udri and yuva, disappointing and concerned

Dear All,
Please find attached a Times of India article (link below) on UDRI’s comments to the Municipal Corporation of Greater Mumbai on the revised draft Development Control Regulations for the Mumbai Development Plan 2014-34.

(http://timesofindia.indiatimes.com/city/mumbai/Piecemeal-release-of-development-control-regulations-disappoints-UDRI/articleshow/51885798.cms)

The MCGM since March 2016 has been partially releasing chapters of the DCRs in no particular order (coincidentally right before a long weekend or public holiday). The time given for submitting public comments for these chapters has been limited (two weeks at best) and further cut short by the said long weekend/ public holiday. In many cases, the bye-laws are referring to unpublished chapters limiting the competence to evaluate and comment holistically.

So far following chapters have been released in the following order:
Chapters 1, 2: March 11, 2016
Chapters 3, 4: March 23, 2016
Chapters 9, 11, 12: April 5, 2016
Chapters 7, 10: April 11, 2016

The DCR chapters can be accessed here: http://www.mcgm.gov.in/irj/portal/anonymous/qlddevplan

We request you to kindly take a look at the revised chapters as it will determine the course of Mumbai’s growth and quality of life over the next two decades.
Best regards,
The Urban Design Research Institute
Apr 20th 2016

PRESS RELEASE
PEOPLE’S CONCERNS IN THE REVISED DCRS (MUMBAI DP 2034)
HAMARA SHEHAR MUMBAI ABHIYAAN
4 MAY 2016

Hamara Shehar Mumbai welcomes the efforts by the review committee at making the Revised Development Plan more equitable. The positives in the revised DCRs released since March includes suggestions made by the campaign. These include developing new reservations with multiple uses such as:

• Reservation of Homeless Shelters in consonance with NULM (National Urban Livelihood Mission) standards. We welcome the clubbing of homeless shelters with other amenities.
• Introduction of Gender amenities at the ward level like Adhar Kendras, Livelihood /Care Centres, multipurpose housing, hostels, public convenience sites is a first step towards increasing the workforce participation of women which stands at a dismal 16% in the financial capital of the country.
• Housing as a reservation that the MCGM previously stated was not within their ambit has been included with a new target of creating one million houses – reservation for Affordable Housing and Inclusionary Housing are welcome but their definitions are yet to be clarified in terms of which sections this form of housing caters to.

Concerns in Governance

• The current DCRs invests discretionary power with individuals in authority (the Municipal Commissioner or Officer on Special Duty) at crucial planning junctures. This is against the 74th Amendment for decentralization of urban planning.
• There is clear State Govt. interference in the planning decisions in the city – the coastal road, metro shed, opening the salt pan land for Affordable Housing (also reflected in the draft Maharashtra Housing Policy) are a few examples of this etc. The decisions ignore local demands and needs that have constantly been put forth.
• Local Area Plans (LAPs) and planning sectors that were a step towards third tier planning have been discontinued. LAPs that were demarcated earlier were large slum clusters, and in the RDDP 2034 the MCGM has stated that the SRA will be conducting slum mapping. It is important to state that the SRA is applicable only to slums that meet the 01.01.2000 cut off date, does not include families living on floors above the ground floor and allows only 1 kind of redevelopment i.e. high rise-high density housing. In this light, crucial issues in slums are not being addressed by the MCGM.
• Similar to the creation of the Parking Authority, the Ward Vending Committee and Town Vending Committee are bodies that can implement some planning decisions for hawkers. They need to be included as stakeholders in planning.
• There needs to be a fundamental rethinking on the MR&TP Act to ensure that people’s participation in the planning process is ensured. The piecemeal release of the designation survey, roads survey and the DCRs is not acceptable as this does not ensure holistic suggestions and objections from the public.

Concerns in Open space and Environment

• The percentage of Public Open Space (POS) and Recreational Open Space (ROS) that will be created are favoured towards creation of ROS that will be privately owned and run.
• Reclamation of Cuffe Parade as a Central Park is surprising, considering the fact that the area is an MMRDA Special Planning Area (SPA). Moreover reclamation for creating a POS is not justified as it is environmentally damaging.
• Similarly, the opening up of Salt Pan Land and Aarey Colony are ecological disasters in the making.

Concerns in Economy

• Inclusion of informal livelihoods as a concern that the city must tackle is also welcome. However, the 4 hours per week in specific areas provided for hawking subject to the Municipal Commissioner’s discretion is contradictory to the Street Vendors Act 2014. This provision for the 2 lakh hawkers is tokenistic.
• The conversion of Industrial Zones to Residential and Commercial Zones will have long lasting impacts on job creation in the city. We are not in favour of weekly vending zones and conversion of Industrial Zones into Residential or Commercial Zones. Industrial conversion policy continued from the last DP is going to displace far more formal industrial workers than the new 8 million jobs the DP claims to provide.
• For a city that has 75% informal workforce, tokenistic arrangements provided in Project Affected Business and Community Workplace (PABCW) will not help the marginal informal workers within informal settlements. We look forward to a more thought out and complete proposal to assist 75% informal workforce.

Concerns in Social Amenities

• Social amenity categories of Health and Education need to be expanded and made at par with various missions and schemes suggested by central government. Eg. Right to Education and National Urban Health Mission.

Concerns in Housing

• The new categories in housing i.e. affordable housing and inclusionary housing must be defined in terms of economic parameters. Affordable and Inclusive for which sections is an important question that must be addressed by the RDDP2034. The segment and differentiation of Affordable Housing needed to be considered. We propose that instead of 35% LIG, 35% MIG, 30% HIG – emphasis should be given to create more EWS and LIG housing.
• Similarly R&R as a reservation must be defined since this is a reservation used on most existing slums. These are definitions that are much needed as these reservations are used repeatedly.
• Once again, slums have been left out of the planning process . As stated above - It is important to state that the SRA is applicable only to slums that meet the 01.01.2000 cut off date, does not include families living on floors above ground and allows only 1 kind of redevelopment i.e. high rise high density housing. In this light, the issues in slums are not being addressed by the MCGM
• Mass redevelopment schemes like Cluster redevelopment, MHADA redevelopment, BIT chawls redevelopment has been left out of the DP ambit.

Planning and its relationship with Human Development Indicators is a need that the campaign continues to reinforce. We demand that the MCGM host ward level and city level consultations at this stage to gathers people’s concerns.

Attached are a few of the news reports based on the Press Conference held yesterday:

Mumbai residents’ group raises concerns over minimal public open spaces in Development Plan,
Group says the draft prioritises recreational open spaces which will not be open to the public.
By: Express News Service | Mumbai | Published: May 5, 2016 1:15 (http://indianexpress.com/article/cities/mumbai/mumbai-residents-group-raises-concerns-over-minimal-public-open-spaces-in-development-plan-2784821/#sthash.yMQZJSen.dpuf)

CITING concerns over the allocation of open spaces in the draft Development Plan, members of Hamara Shehar Mumbai Abhiyaan, said Wednesday that the draft prioritises recreational open spaces that will not be open to the general public. They highlighted various other instances in the DP where the needs of local areas have not been adequately addressed.

Hamara Shehar Mumbai Abhiyaan is a city-wide campaign comprised of communities, people’s movements, academic institutions, NGOs, community-based organisations, and activists working for improving public participation in governance in the city.

Sitaram Shelar, programme director of YUVA, stated that various aspects of the DP indicated there was a significant amount of interference from the state government in planning decisions. “The coastal road, metro shed in Aarey colony as well as allowing development on NDZ lands for affordable housing are all examples where the local demands and needs have been ignored,” he said. He added that people’s participation is necessary in the planning process of the DP. “The piecemeal release of the designation survey, roads survey and the DCRs is not acceptable as this does not ensure holistic suggestions and objections from the public,” he said.

Stating that their biggest concern is open spaces, members of the campaign stated that in the draft DC regulations, 20 per cent of open spaces is recreational and only five per cent is open to the general public. “There is a clear prioritising of residential spaces which will benefit the builders, but not the general public. They cannot be termed open spaces if the public has no access to it,” said Aravind Unni, an architect planner with YUVA and a member of the campaign. Making a reference to the reclamation of 3,000 hectares in the bay area of Cuffe Parade, Shelar stated that a public open space has been proposed in an MMRDA special planning area, adding that the reclamation would have serious ecological implications. Campaign members also pointed out that the DP is not inclusive and does not include the slum population. “The BMC is only planning for housing of the slum population who have proof of residence before the year 2000. What about the large number of people who came after 2000 or those on central government lands? The BMC is also responsible for them since they have to plan the entire city which includes them as well,” said Shelar. He also pointed out that mass redevelopment including cluster redevelopment, MHADA redevelopment and BIT chawls redevelopment has been left out of the DP.

BMC’s reclamation plan has activists worried
TNN | May 5, 2016, 05.03 AM IST (http://timesofindia.indiatimes.com/city/mumbai/BMCs-reclamation-plan-has-activists-worried/articleshow/52115016.cms)

Citizen activists on Wednesday raised concern over BMC’s revised draft Development Plan (DP) 2034. They said reclamation of Cuffe Parade as a Central Park to create public open spaces is not justified as it is environmentally damaging.

Members of the campaign, Hamara Shehar Mumbai abhiyaan, said that the revised DP being released in parts has positives and concerns. Aravind Unni said there are few concerns over the new Development Control Regulation (DCR) 2034 released for the revised DP 2034 which they are keen to bring forth.

While raising concern over open spaces and environment they said public open spaces (POS) and Recreational Open Spaces (ROS) that will be created are favoured to create ROS that will be privately owned and run.
Sitaram Shelar, another member, said reclamation of Cuffe Parade as a Central Park is surprising, considering that the area is an MMRDA Special planning area and reclamation to create a POS is not justified.

Similarly, activists said opening up salt pan land and Aarey Colony are potential ecological disasters.

The concerns with housing, they said, is that new categories of housing like affordable and inclusionary housing be defined in terms of economic parameters.

The members said there seems to be government interference in planning decisions in the city like coastal road, metro shed and opening salt pan land for affordable housing reflected in the draft state housing policy. TNN

Maharashtra government’s pet projects dominate Development Plan: Activists _ GEETA DESAI | Thu, 5 May 2016-05:53am, dna (http://www.dnaindia.com/india/report-maharashtra-government-s-pet-projects-dominate-development-plan-activists-2209266)

Citizen activists and NGOs have criticised the political interference in the revised Draft Development Plan 2014-2034. Activists have said that Metro, coastal road and affordable housing projects among others, which are state-promoted, in the draft DP, will go against the common man.

Explaining the adverse effect of the affordable housing project, Sitaram Shelar from Hamara Shaher campaign said the new categories of housing, like affordable and inclusionary, should be defined in terms of economic parameters.

“Instead of 35% for low income group (LIG), 30% for middle income group (MIG) and 30% for high income group (HIG), emphasis should be given to economically weaker sections and LIG and lesser scope should be given to MIG and HIG,” he added.

Concerns were raised pertaining to the revised draft DP, especially about the reclamation of Cuffe Parade as a central park for creation of public open spaces. “It is not justified as it is endangering the environment. Reclamation of Cuffe Parade as a central park is surprising, considering the fact that the area is an MMRDA Special Planning Area,” Shelar pointed out.

On Wednesday, members of the Hamara Shehar Mumbai Abhiyaan said that the revised DP, which is being released in parts, has a few positives as well as concerns. Aravind Unni, a member, said there are a few concerns regarding the new Development Control Regulation 2034, which has been released for the revised DP, and they are keen to highlight those.

While raising concerns pertaining to open spaces and environment, the members also said that the public open spaces and recreational open spaces that would be created would be privately owned and run. Opening up of salt pan land and Aarey Colony are ecological disasters in the making, they added.