restructuring a post
The preparatory studies document has been an instrument of the MCGM towards presenting an interface to the city at large in what their vision of the development of the city is. Posted after a group of citizens consultation exercises, that was held after publication of the report, this blog post by YUVA highlights the several disparities of the document and thus the factors to be considered by the corporation when they make the next phase of the plan public. Though not a direct critique, the text tries to highlight some critical issues as deemed necessary by YUVA and its partners in the campaign Hamara Shehar, Hamara Vikas, Hamara Niyojan, Abhiyan Mumbai. The post is a iteration to the Peoples Vision and is hence seen as two different entities. To these documents several other citizens charters could be drawn in to establish a larger People vs Municipality view on what directives for development should be. Exercise here is to map the narrative as per the structure of the official publication towards establishing priorities that have been positioned in relation to the details given by the corporation. Three primary heads lay out the [preparatory] studies a) Existing Landuse Survey, b) Assessment of Existing Situation and c) Visualizing the future. In further simplification and consolidation of limits of this process, section b has been sorted into 14 layers of consideration that the plan will be addressing thus establishing an approximate field for the discussion and further elaboration for analysis.
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EXISTING LANDUSE SURVEY
01) Planning Sectors - The MCGM has adopted the concept of “planning sectors” for the revision of the DP to have “basic workable spatial units” for the provision of social amenities “at the smallest level of disaggregation appropriate to be addressed in the Development Plan.” The planning sectors do not correspond to the Corporator ward boundaries, but do correspond to the administrative ward boundaries.
02) Per Capita Built Up Space Consumption by Income Levels - The Report does not indicate income distribution as well as per capita space consumption and analyze the relation between the two. By not counting these, it glosses over the more difficult questions of inequalities in the city.
03) Factors Affecting Population Growth or Stagnation - Assuming that there is a decline in the rate of growth of population, as the Preparatory Report states, citing the 2011 census, what are the reasons for the decrease in the rate of population growth in the city? The report makes population projections, but does not get into an analysis of why there is a decline.
04) 2011 Census, Slum Data and Human Development Index - The Development Plan uses the 2011 census for its population data but uses ‘provisional data’ for slums, which seems to be a massive underestimate of slum households and people living in them.
05) Planning Standards and Benchmarks - Planning standards have been reduced in the preparatory studies to being almost half of the lowest among the various norms enumerated by different planning agencies and authorities in the country. Compare the MCGM’s 2014-34 DP’s total per capita amenity and open space benchmarks at a Planning Sector level (2.154) with UDPFI norms (18+), Delhi Development Authority (5.7+), National Building Code (16.34+), CIDCO (4.42), 1991 Mumbai DP (5.36+), Committee on Planning Standards (4.14+). It must be noted that minimum benchmarks for every Planning Sector (PS) is lower than even the existing amenity areas at the city level according to the ELU.
13) FSI, Density and Gentrification - If per capita consumption of built up space is held constant, increase in FSI will increase density ; Assuming that all the built up space produced as a result of higher FSI will be consumed, and assuming that per capita consumption is constant, won’t population growth (and hence density) increase as a result of availability of built up space? How will the subsequent increase in requirement for amenity and open spaces be satisfied?
18) Existing Land Use Distribution - The percentage of developed areas dedicated to different urban functions according to the MCGM’s ELU can be compared to UDPFI’s guidelines. The guidelines suggest 35-40 % developed area for residential functions (Mumbai presently is 38%), 4-5% for commercial and offices (Mumbai is 4.6%), 12-14% for industrial (8.27%), 14-16% for utilities and amenities (5.19%), 20-25% for openspaces (5.67%), 15-18% for transport & communication (19.57%). UDPFI is extremely generous in its open space norms, and there is a strong case to relax these, especially since streets and other informal spaces are already used as public spaces in our cities. Though the report has emphasized that these norms are unachievable in Mumbai, the comparison shows that the functions that are deficient in terms of land area are recreational facilities and amenities.
22) Comprehensive Area Development plans - The MCGM suggests a “two tier planning strategy” and the DP report will indicate the “Areas for Comprehensive Development’ and also…the priorities for undertaking the preparations of such plans.” Comprehensive “redevelopment plans” will be made for large slum or resettlement areas such as Shivaji Nagar, Malwani, Golibar, Asalfa, etc. Urban renewal plans for areas such as Null Bazaar, and plans for areas “undergoing land use changes” and transit oriented development. There seems to be a great deal of ambiguity about this: who is going to be the Planning Authority for these areas? Will the MCGM appoint an agency / organization for the making and implementation of plans for these areas?
25) ‘Placemaking’: emphasis on Physical form rather than social aspects - The DP report recognizes various “character based built assets and precincts,” places that attribute value to greater Mumbai and need to be maintained for the future, and adopts “place making” as a strategy by “capitalizing on the community’s assets, inspiration and potential,” to create “places that promote a local quality of life.” The DP 2014 acknowledges these areas as spaces desirous of planned transformation, making a case for holistic renewal and area specific development. It rightly sets out to transcend statutory requirements and adopts a cultural geography approach to map various places in Greater Mumbai that harness their “special and peculiar characteristics” (chapter on urban form).
30) Environmental and social impacts of proposed projects - The report refers to some proposed large infrastructural projects without absolutely no mention of environmental or social impact assessments. For example the Coastal Road which is being promoted as an alternative to sea-links as “both a feasible and economically…attractive option,” appears as a ‘proposed road’ in the preparatory studies report.
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ASSESSMENT OF EXISTING SITUATION
residential
06) Mapping Social Realities - The term “slum” suggests a combination of insanitary conditions, inadequate access to services, poor quality construction and so on. These might vary in scale and intensity for different areas. Rather than simply mapping areas perceived or recognized as “slums,” it might be more useful for policy and planning, to produce maps based on specific social indicators.
09) Supply and Demand in the Affordable Housing Market - The report makes the supply-demand argument to explain the high costs of land and housing in the city, without undertaking an honest assessment of the disequilibrium of forces operating in the housing market, and on other markets that are connected to the housing market. The document ascribes speculation in the housing market to state regulations, making the case for doing away with them altogether. What is needed is a thorough study of the kind of housing stock being made available by private builders, the costs of these dwellings and their affordability to the larger population including women and other economically disadvantaged groups.
10) Unoccupied dwelling units - The census survey and research studies have brought out the worrying picture of unoccupied dwellings space lying unused. Data about total housing stock in the city, their prices and their occupancy status will provide a good understanding of the scale of speculation in housing which has implications for policy and planning.
11) Per Capita Land Area for Residential Development? - The per capita land mapped as residential areas as per the ELU is highly suspect at 8 sqm per person. Some commentators have pointed out that the per capita consumption of built up residential space in Mumbai is as low as 4.5 sqm.
26) “Facilitating the market” as a Strategy for creation of Inclusive housing - On inclusive housing the report explains how surplus vacant lands were exempted from acquisition under the Urban Land (ceiling and regulation) Act 1976, if the landowners agreed to develop smaller dwelling units less than 40 sqm in area.” This strategy, it says, did not achieve its intended goal of generating affordable housing as in many cases “they were combined into bigger units and allotted to higher income households”. But rather surprisingly, the report articulates its new strategy for providing affordable housing in which “all developers are required to devote a certain proportion of total floor space proposed to smaller dwelling units.” The report states that the new FSI strategy, with varied and increased FSI, will facilitate supply of affordable built spaces in the city and, thus, promote “inclusionary housing.” The suggestion is that smaller units made will be taken over by the state and allotted as affordable housing. There are a few problems with this: for one, it assumes redevelopment through FSI incentives as the only strategy for creating affordable housing. Second, it will lead to extremely high densities that can only be achieved by a drastic reduction in amenity standards. Third, a large part of the informal employment in the city is made possible in squatter settlements, that will be lost as a result of the typologies that will emerge from large scale redevelopment.
urban villages
32) Gaothans, Koliwadas and Aadivasipadas - Though “urban village” has been included as a land use category in the ELU survey many of the urban villages have not been mapped in the ELU. There is no mention of koliwadas, gaothans and adivasipadas in the preparatory studies report.
33) Demarcation of the Coastal Regulation Zone and integration of ICZMP’s in DP - Furthermore Koliwadas have been designated as CRZ III as per the CRZ notification 2011 in order to protect the coastal community’s right to livelihood and housing. CRZ boundaries, especially the areas to be designated as CRZ III including public areas amenities and commons within these fishing villages, need to be demarcated with community participation and included in the development plan.
educational amenities
23) b Health and Education - Instead recommendations for space provision with regards to educational amenities state “diminished need for land availability” due to RTE norm of 25% reservation of seats as free for low income students. This statement is shocking as even if RTE norms are enforced, 25% of seats are barely enough to service the density of low income areas. It further approaches the provision of educational amenities through intensification, integration and combining of existing schools.
medical amenities
23) a Health and Education - The Preparatory Studies state that healthcare is central to citizen welfare and needs to be augmented to at least achieve DP 1991 norms. It further states NUHM guidelines on population and health care services, but its ultimate recommendation is intensification of existing amenities.
commercial activities
NA
social amenities
07) Mapping Access to Amenities - The Report seems to focus only on amenities in terms of per capita areas, and mapping locations. Simply achieving planning benchmarks does not achieve any purpose in the absence of addressing issues of inequalities of access to amenities. The approach to calculating amenity space is counting the number of people in an area, and dividing up the total floor area of an amenity among them. But not all people have equal opportunities to enjoy a given amenity. What needs to be mapped instead is the per capita amenity areas for different income groups and a gendered approach to the same.
15) Evidence for production of land for “public use” through redevelopment - Before proposing redevelopment as an answer to the city’s woes related to land scarcity, it is important to study the impact of redevelopment in the past. Is there evidence that redevelopment has been able to produce land for public use? On the contrary there is evidence that it does not work.
20) Land Pooling vs Reservations - The Report observes that land reservations as a tool for providing amenities has not worked in the city, as land acquisition has not been always successful, and scarcity of land has limited possibilities for more reservations. To overcome these limitations, it suggests a different strategy for accumulating land for public use and a alternative approach for the provision of amenities. Through redevelopment, a small amount of land can be extracted, this land will be “pooled,” and through a participatory process, the amenities needed will be provided. But has extraction of land in this manner succeeded so far?
24) Amenities for vulnerable groups - Under social /public amenities, there is no mention of creation of shelter homes under MGPKY. A metropolis like Mumbai should necessarily provide for the needs of the homeless. Shelters are needed also for women who face violence and street children.
natural areas & open spaces
08) Mapping Access to Open Spaces - As the preparatory studies itself mentions, many of the open spaces in the city are public in name but private in use. Barricaded, policed and restricted in use, to name a few. These are made to become suited to certain classes and their lifestyles. But while computing the available open spaces in the city and setting benchmarks, the assumption is that every square meter of open space in the city can be enjoyed by every member. This is misleading. Can a method be devised to measure access to open spaces based on income levels, or inequities in open space consumption?
28) Open spaces, natural areas and commons, use, access and control - There is ambiguity and confusion over certain Land use categories in the Development plan. The DP needs to make a clear distinction between natural areas, open spaces and commons.
29) Green and blue networks - The DP 2014- 2034 demarcates all major water courses (4 rivers – Oshiwara, Poisar, Dahisar and Mithi and all major creeks like Mahul creek, Irla creek, Versova- Malad creek and Manori-Goral creek as part of a ‘blue network’ to be rejuvenated and accompanied by a green buffer zone to be created along its length. This would form a “green grid”- a green corridor that will run alongside the “blue grid” of watercourses. The green grid would provide much needed additional open space in the city.
35) Incorrect Demarcation of existing natural features - The ELU does not accurately map several natural features which have been shown either as vacant lands or some other land use. All these errors on the ELU maps which have been pointed out earlier should be rectified and made public before the PLU maps are made.
offices
12) The Tertiary Sector and Employment - The Preparatory Studies is rather cheerful about the possibilities offered by the service (tertiary) sector, without an analysis of its performance over twenty years. How many formal and informal jobs has this sector generated versus the formal jobs it has lost to the industrial sector? How have incomes been distributed within the tertiary sector? The report refuses to ask these questions.
transportation & communication
19) Transport infrastructure - In its transport section, the MCGM blames the problems of mobility and poor efficiency of traffic flow on the “inadequate road density and…several missing road links in the overall road network infrastructure…particularly so in the Western Suburbs.” It abdicates its authority over major “arterials and highways” that are “addressed comprehensively at the larger scale” but will pass over its territory (such as the coastal road, that appears as “proposed road” in the preparatory report’s maps).
industrial use
NA
vacant land
31) Opening up NDZ areas which are not ecologically sensitive for development - In section 18.5 ‘Increasing supply of land for public purpose it is mentioned that mentions “opening up vacant or underdeveloped lands in the City, which are not environmentally sensitive, and creating a pool of land for public purpose. It states that DP 1991 had zoned 116.56 sqkm under No Development Zones. Majority of lands under NDZ, DP 1991 are environmentally sensitive. However some areas which are not environmentally sensitive can be made available for development.
primary activity
34) Indication of Land use sub categories in the ELU - There is ambiguity in Land use categories in the ELU survey. For example in the ELU survey, areas demarcated as primary activity include diverse activities such as Fishing/drying yards, plantation, dairy, bufallo stables, cattlepounds, quarry, dhobi Ghat and salt pan lands.
public utility & facility
21) Infrastructure and Services - The Preparatory Studies points out that a comprehensive mapping of the drainage network interlinked with other municipal services is essential. Mapping the adequacy, quality and delivery of municipal services (water supply, sanitation, flooding areas) and overlaying this map with infrastructure networks can be an effective way of understanding shortfalls in municipal infrastructure and services.
27) Water Supply - The Preparatory Studies assessment of water is only a description of the existing physical infrastructure (water systems) and ongoing water supply proposals. There is no assessment of existing infrastructure in view of development and improvement of this infrastructure. Moreover, there is no elaborate discussion or proposal for improvement and development - only bullet points of improvements and challenges are noted. Norms, criteria and basis for improvement and development are not discussed. While there is emphasis on the augmentation and resource side development, no points are made about demand or distribution side development.
unclassified lands
NA
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VISUALISING THE FUTURE
16) No Concrete Goals, Little Data and No Situation Analysis or Projections for the Vision of Making Mumbai a “Sustainable City” - The report uses technology to precisely map and measure FSI consumption and potential in every neighborhood of the city. It also has clear goals in terms of space requirements for residential, commercial and amenity spaces for a growing population over 20 years. In doing so, it exhibits clarity in articulating goals and a commitment to objective analysis that is praiseworthy. However, it provides no clear goals or objectives for its purported ambition of making a “sustainable city.”
17) No Concrete Goals, Little Data and No Situation Analysis or Projections for the Vision of Making Mumbai an “Inclusive City” - MCGM’s report gives itself the challenge of making the city inclusive. In a highly unequal city, such an ambition ought to be the primary concern of any planner. Towards achieving this vision, the Preparatory Studies Document, needed to elaborate on various forms of inequalities and exclusions in the city with data. The situation analysis report has almost no analysis of the various forms of exclusion in the city, the causes and consequences of exclusion, or of means and measures to alleviate them. As a consequence, it has not articulated any clear goals or targets except rather vague suggestions about reducing slums. Most of the data (such as incomes, built up areas, amenity areas, open spaces, etc) is based on per capita aggregates which completely misses out on inequalities of distribution in all of these measures.
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Observations
As introduced on the basis of an established broad structure found in the preparatory studies, the [YUVA] post for its various directives has been distributed serially into 35 locations. These are then as applicable associated with found head and subheadings from the [preparatory] study. The post tries to simultaneously point out discripances and suggests alternatives where possible. Goal of this exercise has thus been to monitor the extent of distribution of demands in relation to a broader set of official intervention heads. In regards to the directed goal one should note based on postulate concentration where the institutional priorities lie.
Addressing to the needs of the informal city is the overarching theme. A fact iterated in the post itself is that the document is substantially interested in the planning process and not particularly its details. Therefore a majority of postulates, 10 clauses, find slotted in the Existing Landuse Survey section. To the Assessment of the Existing Situation there are 14 subsections or layers with respect to the development plan. These are based of on grouping of the several land classifications adapted from the earlier development plan and introduced as updates for the new one. Therefore trying to summarize the remaining distributed postulates as follows _ Amenities are/ can be looked at both a singular objective or segregated under four - educational, medical, commercial and social - subheads. Views presented could be stated as being overriding for all amenities making it the largest as a group with 7 suggestions. But to note are of the lot 5 of which are overarching and temporarily submitted under the social subhead. The rest two are distributed between educational and medical amenities. Specifically commercial and social activities aren’t addressed. Residential comes in next with 5 suggestions all laying out concerns at the informal sector. Next on the priority list is natural areas & open spaces with 4 suggestions. Edited here due to constraints, openspace notes are some of the most detailed among the lot. Urban Villages and Public Utility & Facility come in next with 2 postulates each. Issues at Offices, Transport & Communications, Vacant Land and Primary Activity are all addressed with 1 suggestion per issue. Industrial Use and Unclassified territories don’t find any mention. With a city that has been an outcome of industries and with ever ending statements on the non availability of land its unfortunate both these areas have been overlooked. For the last head of Visualizing the Future 2 postulates are stated.
To consider is the fact is that this exercise is an ad hoc endeavour and position isn’t necessarily conclusive. Most of ordering is speculative. This is a sketch to an attempt to adequately list down policies on what the people consider important and need to be addressed. To bring together ideas into a singular format towards redressal and discussion is the key for this endeavour. A framework to find a common grounding for all organisations involved. Either the governing agency or the citizen’s initiative should recognise lacunas in communication and work towards a mutual implementation of ideas. The development plan is definitely a design exercise to a degree and as all designs go imagination has got its constraints. There is no right solution to a problem but a commonly negotiated one. Thus the negotiation is of essence and not its fall outs.