From: bcsabha.kal...@gmail.com To: From: G R Vora <grv...@gmail.com>
10.4.2015 Dear friends, I intend to send these objections / suggestions to the Ch. Eng. DP and others of BMC by tomorrow evening. Kindly inform me of any additions / corrections etc. by 4 pm tomorrow. Please see attachment. It is copy-pasted below too. Regards. GRV ==== 11.4.2015 To, Municipal Commissioner, BMC Head Office, Room No. 46, 1st Floor, Mahapalika Marg, Mumbai – 400001. To, Chief Engineer (Devpt. Plan), BMC Head Office Annexe, 5th Floor, Mahapalika Marg, Mumbai – 400001. To, Chairman, Standing Committee, BMC Head Office, Mahapalika Marg, Mumbai – 400001. Sub. : Suggestions / objections for the proposed Development Plan 2014 – 2034 for Mumbai. Sir, We would request that the MCGM reduce the selling price of the DP Report, DC Regulations and the Maps since the cost is very high and is unaffordable to the common man. Whilst soft copies are available, these are not easy to read on a screen.We would request that the 60 day time period needs to be extended since the hard copies of the overpriced maps and reports were not available until two weeks ago.We would suggest that the Plans for all the areas under the Special Planning Authorities be prepared in conformity with the provisions of the DP/draft DP, and would need to be approved by the MCGM, since it is the responsibility of the MCGM to provide the infrastructure.The New Coastal Zone Management Plan for the city of Mumbai which is to be made in accordance with the Coastal Zone Regulation Notification of 2011 is yet to be finalized. The current Development Plan is based on the old CZMP which has finally expired on 31st January, 2015 (i.e. after two extensions from its original expiry date in 2013). We object to the fact that the Development Plan of a coastal city like Mumbai is being finalized without there being an approved and final CZMP in place. New Development Plan 2034 looks at Aarey Milk Colony lands as an opportunity for creating large scale public infrastructure for the city. It proposes use of open spaces of Aarey for Metro III coach depot and for business activities. We object to this and recommend that open spaces of Aarey should be kept green and should be handed over to the Forest Department for protection. No construction or infrastructure activities should be permitted on these lands.The No Development Zones in the Development Plan of 1991 should be kept green and open and treated as forest lands.We recommend that natural areas like SGNP, Mangroves, Mud flats, Salt pans, hills and forest lands should be zoned as Green and no construction or infrastructure activities should be permitted on these lands.The Development Plan 2034 has considered only risk of flooding under Climate Change risks. Impacts of climate change should include all the factors like Sea level rise, Rainfall, increase in Temperature, extreme climatic events, earthquakes, etc. All new proposed projects must factor impacts of climate change in their proposals, and these need to be considered in depth by the Planning Authority. We depend on monsoon for water supply. There is no policy for recycling and reuse. Water recycling and reuse should be made mandatory for existing and new buildings. Water bodies such as ponds, creeks, streams, Lakes, River, Nullahs, bays and estuaries should be considered as green spaces. All waterbodies including their buffer zones must be clearly marked in the DP. The mandatory open space on the sides of water body must strictly be reserved as public open space, where no form of construction and or commercial activity be allowed.The Development Plan mentions about proposed Coastal roads for better transportation. The Coastal Road is illegal and needs to be scrapped. Instead of this there is a need to invest in up gradation of Public transport, especially Bus Rapid Transport and the suburban train network. The investments made on new roads are disproportionate and seems to be benefitting a tiny section of Mumbaikars. The MCGM should instead invest in increasing the frequency of the suburban train services and also by linking CST and Churchgate stations. The M.C.G.M. needs to plan and invest in better public transportation networks with emphasis on promotion of comfortable Public transport and higher investment in this sector. Further, the Singapore model for private road transport needs to be followed by restricting registration of private vehicles and adopting cordon pricing.Currently, Greater Mumbai’s environmental health is severely compromised due to increasing air pollution largely caused by vehicular pollution; increasing water pollution due to inadequate sewerage system and industrial pollution along with non-segregated garbage and plastic waste clogging drainage systems. Inadequate and poorly managed landfill sites are yet another cause of environmental pollution. The MCGM must discontinue the dumping of garbage on mangroves and mudflats and ensure that garbage is separated at source.We suggest MCGM undertake Risk assessments and Pollution assessment for the entire city before sanctioning new projects. We suggest that the MCGM examines the “Carrying Capacity” of the city before sanctioning new constructions.There are numerous errors in the draft DP wherein illegally reclaimed areas in Malad, Versova and Kanjur Marg have been shown as “buildable” or “commercial” areas. We would urge that all areas that have been illegally reclaimed should be restored back to their original condition, and not shown under “buildable” reservations.We suggest that the trees should be marked on the DP maps.We suggest that the CTS numbers be shown on the DP maps.We suggest that the Heritage Structures and Heritage Precincts be marked on the DP maps.We suggest that the HTL, LTL, 200 metre line, 500 metre line and the Hazard Line be marked on the DP maps.We suggest that the silence zones be marked on the DP maps.In view of the alarmingly high air pollution levels that our city has been witnessing lately, it is imperative to ensure that the new constructions do not adversely affect the air movements within the city. This parameter should be considered whilst approving new constructions.To ensure that renewable energy investments are not compromised, the MCGM should ensure that new constructions do not block the sunlight and the air movement on existing terraces.We suggest that the mobile towers be marked on the DP maps. Different colours/symbols should be allotted to different network providers.We would suggest that in case the MCGM continues with its policy to allow glass fronted buildings to come up, the builder and occupier needs to put special measures in place (such as the use of laminated safety glass that is used in automobiles) to ensure that the glass fragments do not cause injuries in the event of a disaster.We would strongly urge that the preparation of draft DP should not be outsourced to private entities and to retired officers since it is not possible to fix accountability and responsibility on these entities.We would request that we be given an opportunity to be heard so that we can elaborate on our written suggestions and objections. Yours faithfully, ==== -- Please send a blank email with "delete my id" in the subject line if you do not wish to receive our mails