The Development Plan for 2014-2034 prepared by the Municipal Corporation of Greater Mumbai, will shape the city over the next 20 years. After the furore over the city’s previous Draft Development Plan, released in February 2015, the state government put it under review and directed the Municipal Corporation of Greater Mumbai, the city’s civic body, to correct its numerous “errors.”

The civic body appointed Ramanath Jha, a retired bureaucrat, as an Officer on Special Duty to oversee the process. After a year, the Revised Draft Development Plan has been released, inviting suggestions and objections from the public. The response in the media so far has been tepid, and one might be tempted to assume that this time the draft is better. But the opposite is true.

Back to 1991

In the name of correction, the Development Plan has retained the approach and many of the proposals of the 1991 Development Plan including amenity reservations, road proposals, land use zones, and it's highly loopholed Development Control Regulations. Almost all of the more potentially progressive ideas of last year’s draft have been dropped. The new ideas include an ambitious “affordable” housing scheme, and a new approach for developing the city’s No Development Zones.

After the year-long revision exercise, the Development Plan has produced no creative approaches for the city’s informal housing and livelihoods, little thinking about improving access to basic health and education, negative progress in terms of building controls, some aspirations about making public transport attractive, and some ingenious ways of showing more amenities than will ever get realised.

Creative semantics and planning arithmetic

The biggest innovations of the revised Development Plan are related to semantics and arithmetic. How does the plan show an increase in public open spaces in a land-scarce city? By simply changing its definition.

So now, spaces between buildings, community spaces, gymkhanas, swimming pools, open areas of educational institutions, school grounds, golf courses, flowerbeds below flyovers, promenades, beaches and newly proposed buffers along drains will all be counted as public open spaces. In some places, the report even sounds eerily like a project pitch. Sample this excerpt from the report:

“Permeable pathways in some mangroves...will serve a double purpose of keeping a watch on mangroves so that they are not the same time, it would be an exhilarating experience to walk along their edge.”

Similarly, we must now consider shopping centres and film studios as “social amenities” and call something a No Development Zone while defining it as land that is “potentially developable”. We can also reclaim land from an eco-sensitive zone for an park and call it a “green reclamation”.

While the new Development Control Regulations painstakingly define yogalayas (fitness centres) and malls, highly contested concepts such as Affordable Housing or public purpose are left to the fancy of civic engineers.

Further, while designations meant existing amenities that are retained for the next plan period, it is now narrowly defined in the new Development Plan as amenities that were “provided or aided by an appropriate authority on a parcel of land.” Therefore, amenities that were not proposed or designated in the 1991 Development Plan but were produced on private land have not been designated. Planners have widely acknowledged the failure of the implementation of the 1991 plan. Why, then, would the civic body further deprive the city of amenities that were produced outside it?

But the shortfall of amenities, it seems, should not worry us too much. In an incredible paragraph titled the “impact of technology on education”, the Development Plan promises that broadband technology will transform the “manner in which [students] are taught.” Students can now learn faster, and “need not attend school on all days” but may “congregate, say twice a week for interactive face to face sessions.”

What we need, it implies, is not educational facilities, but broadband.

Abandoning the positives of the earlier plan

For all its problems, the earlier draft Development Plan initiated some useful ideas – one of which was the sub-division of the city’s administrative wards into smaller Planning Sectors to facilitate decentralised planning. Another important proposal was the identification of areas for second-tier planning through Local Area Plans, which could have allowed for a more comprehensive and detailed planning for some areas. The earlier draft also proposed variable Floor Space Index zones, designed to enable higher densities near mass-transit nodes. This integration of transport and land use planning is called Transit Oriented Development.

These ideas were far from perfect, and were criticised for being insufficiently developed. However, instead of doing away with them completely, all of these could have been improved. Planning Sectors could have been made to coincide with the city’s 227 electoral wards, Local Area Plans could have been expanded to include more areas, and Transit Oriented Development could have been better regulated to prevent overcrowding.

In scrapping these, the Development Plan ensures that the civic body will continue to work with administrative wards – each of which have a population of a medium to large size town. It also advocates a single redevelopment approach towards the city’s incredibly diverse informal settlements, and an opaque and fragmented FSI regime that makes planned provision of infrastructure and services impossible to anticipate.

The revised Development Plan also reinstates in form and substance the 1991 Development Control Regulations that have devolved over 25 years through periodic exemptions and modifications, all pushed through by the state government. The new plan caps FSI at 2 in the entire city, but exemptions are made for redevelopment schemes, where FSI and Transfer of Development Rights are awarded as an incentive to allow higher intensity of development.

As a result, FSI values are dislodged from land and are determined based on multiple factors. This makes it difficult for planners to anticipate how much development is likely to take place in a certain area, thereby making it impossible for them to plan adequate physical and social infrastructure and services. Further, since areas such as slums, properties under the Mumbai Housing and Area Development Authority and cessed buildings are targeted for redevelopment, incentive FSI goes to these already high density areas, resulting in a severe deterioration of living conditions and overcrowding, and an unanticipated strain on infrastructure and services.

To add to this, the new draft Development Plan proposes to adopt highly compromised environmental norms (regulated through building setbacks, marginal open spaces and building height restrictions) of the Slum Rehabilitation Authority for all redevelopment projects in the city under the notorious regulation 33 of the Development Control Regulations, which provides FSI exemptions.

Worsening the negatives of the earlier draft

Despite their differences, both the earlier draft and revised draft Development Plan fail to evaluate the social consequences of increasing FSI, mainly due to the highly iniquitous consumption of floor space in the city. Both plans look at offering a higher FSI in high-density areas – the first through high FSI zones along transit corridors and inner city areas, and the second by using FSI as a fiscal mechanism.

Both aim to promote urban renewal. While the earlier plan made an abstract economic argument, the new draft decides to continue the now-artful process of responding to political and electoral pressures by offering concessions to real estate interests. And both are based on the economics of land, with the value of land being the driver of urban development – for the creation of housing, employment, physical and social infrastructure.

And while the revision process was set up to sort out the errors of the earlier draft, the maps in the revised plan are riddled with absurdities.

For example, proposed six-lane highways terminate abruptly on beaches and other natural areas, streams disappear into amenities and reappear as segments somewhere else, and open space buffers run deep into mangrove forests, cutting off them off from their water channels. Roads and amenities imported directly from the 1991 plan end up on natural areas and encumbered plots – making it highly unlikely that these will ever be achieved as planned.

New ideas and proposals

The revised Development Plan brings back the concept of No Development Zones that had been done away (in a planned manner) in the earlier draft. Under the new plan, land owners who can assemble four hectares of No Development Zone land will be allowed to develop it. In return, they will have to set aside land for amenities and affordable housing for the city. The vagaries of the market will determine how and where these new development areas will come up.

However, several areas identified as No Development Zones in the 1991 plan are natural and semi-natural areas, and home to urban villages, informal settlements and a range of primary occupations. The new plan disregards these existing uses and chooses to treat these areas as vacant sites. Proposed roads cut through No Development Zone areas and run over settlements and villages as though they do not exist. In other words, the new draft has rendered the Existing Land Use survey maps, much criticised for their errors, irrelevant. So much for correcting errors.

And then comes the big idea of building 1 million supposedly affordable housing units, on about 1,500 hectares of No Development Zone lands, salt-pan lands, Mumbai Port Trust land and other areas.

Mumbai already has 2.66 million households and is projected by the revised plan to have 3.19 million households in 2034. This suggests an increase of 0.53 million households, about half of what the revised plan pegs as the housing demand. Furthermore, the affordability of a house is determined not just by its size, but also by household incomes and location-specific factors such as access to public transport. But these vital questions are quietly bypassed. What is proposed seems to be more as units for investment, of great value even when they lie vacant. Curiously, while the revised Development Plan pleads administrative incompetence for undertaking Local Area Plans, it ambitiously declares its intention to enter the housing sector.

Equitable city?

Like any other activity, informal work requires infrastructure – land, built spaces and services – to function and thrive. An estimated two-thirds of Mumbai's workforce is employed in the unorganised or informal sector. Yet, in what could be considered nothing less than planning alchemy, the revised plan proposes formal commercial space for the city’s entire eight million workers. Clearly, this has nothing to do with employment creation, and is a lopsided justification for increasing FSI in commercial zones.

Street vending is an occupation that provides employment to about 250,000 people in Mumbai. The Development Plan has no conception of how spatial provisions or street design guidelines can be made for this crucial source of livelihood. So far, street vendors do not exist in the spatial imagination of urban planners. They are excluded twice – first from the city’s formal economy, then from its spatial plans.

The revised plan aspires to adopt a “cafeteria approach” for slums, but it remains a cafeteria with just one item on the menu. A range of possible development options for slum dwellers is desirable, but they continue to be excluded from the Development Plan and left to the state government’s parastatal agency, the Slum Rehabilitation Authority. The free housing scheme of the Slum Rehabilitation Authority pushes slum dwellers into a corner of the land they occupy, and free up land for private developers to build super-towers for those who can afford them.

However, around the world, the most effective programmes of reducing housing poverty has been a combination of tenure security – assuring slum dwellers that they will not be evicted – with in-situ upgradation and improvements, but the development plan precludes this approach. Learning from settlements in Brazilian cities, slum areas could be delineated as “special zones for social interest” as areas free of evictions and destined in their entirety for the housing, livelihood and amenity needs of slum dwellers.

Pressure groups and plan revision

On June 17, 20 days after the revised Development Plan was published, the Municipal Commissioner Ajoy Mehta delivered a talk at a conference organised by the Practicing Engineers, Architects and Town Planners Association. For the uninitiated, this is a powerful lobby aligned ideologically and professionally with the city’s developer groups, with close links to the building and planning departments of Mumbai’s civic body.

One would assume that the intimacy between real-estate interests and city authorities flourish only behind closed doors. Hence, the unabashed public display of affection was quite captivating. In their presentations, speakers from Practicing Engineers, Architects and Town Planners Association “saluted” the civic body for their revision work, and the 3,500-strong audience of architects, developers and engineers applauded every deregulation and incentive the new Development Plan proposes to bestow on the building industry.

The association was grateful to the corporation for reducing “hardships” for developers, and for upgrading, instead of altering the 1991 Development Control Regulations. After one year of “continuous” engagement with the Development Plan revision process, the association was confident that the new plan will “not be scrapped.” The municipal commissioner, in his spirited talk, even “put on record” the close consultations with Practicing Engineers, Architects and Town Planners Association, whose “inclusiveness” made it seem to him “almost like a people’s movement”!

It is obvious, that to have real-estate interests play a prominent role in framing regulatory policies for development is akin to having poachers set the ground rules for game-keeping. The Development Plan proposes to increase its reliance on developers and land-owners to achieve public amenities for the city. Planning instruments are oriented single-mindedly towards incentivising the private sector to achieve social goals.

The government’s welfare commitments, as a result, are increasingly entangled with the interests of land owners and property developers, making it a participant, not regulator, of the city’s real estate growth coalition. The revision process is another opportunity lost for Mumbai. It seems that pragmatism and viability, not equity and priority, will drive the city’s transformation over the next 20 years.

Hussain Indorewala and Shweta Wagh are associate professors at the Kamla Raheja Vidyanidhi Institute of Architecture and members of the Hamara Shehar Mumbai Abhiyaan. This article is indebted to the numerous discussions and workshops the authors participated in with the members, groups and communities of the Hamara Shehar Mumbai Abhiyaan.