conversation. Prioritizing only on open space, health and education are limiting to a holistic well-being of Mumbai.
Portlands is marked only in part. The remainder when available for public should be part of the larger land pool for amenities. Anticipated allocations in the area is required. Program from the proposed recreation and tourism development zone can be re-purposed around the city instead of a concentration at the city’s edge. #
15] Transport & Road Network
objection _ The plan expends a complex reliability towards public transport networks in the city. Most proposals hinge along the prominent road, rail and the phases of the metro line. This dependence is indicative of the limited importance given to walkability among these networks. Low-intensity transport still prevails in areas not designed for use of cars and other automobiles. Aura of an older city and its limitations aren’t apparent in the plan. All areas in the city need not have vehicular access. Housing societies who haven’t planned for parking and needs requires neighborhood wise parking allocation haven’t been addressed. Communities such as hawking and auto/ taxi drivers who are dependent on the street for livelihood need allocation within the transportation plan.
suggestion _ Community parking provisions in public institution buildings can be considered during redevelopment of these building types [as accommodated via design in residential hotels, lodgings, hotels, educational institutions, medical institutions, auditoriums, shops, restaurants, industrial uses, warehouses etc.] Multi-tiered parking structures should be allocated at the edges of markets and commercial districts where feasible/ required.
16] Physical Infrastructure & Departmental Demand
objection _ Conservation of water sources and its neighboring communities are necessary when external resources are used. Community programs with the assistance of state government can be initiated where rehabilitation is mandated. In city limits, housing needs of workers involved in the provision of these services [water/ sewerage/ storm water drainage/ solid waste management] should be part of public housing provisions.
suggestion _ Environmental assessments on functioning and status of these services require participatory discussion every five years. Rainwater harvesting, on-site/ neighborhood composting need recognition at the plan level at all applicable scales. Instead of locating waste management plots in city limits, on consultation with the regional plan sites in the immediate vicinity be identified for disposal and accommodating a recycling industry.
17] Environment
suggestion _ DP plays only the role of recognizing natural features in the plan. These are also no mention of communities which are dependent and are responsible for the maintenance the of several rivers, beaches. Involvement of stakeholders of natural features of the city should be considered as the only way in a sustainable city development.
18] Development Control Regulations
objection _ These regulations have catered to only popular concerns and situations of a public imagination on errors with plans. As per list some of the recommended modifications are a) land pool is unclear if it’s from the city level or local ward, ideally the ward should be an aggregator for the pool; b) urban design regulations for roads as per available type needs incorporation; c) what is expected from a marginal space needs clarity in regulations; d) rent over ownership needs regulation therefore as a result all public housing be rented properties; e) open spaces are be made for public use and not utility oriented, utilities if on open space is stated as utility and f) Handbook on Barrier Free and Accessibility [2014] by Central Public Works Department should be consulted for disability design.
suggestion _ Special development shouldn’t be limited only to built structures but ecological sites, areas around utilities and natural markets formed in various neighborhoods of the city. Regulations for design of open spaces with requirements on artwork/ memorials are definitive considerations.
19] Dovetailing Local Area Plans with the DP
objection _ No natural features such as Mithi river, beaches are considered part of local area planning exercises. These too should be incorporated forming a larger list of areas for planning as per type.
suggestion _ Using the planning sector as reference a catalog of proposed areas for redevelopment can be demarcated on the plan. From these listed areas proposals for redevelopment is invited to interested agencies who with partnership of stakeholders, draft out the required plans and they be submitted to the Municipality for inspection thus assisted implementation. Citizens associated with a neighborhood should have more control on proposals for their area and the state an enabler.
20] Financing the Development Plan
suggestion _ Ward wise distribution of funds over the 20year period should be available for inspection. Five yearly report on DP implementation can be shared and consultation meetings held to present progress of work done with revisions if any made.
21] Monitoring & Evaluation
objection _ Participation at the citizen’s level at wards is absent and needs introduction. The 5year benchmark is mandated as review point and identified ngo’s, alms and citizen’s groups involved in decisions made at local areas.
suggestion _ If planning sector is introduced then its administration should be scheduled at the identified level with collective reporting at the ward. This would then not require the further bifurcating the wards and creating more boundaries in the city. All wards can remain at the alphabet level and subsequent east/west or north/south associations removed. Imminent logic is that the eastern wards are considered the lesser of the two wards in most cases and deactivating the east/ west boundaries or north/south may present a more equitable overview of a place instead of the current underlying norms in place. National Park [including IIT/ Powai Lake] should be isolated as a ward such as not to be subjected to wards its now divided against. Ward boundary running across the Oshiwara District Centre can move around it. Similarly applicable for Bandra Kurla Complex
15 wards [A/ B/ C/ D/ E/ F/ G - Island City, H/ K/ P/ R - Western Suburbs, L, M, N, S, T - Eastern Suburbs & National Park] containing 150 planning sectors with each sector empowered to address issues within limits. #
CONCLUSIONS #
This formatting is one of the possible ideas to consider. Every presented situation could promote various narrative structures thus different formats. At this instance, the need for the overarching or summary set of review points are avoided as the document is the summary to a larger entity of the actual plan. A result of which some of the mentions is stated in the light of incomplete information which may be submitted in the final plan. Most of the pointers can be further elaborated upon but limited for this instance. It’s not clear what is the level of hearing when a set of objections and suggestions are provided. There isn’t any clarity if invited against a presentation what is the time frame given per individual/ organization and interest level by the planning agency if the pointers submitted will be considered and formal mention of how revisions will be made with accepted ideas. The ideal next step to consider the process of commenting is having all three document sets of report, development control regulations, and the proposed land use maps in place. These are then matched with a collective set of demands by the citizens groups overlaid on found discrepancies of the existing land use plans. The anticipated narrative could be either the framework of the report or identified planning layers by citizen groups.