On March 13, the Maharashtra government unveiled its Climate Action Plan for Mumbai . The core team of this initiative includes officials and individuals from the Municipal Corporation of Greater Mumbai, the Maharashtra government, a United States-based non-profit think tank World Resources Institute, and the C40 Cities network.

The Mumbai Climate Action Plan aligns itself with national and international commitments to achieve net-zero emissions by 2050. To achieve this goal, it identifies six “action areas”: sustainable waste management, urban greening and biodiversity, urban flooding and water resource management, energy and buildings, air quality, and sustainable mobility.

It is encouraging that Mumbai’s planners finally recognise the climate crisis to be serious enough to deserve an official response. The question has now shifted: how serious are the actions proposed?

The Mumbai Climate Action Plan provides many useful recommendations for adaptation and mitigation, such as increasing the permeable surface in the city, conservation of existing green cover, equitable distribution of water, passive design guidelines for buildings, development of a Green House Gas inventory.

While these measures are welcome, many questions remain: how effectively does the climate action plan alter the city’s current planning and development paradigm? What was the role of ordinary citizens in determining its goals and proposals? How fundamentally does it aim to transform the conditions that have given rise to insecurities of the city?

Does it carefully review and evaluate the implications of existing plans and projects? Is it equitable in the distribution of the burdens and benefits of climate action? What does it include and what does it leave out from the scope of climate action?

In this article, we explore some of these questions.

1. Non-statutory, ‘expert’ driven

The Mumbai Climate Action Plan is based on an advocacy and project consultancy framework rather than being placed within the domain of statutory planning. This is a fundamental limitation, especially since its recommendations or proposals will not be legally binding, nor will the agencies involved be accountable to the public.

What this means, in practice, is that “climate action” will be left to the good intentions of bureaucrats, the commercial interests of green technology firms, and interventions of foundation-funded “experts” and non-governmental organisations.

The Maharashtra Regional and Town Planning Act provides wide-ranging powers to planning authorities to prepare comprehensive plans that subsume almost all the issues that concern the Mumbai Climate Action Plan.

Section 20 of the Maharashtra Regional and Town Planning Act allows the state government to modify regional plans if it deems necessary, while Section 38 allows the state to demand, at any time, modifying a Development Plan “either wholly, or the parts separately,” and if necessary, call for fresh surveys and new provisions.

Mumbai’s Development Plan, as it stands today, is antithetical to climate action, but the climate action plan only envisions piecemeal amendments to it. So the question is, why did the state government not call for a revision of the Regional Plan and preparation of a fresh Development Plan for climate action?

Furthermore, the Mumbai Climate Action Plan has been publicised as the initiative and extraordinary “leadership” of the current administration, rather than as a cross-party consensus. Suppose there is a change of government, what will stop the new administration from tossing it away?

Formulating a climate emergency plan requires a collective effort, through a deliberative consensus building process, rather than networking and partnering with a willing audience.

It will need to bring together opposition parties, administrators, local communities and civil society organisations based on the central principle of justice planning: a share in decision-making that is proportional to the impact on people and communities.

The Mumbai Climate Action Plan has been prepared, in its own words, through a “consultative and collaborative approach built on the contributions of several experts, CBOs [community-based organisations, research institutions and private consultants.”

Unlike statutory plans, there was not even the pretense of participation with the broader public, nor a call for “suggestions and objections” to its proposals.

In its language and recommendations, it presupposes that climate action is the domain of experts and officials, and citizens need to be made “aware” of climate action, “educated” about the various measures taken, and “sensitized” to adapt and cope with their own “vulnerabilities”.

Perhaps some day, planners and “experts” will begin to educate themselves about the reasons why so many people customarily resist their visions and plans.

2. Limited ambitions

The Mumbai Climate Action Plan aligns itself with national and international commitments to achieve net-zero emissions by 2050. Net-zero is defined as the offsetting of emissions generated in one place with emission reductions somewhere else, to ensure that the overall carbon dioxide level in the atmosphere remains stable.

The key assumption here is that it will be possible in the near future to develop technology to deliver negative emissions, or to adopt the much touted “nature-based solutions” to sequester emissions.

However, carbon removal technology is at best questionable; and on the other hand, there just is not enough land to sequester greenhouse gas emissions, even if we maximised the planet’s green cover.

As critical commentators have pointed out, net-zero targets are a facade used by the world’s biggest polluters and governments to disguise their actions and inaction on climate change.

By choosing this as the overarching goal, the Mumbai Climate Action Plan seems to imply that if all institutions and governments respect their net-zero commitments, and if Mumbai undertakes its “fair share” of emissions reductions, the most serious implications of global warming on the city will be averted.

This is an astoundingly naive starting point, both in the belief that net-zero is a worthy goal, as well as in the belief that everyone – even those outside the state government’s control – will faithfully carry out what they agreed to do.

And so, while the Mumbai Climate Action Plan prides itself on its “evidence-based” approach, it ignores the most compelling piece of socio-historical evidence: that the world’s most powerful institutions are unlikely to act contrary to their own material interests.

An adaptation and mitigation response for a coastal city-region that is home to 23 million people ought to be based on a careful assessment of the probability and severity of impacts due to runaway global warming.

Instead of beginning with anodyne targets agreed upon by those most responsible for the crisis, we need to face squarely and prepare for the various warming scenarios that are more or less likely to unfold over the next few decades.

3. Kicking the can down the road

The time-frame of 2050 allows the government to continue with its current proposals and plans, with a promise to mitigate and adapt in the future. It is glaringly obvious that the Mumbai Climate Action Plan has failed to undertake a comprehensive review of existing plans and projects in the city, or seriously consider their (still avoidable) impacts.

While the plan speaks of the virtues of public transport, infrastructure megaprojects that affect a behavioral shift towards private automobiles – such as coastal freeways, underground car-tunnels and sea bridges – are being executed in Mumbai at rapid pace.

The perils of projects that perpetuate, delay or prevent the transition to low-carbon alternatives, called “carbon lock-in”, are well known by planners. Unfortunately in the Mumbai Climate Action Plan, the planners do not take their own advice seriously.

The recently sanctioned Development Plan of 2034 opens up a large swathe of the city’s erstwhile No Development Zone areas, as well as increases the intensity of development across the city.

What will be the consequences of land use change and development intensity on surface temperature, or stormwater run-off? Metro projects, meanwhile, are being built over the city’s arterial roads, some of which could still be overturned in favour of bus corridors. The Mumbai Climate Action Plan assiduously avoids a critical review of current plans and projects, many of which are seriously maladaptive for the city.

It also fails to set in motion many common sense proposals that can be achieved in a short span of time at little cost. For years, transport activists have been demanding dedicated bus corridors on arterial roads in the city (to increase road space for public transport and reduce it for private automobiles).

The Mumbai Climate Action says that dedicated bus lanes can be built “where feasible” by 2040. Apparently, it takes longer for the government to set aside one lane on existing highways for buses than to build an entire metro system on them. Contrary to claims, it serves to persist and justify “business as usual” rather than shifting away from it.

4. The burden of climate action

Every project or plan produces net benefits for some groups and net costs for others. In an unequal society like ours, the burden of transformation is almost always borne by the poorest and most vulnerable. Therefore, any plan that claims to be “inclusive and equitable” ought to consider the distribution of benefits and burdens of its own proposals.

The market-friendly expert-oriented approach of the Mumbai Climate Action Plan will mean that for the city’s poor, climate action will be another justification for coercion and dispossession, while the wealthy will be encouraged to adapt through inducements and “incentives”.

For instance, the plan recommends remediation and conversion of landfill sites into parks, increasing vegetation cover and restoring natural drainage by removing “encroachments” (squatter settlements), and the rehabilitation of vulnerable communities to “safer locations.”

While these concerns are well-founded, almost each one of them will continue or exacerbate the threat of livelihood loss and displacement of the city’s low-income communities. Besides, none of these are deviations from the current planning paradigm, that victimises the poor in the name of environmental protection.

Tens of thousands of people in Mumbai depend upon informal waste management for their livelihood. Protection of green cover and river clean-up projects are almost always aimed at squatters and almost never penalise large institutions or real estate firms.

Slums next to high-rise buildings in Mumbai in June 2020. Credit: Reuters

If the Mumbai Climate Action Plan is a “plan”, as it claims to be, it would include at minimum a detailed survey of the areas affected by its proposals, an estimation of land required for alternative housing and employment, and the financial outlay for such a program. However, there are no such provisions in the “plan”. Instead, it simply lists the various agencies responsible for such actions and timeframes in which these need to be achieved.

Contrast this with progressive measures that would cause some inconvenience to middle and upper-class commuters. The Mumbai Climate Action Plan envisions electrification of 96% of private four vehicles by 2050 (that will presumably be powered by renewables).

But it proposes no stringent measures to control four-wheeler use (as is done in cities like Singapore), rather it offers “incentives” (such as reduced parking fees or installation of electric vehicle stations) that will affect the transition towards zero-emission vehicles.

The implications are clear. The Mumbai Climate Action Plan, in the coming years, will impose the heaviest burden of change on the city’s most vulnerable, while causing little or no inconvenience to the biggest polluters and profiteers in the city.

5. Restricted scope

Despite being backed by the state government, it is curious that the plan chooses Greater Mumbai as the spatial unit for analysis and recommendations, rather than the Mumbai Metropolitan Region.

As almost everyone understands, social-ecological systems, carbon emissions and climate impacts do not respect administrative boundaries. The restricted scope evades the extent of planned urban growth and environmental destruction outside Greater Mumbai limits.

Navi Mumbai’s new airport has been reported by environmentalists to have destroyed 1.6 square km of mangroves, four square km of mudflats, and 1.4 square km of forest area.

A signboard at the proposed site of Navi Mumbai airport. Credit: Reuters

But more importantly, the Regional Plan for the Mumbai Metropolitan Region, sanctioned as recently as May 2021, aims to increase the urbanisable land from the existing 800 to a staggering 1,336 square km – an increase of 538 square km – an area larger than the whole of Greater Mumbai. Much of this land is not legally protected by environmental laws.

Instead, it is classified as “scrub/wasteland,” a category that conveniently underplays its ecological value. Compare the silence around the Regional Plan’s urban expansion to the much publicised decision of the government to “protect” 3.3 square km of forested area in Aarey.

It is well understood that land cover land use change is a significant contributor to climate change, and such a massive urban expansion would be near impossible to justify as a part of climate action.

6. Limited mapping of ecology

The Mumbai Climate Action Plan points out that a Green House Gas inventory requires mapping various land use categories such as forest, grassland, cropland, wetland, settlement and barren land. Nevertheless, in a map titled “ecological landscape” (the only place where the city-region is pictured) it lists only three legend entries: water bodies, mangroves and forest.

This is a highly impoverished view of the city’s ecology, that only recognises legally “protected” areas as areas worthy of protection. Despite claiming to be a “science based” approach to planning, this betrays a legal-political view of the city’s environment, not a scientific one.

In some places, the climate action plan declares that Mumbai is an “an estuary,” but this is a metaphorical use of a technical term that cannot compensate for the absence of a systematic survey of the city’s diverse and complex ecosystems.

An estuary, incidentally, is derived from the latin word aestus which means “the tide”, and denotes a semi-enclosed body of water that extends to the effective limit of tidal influence. To be precise, the city – as a whole – is not an estuary, but there are undoubtedly estuaries in the city.

After mapping the coastline of the city, the Mumbai Climate Action Plan compares shoreline changes between 1990 and 2020 to observe the processes of erosion of beaches in the northwestern shore and accretion in the Thane creek.

It suggests that policies of the state government have been successful in conserving mangroves in Greater Mumbai. However, this is a selective account of the “facts” of erosion and accretion – as though these are purely “natural” processes – without analysis of the probable anthropogenic factors that have contributed to them.

A fair analysis of the Thane creek, for example, would not restrict itself to the boundaries of Greater Mumbai, but would have taken into account land cover changes in catchment areas of rivers and streams in the MMR that feed the creek. Perhaps such an analysis would have indicated that deforestation in upstream areas could have led to siltation, and reclamation of coastal areas contributed to erosion elsewhere along the coastline.

A map of the Mumbai region's ecological and urban landscape. Credit: WRI India

7. Underplaying sea-level rise

A serious concern in the Mumbai Climate Action Plan is its expectation of and therefore preparation for sea-level rise. It relies uncritically on the projections of the government-financed Intergovernmental Panel on Climate Change, which has a track record of being conservative on climate change intensity, threats as well as recommendations.

But it gets worse.

It nonchalantly remarks that “due to a lack of coastal data for the Mumbai coast, it is tough to establish [sea-level rise] as a current risk for the city”. This remark denies the danger of global sea-level rise on coastal cities. Furthermore, it has ignored the first premise of the climate crisis: that we cannot look at current and past trends to assess future risks.

Citizens during a “Global Climate Strike” march at Juhu beach in Mumbai on March 26. Credit: Reuters

Recent reports have raised serious alarm about warming in the Arctic and Antarctica, with temperatures touching 30-40 degrees celsius higher than seasonal norms.

Satellite data shows that we have the lowest sea ice extent on record since 1979. If the ice shelves in Antarctica weaken, it will expose the inland ice as well as warm the region faster, leading to rapid sea-level rise.

As a low lying coastal city, large areas of the city are under risk of permanent submergence. Even if we assume this as a low-probability scenario, the consequences are too high-risk to wish away. Any climate action initiative that does prepare for such an eventuality suffers from a potentially calamitous optimism bias.


In the name of an “evidence based” approach, the Mumbai Climate Action Plan grievously underestimates climate risk and the kinds of interventions needed to address the crisis.

Second, in the name of a “collaborative” approach, it constructs a project consultancy framework that lacks teeth to reign in the biggest polluters, and pins its hopes on the good intentions of powerful groups to deliver meaningful action.

Third, in its desire to be “scientific”, it remains a highly technocratic and expert-led process that fails to foresee the way risks and rewards of climate action will be distributed.

And finally, by beginning with an emphasis on “implementable” interventions, it restricts itself to the city and select “sectors” and leaves the regional context outside its scope of action.

But most importantly, the Mumbai Climate Action Plan represents an amiable response to a predictable trajectory of climate change, rather than an effort to comprehend and prepare for an unpredictable and potentially catastrophic climate emergency. As a result, its biggest shortcoming is a false sense of hope.

The authors teach at the Kamla Raheja Vidyanidhi Institute of Architecture and Environmental Studies, and are PhD researchers at the Indian Institute of Technology, Bombay.