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Tuesday, June 25, 2013

Emailing Letter of Objection & Suggestion to the proposed DP for old city limits

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" <>, "Town Planning Officer PMC" <>, (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" <>, 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.
Email id:                                    Tel. No.
The Town Planning Officer / City Engineer
Room No. 110, First Floor
Pune Municipal Corporation
Shivajinagar, Pune 411005     
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..

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.

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.

Reduction in width of Roads - Width of Roads as in the 1987 Development Plan should not be reduced at any cost.

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.

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.

‘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.

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.

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.


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.

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.

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.

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.

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.

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.

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

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.
TDR FOR ROADS OVER NALLAS and CANALS and other reservations

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.

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.

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.

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.

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.

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”,

(in addition to “developing and leasing 10.4435 Ha land from Property Development with FAR of 4 on plots for projects for commercial exploitation to yield income of Rs.600 Crores from development and Rs. 23899 Crores over a period of 33 years from leasing the property, as mentioned in FIRR above)

(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.

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.

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.

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:

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.

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.

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.

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.

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.

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.

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.

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.

1 comment:

  1. 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: