Hi there all,
Many of you may not have been able to send a hard copy of your letter of Objections and Suggestions due to one reason or the other.. The Municipal Commissioner has said that he will consider all the emails too.. However, you will not be able get a receipt, but then PMC has to consider your letter and even invite you for the hearing.. (You dont have to go for this hearing..)
I am enclosing a draft letter of Objection & Suggestion to PMC. All you have to do is to forward this letter to :
"City Engineer" <prashant.waghmare@punecorporation.org>, "Town Planning Officer PMC" <tpo@punecorporation.org>, (Pl cut and paste the email ids onto the "To" window of your letter..)
Do remember to put yr name and address etc. on your letter
And do send a copy of your letter to: "Green Pune Movement" <greenpunedp@gmail.com>, so that we will know how many emails have been sent.. Thanks..
Please forward this letter to your friends and family.. We want thousands of emails to go..
Many of you may not have been able to send a hard copy of your letter of Objections and Suggestions due to one reason or the other.. The Municipal Commissioner has said that he will consider all the emails too.. However, you will not be able get a receipt, but then PMC has to consider your letter and even invite you for the hearing.. (You dont have to go for this hearing..)
I am enclosing a draft letter of Objection & Suggestion to PMC. All you have to do is to forward this letter to :
"City Engineer" <prashant.waghmare@punecorporation.org>, "Town Planning Officer PMC" <tpo@punecorporation.org>, (Pl cut and paste the email ids onto the "To" window of your letter..)
Do remember to put yr name and address etc. on your letter
And do send a copy of your letter to: "Green Pune Movement" <greenpunedp@gmail.com>, so that we will know how many emails have been sent.. Thanks..
Please forward this letter to your friends and family.. We want thousands of emails to go..
We must protect our Pune and improve the Quality of our Life.. All the best wishes.. Satish Khot
Remember to delete all messages above the line.
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From:
Address:
Email id: Tel. No.
To,
The Town Planning
Officer / City Engineer
Room No. 110,
First Floor
Pune Municipal
Corporation
Shivajinagar, Pune
411005
Sir,
We the undersigned
Citizens of Pune wish to put in our Objections and Suggestions in respect of
the following aspects in the Draft Development Plan for the old city limits of
Pune.
Please acknowledge
receipt of my letter and also please call me for the Hearing before the
Planning Committee..
1. RESERVATIONS
FOR ‘PUBLIC PURPOSE’
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Change of
Reservations - It appears that
several reservations that appeared for Public Purpose such as Gardens,
Schools, Playgrounds, Children Play Grounds, Hospitals etc. in the 1987
Development Plan have been deleted in the proposed Development Plan and now
converted to Residential or Commercial Purpose. Changes made by the
Administration and later through resolutions of the City Improvement
Committee and the General Body of the Municipal Corporation need to be
studied for the said purpose and the open spaces or public purpose reservations
as in the 1987 Plan be retained. Deletion of reservations is strongly
opposed.
However, where
such change is made from one 'Public Purpose' to another 'Public Purpose', in
keeping with the specific needs of the citizens of that area, and in the interest
of the city, only be allowed.
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Reservation
on Open Spaces of Housing Colonies
- It appears that the plots which were/are to be shown as ‘open spaces’ in
layouts of residential societies/colonies have been loaded with reservations
at the cost of deleting others in the 1987 Plans. It is ridiculous to do so
as the open spaces in the society's are meant for the purpose of its members
and the reservations under the Development Plan on plots are meant for use of
the all citizens. Both the open spaces and the reservations need to be
retained as so.
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2. ROADS
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Reduction in
width of Roads - Width of Roads as
in the 1987 Development Plan should not be reduced at any cost.
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Comprehensive
Mobility Plan - All roads must take
into consideration separate earmarked paths for pedestrians and cyclists. No
Flyover, Subway, grade-separators, sky-walks or any such infrastructure
should be constructed if it is not in conformity with the Comprehensive
Mobility Plan.
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Roads in
Ecological Sensitive Areas - Some
roads in the Draft Development Plan have been shown in ecological sensitive
areas such as River bed, Green belts, Hill Top Hill Slope Zones, Nallas,
along Canals, as tunnels through hills - All such development by way of
roads is strongly opposed. Intrusion of vehicles and increased human traffic
in this area will result in the loss of this important feature of nature and
loss of wild life, flora and fauna which needs to be preserved and conserved
for the ecological balance of the city and for the future generations. We
therefore vehemently oppose any development which is planned at the cost of
nature.
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3. HILL TOP HILL SLOPES
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‘HTHS Zone’
to be converted to ‘BDP
Reservation’ - Area above 1:5 gradient had been earmarked as ‘Hill Top Hill
Slope Zone’ in the 1987 Development Plan for the old city limit of Pune. The
Draft Development Plan retains the same status to this area. It is suggested
that the entire area be earmarked as ‘Bio Diversity Park Reservation’ as has
been done in the Development Plan for the 23 merged villages in the city of
Pune.
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CDAC Reports
to be made use of - The base data
for earmarking the said area should be the 1987 Development Plan and the CDAC
Reports. It appears that a substantial area in some parts of the Hill
Top Hill Slope area have been converted to Residential and this is strongly
opposed to.
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Restricted construction in areas that may be grandfathered - Where there exist old constructions and gaothans in pockets on the Hill Top hill Slope area, which may require to be grandfathered, it is suggested that they be designated as ‘BDP Sensitive Zones’ or any other appropriate term and construction in this area be restricted in terms of height and usage of FSI and appropriate provisions regarding the same be made in the Development Control Rules. |
4. GREEN BELTS
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The Green Belts
along the Rivers and Nallas appearing in the 1987 Development Plan seem to
have been deleted/ reduced to a great extent at several places. This is
strongly opposed and it is suggested that they be reinstated in the Proposed
Development Plan.
It appears that
Roads/ road widening are marked in Green Belts in the Draft Development Plan,
this is also strongly opposed to. The Green Belts should be earmarked as 'No
Development Zones' and no activity whatsoever except development of Parks,
Gardens or Urban Forests should be allowed on the same.
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5. RIVER, NALLA AND OTHER WATER BODIES
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It is shocking
to see that the Mutha River has been shown in BLUE color only in the
channelized section so also some of the Nallas are not appearing at all in
the maps. The Rivers and Nallas need to be shown as BLUE to the extent of the
'High Flood Level'. These are water bodies which constitute important
landscape of the city so also are channels to carry away water during Rains
and also carry the discharge of the Dams, thus protecting habitation along
the rivers and the city as a whole.
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6. TOWN PLANNING SCHEMES
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Wherever lands
covering large areas are being/have been converted from Agricultural Purpose
to Residential (eg. Sangamwadi, Mundwa, Pashan and Lohgaon), such conversions
should be allowed only subject to Town Planning Schemes made applicable so as
to make all amenities and Public Spaces available to citizens in this area
and the Municipal Corporation acquiring the same without any monetary burden.
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7. AIRPORT
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The Airport
being an Air Force base and even otherwise a sensitive area, is subject to
strict conditions pertaining development and constructions. The area of the
Airport is supposed to be enveloped by a buffer zone having a belt of width
of 100 meters of ‘no development’ and further a belt of width of 500 meters
of ‘restricted development’ (i.e. no high rise buildings). It appears however
that the Draft Development Plan has not earmarked these areas in keeping with
the requirements. This vitiates security of the Defense base and that of the
citizens and country in general. Such a change allows constructions and
development on several plots surrounding the airport which would otherwise be
banned. This is strongly opposed and the norms for the Defense base be
complied with.
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8. Floor Space Index (FSI) /FAR, TDR, PREMIUM AND CONCESSION
IN DEVELOPMENT CHARGE
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Excessive FSI - Reading of the Development Control Rules shows
that there has been an excessive shower of FSI to plots earmarked for various
purposes with absolutely no thought to the carrying capacity, existing
infrastructure and the health of the city and its citizens. The city is
already congested and is finding it difficult to take load of the existing
population with the present FSI, width of roads and population densities. We
strongly oppose the arbitrary and excessive FSI accorded.
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TDR and
Premium - It further also appears
that there is no study or scientific reasoning for distribution of TDR and
according construction at a Premium. We acknowledge that it is necessary to
compensate development of certain sectors however there needs to be a proper
study to ensure its proper distribution, density, burden on infrastructure
and in case of Premium the proper use of funds generated.
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Concession in
Development Charge - The concept of
providing TDR / payment of Premium / concessions in Developmental Charges in
lieu of construction of Road etc. will have to be studied in depth by the
Planning Committee to ensure that it is not excessive and that there is a
monitoring system to ensure that there is no misuse of the same. A proper
plan for the release of TDR (and acquisition of reservations) should be drawn
so as to do away with monopoly of some developers - the same be monitored by
a committee to ensure its proper and equitable release
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9. DEVELOPING RESERVATIONS
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Allowing the owner to develop Schools, Hospitals, Fire Brigade Stations reservations partially and in turn getting permission to construct for himself on the said plot and further being allotted additional TDR as per the provisions in the Development Control Rules, amounts to defeating the very purpose of Development Plans under the MR&TP Act, and hence this is strongly opposed to. The plots should be developed only for the purpose that it is reserved for and no other. |
10. PROTECTION OF NALLAS and CANALS
TDR FOR ROADS OVER NALLAS and CANALS and other reservations
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PrimMove – In the past PMC got nallas and streams of the
city mapped by PrimMove Infrastructure Development Consultants Pvt. Ltd.,
however the findings do not find place in the Development Plan. Considering
the disasters in the past due to filling up of nallas or diverting them to
suit the developers, it is utmost necessary that they must reflect in the
maps and further strict clauses be incorporated in the Development Control
Rules in that respect.
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No TDR for
areas falling under Nallas and Canals
- It is learnt that there is a proposal that a TDR be given for roads that
have been built over Nallas and Canals. We object to the same. No TDR should
be given at any cost for the parts on which roads have taken place as this
was and is a 'no development zone' and hence there can be no transfer of
development for areas which never had construction potential.
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Proportion of
TDR - TDR must be awarded only to
the extent the land/plot is developable as in the Development Control Rules
of the 1987 Development Plan.
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11. WATER BODY AT DHANORI
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The water body
at Dhanori is a massive lake with active springs and as such has water in it
all round the year. It is shocking to see that the General Body of the
Municipal Corporation has recommended that TDR to the extent of 1 be given to
the owners for the same. This and such proposals smell of vested interests
and utter dismal vision of the Planning authority. There can be no TDR for an
area that is not developable and hence there is no question of any TDR
whatsoever.
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12. SPECIAL ECONOMIC ZONE (SEZ)
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The Draft
Development Control Rules pertaining SEZ, mentions relaxation of conditions
regarding construction that are otherwise applicable to Hill Top hill Slope
Zones (now suggested to be made BDP) and Green Belts. This is strongly
objected to. We suggest that no construction whatsoever should be allowed in
the ‘no development zones’ that may fall in the SEZ. So also TP Scheme be
made applicable to the SEZs.
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13. METRO CORRIDOR
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FSI 4 - Floor Space Index of 4 is strongly objected to along all routes of the Metro Corridor as this would result in breakdown of existing infrastructure and add on to the density and population in the city manifold. It is ridiculous that the Rules mandate ‘compulsory’ utilization of the FSI. Some of the major Educational Institutes in Pune having heritage buildings fall within this corridor and as such making this provision applicable to it would spoil the scape of the city and the purpose redundant. |
DMRC Report - The Financial Internal Rate of Return (FIRR) as mentioned in the DMRC Report mentions total Revenue of Rs. 44048 crores (over a period of 36 years) comprising of
Rs. 17291 crore
from fare box revenue,
Rs. 24756 crores
from Property Development and Advertising revenue
and only Rs.
2000 crore from sale of additional Floor Area Ratio (FAR) along ‘both’ the
corridors.
.The DMRC Report itself has recommended options such as levy of –
Professional Tax
@1% of the Salary of Employees,
Cess on petrol
and diesel sale in the city,
Surcharge on the
property tax in the city,
surcharge on
motor vehicle tax,
Entry tax on all
commercial articles entering the city”,
(Reference :
Chapter 12 – Financing Options, Fare Structure and Financing Viability)
It is submitted
therefore that the DMRC Report does not envisage this kind of FSI along ‘all’
the Metro Corridors. So also to get revenue of only Rs. 2000 crore it is
ridiculous to give FAR/FSI of 4 for total length of ‘all’ corridors.
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Route – the Metro alignment is shown to pass Bhamburda
Caves and Aga Khan Palace which are protected monuments and hence it is not
clear how the administration will get clearance for the same.
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14. NEWSPAPER REPORTS AND NON COMPLIANCE WITH NORMS AND
GUIDELINES
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As seen from the
maps and through reports of several newspapers there is substantial reduction
in reservations vis a vis the 1987 DP. Considering the fact that the
reservations are already short of the various urban planning norms and
guidelines, laid by the government and other agencies from time to time and
further considering the fact that the growing populations will further reduce
this ratio. Dereservations, detrimental to the sustainable development of the
city, should not be allowed at any cost whatsoever.
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15. INCONSISTENCY IN THE ELU and PLU MAPS AND OTHER
SUGGESTIONS
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The Existing
Land Use and the Proposed Land Use Maps have serious flaws and mistakes. We
find no connection whatsoever between the stated vision in the report, the
various studies on demography, housing and transportation and the Development
Plan and DC rules. Some important issues in this behalf:
SLUMS
Pune dreams of a
“Slum Free City’ and it is our vision to provide affordable housing to the
middle class and the poor. No such attempt seems to have been made in the
present Development Plan. The reservations for the EWS, Housing for LIG, MIG
should have reflected in sufficient reservations for the EWS, however, this is
missing in the Plan.
CLUSTER
DEVELOPMENT
The proposed
Cluster Development in the core city of Pune will spell destruction of the
very character of the city and destroy its rich heritage and remnants of
ancient history.
DC
RULES
The Draft DC
Rules are difficult to understand and should have been ideally providing a
comparison with the existing rules, with a note justifying the change in the
rule. The DC Rules do not therefore exhibit any structure and appear
piecemeal and arbitrary.
The Draft
Development Plan incentivizes construction of Hotels, Hostels, Parking
structures, and further for the owners hospitals, schools, fire brigade
stations on their own land in lieu of allowing residential or other
construction in the said land and further an additional TDR. All these seem
to be arbitrary and without any thought and consideration.
GARBAGE/BIO
MASS AND DEBRIS DISPOSAL
Segregation at Source must be absolutely mandatory for all. Hence strict
implementation of the Supreme Court Order will be followed whereby only
segregated waste will be collected and unsegregated will be rejected.
Modernisation of Solid Waste Management must be undertaken and
waste collection by hand must be minimised. Disposal of garbage should also
be undertaken by more modern proven methods like Pyrolysis etc..
A proper system for Plastic waste must be implemented. Electronic
and Hazardous wastes should be collected by agents authorised by MPCB. About 100 tonnes of debris, which includes concrete,
bricks, cement plaster and iron, is generated in Pune every day. And are
usually disposed off on hills, riverbed or along water bodies. It is
therefore utmost necessary that the city should have a comprehensive policy
for debris disposal as per norms laid down by the urban development
department (UDD) of the Central Government.
RAIN
WATER HARVESTING AND GREY WATER RECYCLING, OTHER GREEN MEASURES
Considering the
impacts of Climate Change, drought situation, depleting ground water and in
general the paucity of water it is necessary to make Rain Water Harvesting
and Grey water recycling compulsory by making appropriate provisions in the
DC rules.
WOMEN,
SPECIALLY CHALLENGED, SENIOR CITIZENS AND CHILDREN
Considering that
urbanization is taking place at a very fast pace it is necessary to make sure
that attention is given to ensure safety, convenience and provision of
appropriate infrastructure for the benefit and convenience of the
women, specially challenged, senior citizens and children in the city.
HAWKERS ZONES
Neither the
Development Plan nor the Development Control Rules show that there has been
due consideration given to the Hawkers and small time/ Street Vendors in the
city. Not only do they constitute a large number whose means of livelihood
depends on sales of their goods but their services form an integral part of
the needs of the people. The Hawkers Zones if properly placed also provide
for safety for the pedestrians who may be vulnerable to safety issues.
SAFETY AND SECURITY
Pune is a city
that is vulnerable to terrorist and other attacks. It is necessary to take
vital steps to ensure security by special regulations for security as has
been suggested by the State Government, which include among other measures
security outposts, fire-safety requirements and buildings with
blast-resistant designs. Neither the Development Plan nor the Development
Control rules suggest that enough steps have been taken in the direction.
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Hi, Its a very good awareness blog to make make a better city to live in.Could you pls mail me the copy of draft development plan of Pune(including lohegaon airport area),I need to study it and mail the above mentioned people,as I could observe the illicit constructions that are coming up in that area. email ID: kprasad15@gmail.com
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