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What went wrong with the Mumbai Development Plan? - I
Citizen Groups and NGOs have found many inaccuracies in Mumbai Development Plan. What was the process and what went wrong? The first part of a two part series
 
On 25 February 2015 the Report on Draft Development Plan – 2034 for Mumbai come into public domain for “consideration and constructive suggestions” as Sitaram Kunte stated in his covering letter to “Mumbaikars” published in the Report. Mr Kunte was the Municipal Commissioner of Municipal Corporation of Greater Mumbai (MCGM) also known as BrihanMumbai Municipal Corporation (BMC). Accompanying this was the “Draft Development Control Regulations - 2034” and 168 maps in pairs, one showing Proposed Land Use (PLUs) and the other, showing the governing Floor Space Index (FSI) in the new FSI Regimen. Time given to citizens was 60 days, which ended at closing hours of Saturday 25 April 2015.
 
Mr Kunte mentioned that in all about 50,000 suggestions and objections have been received, many of them common. He believed that the DP has been evolved following innovative approach and sound planning methodology and in its final form will be a historic document.

 
However, people found out to their horror that several glaring mistakes, like missing to mention two-thirds of Mumbai’s heritage structures, compromise in 4000-acre Aarey Colony’s open space and reclamation of 160 acres of land from the sea for the 34-kms coastal highway. The plan also proposed to increase the FSI substantially besides opening up south Mumbai for utilisation of transfer of development rights (TDR) as floating FSI. There was also a lack of clarity on issues like utilisation of FSI for housing society redevelopment and reduction in open space requirement to 10% from 15%, in contrast with a ruling by the Supreme Court. All this was proposed in the DP without even considering the existing physical and social infrastructure of Mumbai. So what went wrong with the draft? 
 
Sample Maps – DP-1991; ELU-2013 & PLU-2015 (Published)
 
Simple errors such as Babulnath Road Named correctly in DP-1991, changed to Walkeshwar Road in ELU-2013 and continued to PD-2015. Verification of DP-2015 needs to be done with respect to the DP-1991 and ELU-2013. There are some lacunae in the DCR-2034 as well as DP-2034. Identification and correcting them along with S&O received must be carried out diligently.
   
 
In preparation of this draft plan, MCGM has adopted different approaches.
 
Consultative Approach: The Maharashtra Regional and Town Planning Act 1966 (MR&TP Act 1966) requires that the draft plan once prepared, be published for inviting suggestions and objections. MCGM has gone beyond this legal requirement of planning on its own and has adopted consultative approach “in preparation of the Draft Plan itself”.
 
As a first step, MCGM published existing land use Plans (ELU Plans) and invited non-governmental organisations (NGOs) and Citizens to review the plans and point out any inaccuracies. Citizen Groups and NGOs found many inaccuracies at this stage; some important landmarks including Heritage ones, like Town Hall, Asiatic Society of Bombay, Mount Mary Church, Five Gardens and Bandra Railway Station, were wrongly depicted. In addition, the fact remains that citizens cannot necessarily find all the faults, given their limitations. If citizens were to verify correctness of the ELUs in all respects, question arises as to why the Consultants did not do a thorough verification and bring out correct documents. If they could make errors of important land parcels/ buildings in names and usage, confidence levels of citizens definitely gets lowered. It was hoped that MCGM would have got these rectified as they progressed to the planning stages.
 
Who prepared the ELUs? And thereafter, the Development Plans, Development Control Regulations and the Proposed Land Use (PLU) Plans and the Plans showing the new floor space index (FSI) Regimen? Did the MCGM have the necessary expertise and staff to carry out these functions? 
 
Carrying out Development Plan is a complex activity. It needs manpower to do the voluminous tasks of preparing the ELU Plans and verifying bit by bit; it is not merely a job of draftsmen. Accuracy of the ELUs holds the key to obtain accurate PLU Plans but that is not the only matter that determines well thought out DP. MCGM is to carry this planning activity once in 20 years, but did not have the manpower capable of doing the work without external help. This was obtained from an international consultancy firm, specializing in Urban Planning whose Indian setup is known as Groupe SCE India. Most of the persons who worked there were essentially Indians who had done some work as Urban Planners. One was Vidyadhar K Phatak, former (retired) Chief of Town and Country Section of Mumbai Metropolitan Region Development Authority (MMRDA) as Advisor. There could be no better person to understand Mumbai’s woes and then bring about a balanced overall Development Plan for Mumbai. For anyone reading through the document (Not the maps alone) and has open mind to the tools and philosophy used, will have no hesitation in agreeing that what it envisages as making an “inclusive, sustainable and competitive” of a city that appears to be on the decline.
 
Based on the ELUs and various data related to population, employment centres, transportation capacities and network and various relevant information, MCGM then published report “Preparatory Studies” that brought out the issues and challenges of making the Plan. Mumbai was divided into 150 planning segments under certain logical criteria. They did not keep it as large as the 24 Administrative Wards nor increase to 227 smaller Electoral Wards. The Municipal Commissioner then, on 29 November 2013 made a presentation to the NGOs, academics and concerned citizens as also the corporators giving gist of the Preparatory Studies, setting in motion the Consultation Process.
 
From the information obtained through RTI, it transpires that the Consultants had already submitted to MCGM the Draft DP-2034 for approval, before the consultative process had started. Going by this information, it appears that the “Consultative Approach” of MCGM was only a sham. One could also ask to the contrary whether what was submitted by the Consultants to MCGM was the “final” stage of the Draft DP-2034 or was it a Draft of Draft DP-2034? Until the Draft DP-2034 incorporates appropriate objections and suggestions and submits the DP-2034 in the final form to Government of Maharashtra (GoMAH) and get it approved, the current status of Draft DP-2034 remains, i.e. the Draft DP-2034/DCR-2034/PLUs/FSI Plans will come into operation and only in case there is a severity observed in DP-1991 in comparison, then the 1991 version will hold good till such date as the 2034 DP is approved fully. For example the Coastal Regulatory Zone CRZ) Notification 2011 will govern, which is what the DP-2034 is supposed to have followed with the exception of the proposed Coastal Road, for which Environmental Clearances are yet to be obtained. In the second part we will look at why the DP was dumped and whether the BMC can draft a fresh plan within four months.
 
(Sudhir Badami an IIT Bombay graduate in Civil & Structural Engineering is a Transportation Analyst. He has extensively worked in planning and design of Civil and Structural Works including tower building structures, stacks and process columns as well as flexibility analysis of piping systems and challenging erection planning of structures and equipment. He was on Government of Maharashtra’s Steering Committee on BRTS for Mumbai and MMRDA’s Technical Advisory Committee on BRTS for Mumbai.)

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