Old Pune Development Plan — Suggestions+Objections

The Draft of ‘Suggestions and Objections’ with respect to the Draft Development Plan of Old Pune, as commonly agreed upon by experts.

1. Page
1
To,

The Town Planning Officer/City Engineer
Room No. 110, First Floor
Pune Municipal Corporation
Shivajinagar, Pune 411005
DATE – JUNE 2013
Sir,
We the undersigned Citizens of Pune wish to put in our Objections and Suggestions with respect to the following
aspects in the Draft Development Plan for the old city limits of Pune.
1. RESERVATIONS FOR ‘PUBLIC PURPOSE’

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 societies 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.
2. ROADS

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 wildlife, 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.
3. HILL TOP HILL SLOPES

‘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.

2. Page
2
4. GREEN BELTS

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 proposed 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.
5. RIVER, NALLA AND OTHER WATER BODIES

It is shocking to see that the Mutha River has been shown in BLUE color only in the channelized section, as 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.
6. TOWN PLANNING SCHEMES

Wherever lands covering large areas are being/have been converted from Agricultural Purpose to Residential (eg.
Sangamwadi, Mundhwa, 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.
7. AIRPORT

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.
8. Floor Space Index (FSI) /FAR, TDR, PREMIUM AND CONCESSION IN DEVELOPMENT CHARGE

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 appropriate 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.
9. DEVELOPING RESERVATIONS

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

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

3. Page
3
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.
11. WATER BODY AT DHANORI

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.
12. SPECIAL ECONOMIC ZONE (SEZ)

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.
13. METRO CORRIDOR

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.
14. NEWSPAPER REPORTS AND NON COMPLIANCE WITH NORMS AND GUIDELINES

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

4. Page
4
growing populations will further reduce this ratio. Dereservations, detrimental to the sustainable development of the
city, should not be allowed at any cost whatsoever.
15. INCONSISTENCY IN THE ELU and PLU MAPS AND OTHER SUGGESTIONS

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
Area should be allotted for the collection and segregation of garbage at ward level and its disposal by means of bio
methanation, vermicomposting or other methods at several areas in the city so as to take care of the disposal of
garbage. Electronic waste is a matter of concern and needs to be addressed by providing collection areas for the same.

About 100 tonnes of debris, which includes concrete, bricks, cement plaster and iron, is generated in Pune every day.
Till date dumping sites are not identified hence it is 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 areas 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.
SIGNATURE CONTACT NO:
NAME
ADDRESS