This was given to me by a like- minded friend- I have read through it and it appears ok.
To,
Date:
The Chief Engineer - Development
Plan
5th Floor, Municipal Head Office,
Annex Building
Mahapalika Marg, Fort, Mumbai-400
001
Subject: Suggestion /Objections and
Request for Hearing for the Proposed Draft Development Plan for Mumbai 2014-34.
No. ChE/32596/DP/GEN/dtd 25.2.2015
Dear Sir,
We have taken studied the proposed
Draft Development Plan and we list our Suggestions Objections as stated below.
FSI -
We note with concern that FSI has been increased to a base of 2.5 with a
maximum of 8.This huge leap will see further densification in already crowded
areas. There is no proportionate increase in physical and social infrastructure.
Most existing roads are not wide enough to carry the load of this
increasedFSIand will lead to further traffic congestion
Suggestion
- An increase in FSI by even 1 implies that the entire footprint of the city
has been doubled. Hence there should be subsequent doubling of open spaces,
health care, education, water supply and sanitation facilities etc. Higher FSI should be allowed only to the plot
abutting the required road width provided all other amenities are provided for.
The increase in FSI will not
necessarily mean affordable housing as majority of the city's population lives
in slums or small tenements. The proposal to reduce the existing reservation of
20% of area for EWS housing to only 10% will bring no relief to this section.
Further the demand for housing, apart from EWS, is for smaller apartments like
1BHK or 2BHK. This blind increase in FSI throughout the city will only lead to
an increase in built up area in the higher income and luxury segment.
Suggestion
- Maintain the reservation for EWS at 20%. . FSI should be based on the
existing population density of each area. Further, steps should be taken to
ensure that each planning sector has a percentage of housing for smaller ,
affordable apartments.
InfrastructureThe
standard for educational and health facilities have been reduced. There was a
need to increase this,not diminish the ratio. Schools which have come up in the
past couple of decades do not have sufficient area for playgrounds. Whatever is
available is concreted to double up as a parking space for school buses.
Children spend a major part of 15 years in schools. Lack of open spaces in
educational institutions affects theirhealth and growth.Affordable health
facilities too are minimal. Most multi speciality hospitals are too expensive
and smaller ones are crammed into apartments in housing complexes. There needs
to be dedicated space for these two amenities.
Health Amenity
standards are reduced to 0.385sqm per person from 0.83 -1.28sqm per person.
Suggestion - Provision of adequate health care facilities
is the duty of the local government and hence reservations specifically for
municipal dispensaries/swasth chowky, municipal hospitals and municipal trauma
centres should be demarcated in the proposed land use.
Education: Education Amenity standards are reduced
to 1.37sqm per person from 3.58sqm per person.
Suggestion - Provision of adequate primary educational facilities is the duty of the local government and hence reservations specifically for schools should be demarcated in the proposed land use.
Ensure each school has a playground accessible to all children during the day and evenings. Covered play areas can be counted. The overall provision should be 2sqm/capita of population.
Suggestion - Provision of adequate primary educational facilities is the duty of the local government and hence reservations specifically for schools should be demarcated in the proposed land use.
Ensure each school has a playground accessible to all children during the day and evenings. Covered play areas can be counted. The overall provision should be 2sqm/capita of population.
FSI for Open Spaces. There is no need to provide FSI
of 3.5 for areas marked as open spaces. This will lead to possible misuse in
the future. This should be reduced to an absolute minimum. Such spaces only
require basic facilities like toilets or a basic office.
Open Spaces- The ratio of open spaces provided is
dismal. Traffic Islands,
Intertidal areas of beaches, promenades, private layout RG (Cusrow baug) are
included in public open spaces. Natural areas such as Mangroves, Mud Flats,
National Parks, Creeks, Private Gymkhanas, Swimming Pools etc. are clubbed with
the available Open Space to meet
standards. This is trickery with number. Large urban green inaccessible
areas such as Raj Bhawan, Doongarwadi (Tower of silence), JJ Hospital, BARC,
TISS, Aarey colony, Film city, KEM Hospital, Nehru Science Centre, AAI
receiving station, IIT are proposed to be made accessible and counted under
open spaces.The layout open space in residential development has been reduced
to 10% as against DCR 23 of the DP 1991, which suggests RG of 15% to 25%.There
is a further diminution of open space available to the public as the parking
areas, electric substations, storage of harvested rain water, grey water
harvesting plants, sewage treatment plant etc. are permitted below open spaces
in residential development. (The DCR 1991 was amended to state that parking
spaces and basements are not allowed under reservedOpen Space).
Suggestion - Health benefits of green spaces are clearly
proven, particularly for the lower income groups. The DP should have a clear
strategy to increase actual, usable open spaces.There must be at least one
small park (between 500 and 1,000 sq. m.) within 500m of every residence, and
at least one large park (exceeding 1,000 sq. m.) within 1 km of every residence
in the city. Layout open spaces in residential development should be clearly
marked and existing 15%-25% should be maintained.
Aarey Milk Colony-Aarey is shown to be a Residential Commercial zone with plans to make it a major growth hub.
Aarey Milk Colony-Aarey is shown to be a Residential Commercial zone with plans to make it a major growth hub.
Suggestion - The no development zone designation of
Aarey should be made further stringent and be marked as a centralprotected
green area or as open space.
NDZ areas.
It is alarming that nearly 17000 acres of NDZ areas are set to lose this
status. These are ecologically sensitive areas and important as a defense
mechanism to natural calamities and greatly contribute in ecological services.
Areas like Madh island, creeks, mangroves, mudflats etc are very important
assets of Mumbai
Suggestion - All NDZ areas should be protected and if
opened then only be proposed as openspaces
Heritage
Structures -
The Draft Development Plan (DRDP) 2014- 2034 is an attempt to delete protection
of nearly 1000 buildings, sites and precincts i.e. 70% of the about 1488 total
listed and published heritage buildings, sites and precincts in Greater Mumbai
through an act of omission.
Out
of 1995 notified list, one third of the heritage structures including Grade I,
II, III sites and precincts are missing from the land use plan. 116 buildings,
sites and precincts have been deleted and 35 buildings, sites and precincts
altered from the 1995 Notified List of 633 buildings, sites and precincts .DRDP
further deletes all of 7 Textile Mill Heritage buildings, sites and precincts
from the 2002 Notified Addition, 24 Agiary Sites from the 2002 Notified
Addition of Parsi Fire Temples in Greater Mumbai and 7 precincts including
Marine Drive precinct deleted from April 1995 published addition. Almost all of
the 894 Sites are missing from the Proposed Heritage list published in July
2012.
The
SDCR regulation will be applicable to only those buildings as marked on the
Land Use plan according to SDCR 6.1. This would mean that if there is an error
in display of heritage site on the Development Plan sheets it would
automatically mean deletion of reservation under heritage structure.
Suggestion - Incorporate all the listed Heritage
Buildings and precincts in the Development plan and show the mandatory 100 M
regulation zone near all the Heritage Sites on the PLU. The proposed new
Heritage List should also be incorporated.
Grade
I and Grade III and Precincts have been completely removed out of the purview
of the MHCC.
Heritage precincts and sites from Grade III have been allowed redevelopment up to 30m in the Development plan without the approval of the MHCC. This would virtually destroy all the heritage precincts in the City.
Heritage precincts and sites from Grade III have been allowed redevelopment up to 30m in the Development plan without the approval of the MHCC. This would virtually destroy all the heritage precincts in the City.
Suggestion - All Heritage structures, be it Grade I, II,
III and the precincts, should be demarcated in the PLU and the redevelopment
should be only done with the permission of the MHCC. The 30m height is
arbitrary and will destroy the nature of the heritage precinct.The Heritage list should be incorporated in
the SDCR document. All building modification/development permissions should be
referred to the Heritage Committee and the Municipal Commissioner should take
due note of the recommendations.
Safety -Marginal setback as mentioned in section 18.3.1 allows set back
of only 3 m for building height 70 m and above. These high-rise buildings will
not allow fire engine movement around the building during disaster.
Suggestion
- Minimum set back of 9m on ground
should be given on all 4 sides to ensure fire safety for high-rise buildings.
This should be provided irrespective of other mandatory fire fighting equipment
to be provided in high rise buildings.
We will further supplement our issue
with data at the hearing. We request you to consider our Suggestions/Objections
and grant us a hearing at the earliest.
Yours sincerely,
Name-
Address
Phone
Email
No comments:
Post a Comment