Response / Suggestions on Draft ‘Delhi Maintenance & Management of Parking Rules 2017

Secretary cum Commissioner (Transport),

Transport Department, GNCT of Delhi,

5/9 Underhill Road, Delhi-110054.

Subject:- Response / Suggestions on Draft ‘Delhi Maintenance & Management of Parking Rules 2017’

Preamble: On the street people think ...... all Such Policies are made MORE FOR REVENUE GENERATION for the Government  ........ THAN TO OFFER ANY solution to the Problem created in the first place due to GOVERNMENT APATHY AND NON IMPLEMENTATION of dully laid out Rules and Laws .......

........ Please look at previous attempts at giving Parking Solutions ...... Charging ONE TIME PARKING CESS and collection of CONVERSION CHARGES UNDER MPD-2021 ......... Millions of Rupees have been collected without any accountability and no corresponding Parking Infrastructure developed in the past Decade.

On street parking....... 

How will MCDs keep track of cars parked on streets, they cannot even keep track of IMMOVABLE PROPERTIES...... What is the plan for motorcycles???? No solution can be worse than the problem......

Dear Sir,

This has reference to the Advertisement published in various News Papers on the above subject. Following are my suggestions .......

PREPARE A THREE YEAR PARKING ROADMAP (Short, Medium, Long Term and Non-Negotiable), with clear deadlines with the help of Data Collected and Additional Surveys:-

First and foremost, it is claimed the entire capital City has been developed under a Master Plan, that has the force of law since 1962 – the introduction of first Master Plan. Once you have come out with the Draft Parking Rules, it is evident that the Master Plan has been consigned to a Dust Bin with rampant illegal construction, change of land use was allowed for obvious reasons. The Delhi Building Bye-Laws -1983 provides for per hectare permitted housing density of is 140 Dwelling Units. We are not sure whether any agency has carried out any survey to assess the present Dwelling Unit Density per hectare which a must before even proceeding. Further, it has not been assessed that how many stilts have been converted and are being used for purposes other than parking and the cars are parked outside on Footpaths and Roads the classic examples are Vasant Vihar, Punjabi Bagh, Paschim Vihar, Shalimar Bagh etc.

SHORT TERM:-

1. DIFFERENTIATE BETWEEN DYNAMIC AND DEAD PARKING – discourage people who use cars for Home-Office-Home travel, turning scarce Parking Space unproductive (Dead) for 8-14 hours. Shoppers and Visitors to offices for meetings etc occupy Parking Space (Dynamic) for a limited period of time and the same space is utilized multiple times, giving a fillip to Business. DEAD PARKINGshould be discouraged and made prohibitive ..... DYNAMIC parking rates should be of 15 Minute Pulse, to encourage people to conclude business promptly and save money.
2. HIGHER PARKING FEE FOR CARS REGISTERED OUTSIDE DELHI – To encourage registration of cars in Delhi, a lot of Revenue is lost to other states, including ONE TIME PARKING FEE.
3. PARKING FEE BASED ON LENGTH OF CAR – To encourage the use of small cars Parking Fee should be charged based on length of the car, as one BMW occupies twice as much space as an I10.

4. INTRODUCE POINT TO POINT AC CHARTERED/SHUTTLE BUSSES –Care should be taken that Office goers are not inconvenienced and transport BEFITTING THEIR STATURE be made available at reasonable rates. People use Personal Transport out of compulsion due to lack of COMFORTABLE, SAFE & SURE TRANSPORT.
5. STOP FLEECING BY AUTO/ TAXIS; SURGE PRICING BY UBER / OLA AND REFUSAL: Autos have been notorious for Refusals and Overcharging. Now Uber and Ola are also fleecing hapless commuters, charging 1.5X to 3.9X SURGE PRICING. INTRODUCE UNIFORM PRICING.
6. ENSURE FOOLPROOF VERIFICATION OF DRIVERS AND LINKING OF ADHAAR CARD OF DRIVER AND OWNER WITH VEHICLE RC- Safe, Secure and Sure availability of Transport irrespective of distance and area of travel will surely encourage citizens towards Public Transport. Today we cannot dream of allowing Ladies Travelling alone at night to or from Airport / Station etc.

7. ENFORCE LANE DISCIPLINE – Traffic Police should be instructed to enforce Lane Discipline and man Traffic Lights instead of hiding behind Trees to net offenders and pocket bribes.
8. REMOVE BOTTLENECKS ON ROADS – Potholes; Encroachments/Vendors; Parking on Roads; Religious Places; Trees; Defunct Electricity Poles etc. create congestion and slows the traffic.
9. BAN PURCHASE OF VEHICLE (PRIVATE OR COMMERCIAL) WITHOUT PROOF OF PARKING SPACE – Geo Tag Location of Parking Proof with RC, so that multiple vehicles cannot be bought in different names at the same spot. Also, ensure with Google Maps/Geospatial Technology that there is a motorable road for a car to drive to the shown Parking. Introduce differential Fee Structure for parking on Public Land with a percentage increase for 2^nd, 3^rd or 4th Vehicle Registered per Dwelling Unit instead of per family member. A HIGH COURT RULING FOR HOUSING SOCIETY, RESTRICTING ONE PARKING SLOT PER DWELLING UNIT IS WORTH EMULATING FOR EQUITABLE USE OF PUBLIC SPACES. Fleet owners should create own Parking Zones instead of using up public spaces.

10. BAN ALLOTMENT OF PERSONAL VEHICLES FOR GOVT. OFFICIALS, JUDGES, PARLIAMENTARIANS ETC – these people have been allotted Cluster Housing in Lutyens Zone and can easily be transported to their respective offices in Special Buses as their office timings are the same. Their cars use up Parking Space that can be better utilized by Visitors who are forced to park outside on Streets. A small Fleet of cars can be deployed on sharing basis if an official has to visit a Minister going for inspection. Anyway more often than not these Personal Vehicles are Ferrying Children to schools or Wives to Kitty Parties.

MEDIUM TERM:-

1. CREATE HALTING ZONES FOR AUTOS, E-RICKS, GRAMIN SEVAS, TAXIS ETC – Traffic Jams are often noticed near Bus Stops/Metro Stations, Traffic Signals, Market/Hospital Entrances, Street Corners etc as these modes of transport bunch up at such spots usurping one or more lanes.
2. E-RICKSHAW CHARGING POINTS /NIGHT PARKING AWAY FROM RESIDENTIAL AREAS- All such facilities should be on the Chargeable basis and be suitably cordoned off from Residential Areas for security reasons.
3. IMPROVE LAST MILE CONNECTIVITY – This proposal has been in the Pipeline for so long that it seems like a Pipedream, surely it is not as difficult as it seems.
4. PUT THE PUBLIC TRANSPORT INFRASTRUCTURE IN PLACE – Multiple modes of Public Transport adhering to a strict timetable be introduced in consultation with experts.

5. CREATE SUBWAYS AND PEDESTRIAN CROSSINGS – Lack of pedestrian facilities make the roads dangerous and are the cause for traffic snarls when people give up private transport there will be a manifold increase in Pedestrian Traffic, so this aspect MUST GET PRIORITY.

6. INSTALL NUMBER PLATE READING CCTVS - E-Challan traffic offenders and Trucks who enter the city before Entry Hours (which is Rampant)

7. GPS ENABLED APP BASED SYSTEM FOR ONLINE PAYMENT OF PARKING – UAE has developed a Parking System with HUMAN INTERFACE. A person Parks his Vehicle and tags his location on the Mobile App, which records the Location, Time and Duration of Parking and Deducts the amount from a prepaid account at a PER MINUTE PULSE RATE. Traffic Police routinely drive by with a Number Plate Reader Camera, which instantly verifies if the Parked Car has Tagged itself for Parking. Heavey Fines are imposed on defaulting vehicles, automatically deducted from the account.

LONG TERM:-

1. IMPROVE ROAD ENGINEERING AND POSITIONING OF BUS STOPS – Go anywhere in Delhi, most traffic jams occur at the start and end of a Flyover, due to merging traffic and positioning of Bus stops close to the Flyover.

2. EXPEDITE COURT CASES FOR ROAD WIDENING – Ring Road at Nariana is a good example of what can be achieved by acquiring land for road widening …… there are many such points all over Delhi that are stuck in Court Cases.

3. INTRODUCE FIRST CLASS COMPARTMENTS ON METRO – Airlines, Trains, Busses, Mumbai Suburban all have 1^st Class compartments.

4. FRAME PARKING BYE-LAWS - MPD 2021, while allowing additional FAR and the Third Floor on buildings with Stilt Parking. Having charged CONVERSION CHARGES, authorities thought their job was done. As with everything else the LACK OF APPLICATION OF THE MIND IS QUITE EVIDENT. Earlier the front of a building as per BYE-LAW was to Mandatorily have a 10 Feet Gate with Ramp and a four feet Boundary Wall for the remaining portion of the Facade. NOW ON STILTS THERE ARE END TO END GATES, therefore the space in front of Home or Shop is inaccessible to anyone other than the occupier even if there are no vehicles inside.

5. VISITOR PARKING FOR RESIDENTIAL COLONIES/SOCIETIES - MPD 2021 has no plan in place for Visitor Parking in the most modern of Housing Societies and Commercial Complexes. ECS Norms framed are inadequate even to accommodate occupier needs, what to talk of VISITORS.

6. PARKING FOR RESIDENTIAL AREAS- (A) MPD 2021 talks of parking as a composite entity ….. whereas the ground reality is that Parking in Commercial Areas and Residential Areas ought to be treated and addressed separately. While collecting Conversion Charges on account of the additional floor and FAR for a residential plot …. parking has to be provided for the needs of the area residents ……. Whereas the only Parking Lots being planned are in Colony Markets and not for residents. (B) While framing ECS parking norms, Sangam Vihar and Greater Kailash ground realities must be kept in mind, one has smaller cars while upscale colonies have SUVs Saloons ….. Can ECS norms be framed on same benchmarks ?????

SUGGESTION: (A) Areas should be identified with the help of RWAs ….. underground parking in large Colony Parks, Community Centres or Religious Places should be developed for Residential Parking. Parking lots should not be allowed on B.O.T. basis by allowing space for commercial activities. The expensive fully automated parking lots should be avoided to make the projects more viable …. Instead, residents should be encouraged to form Co-operatives and allotted parking spaces on payment as is prevalent in Housing Societies. (B) Different ECS norms are needed for Sangam Vihar and Greater Kailash as bigger cars need more parking space as also larger maneuvering area.

NON-NEGOTIABLE:-

1. NO CREATION OF THIRD PARTY INTEREST OUTSIDE PLOTTED RESIDENCES & DDA FLATS – NO PARKING CHARGES OUTSIDE PLOTTED RESIDENCES- if within norms, within the width of the plot and does not obstruct smooth flow of traffic.  Home buyers have already paid for the Roads and open spaces on account of Super Area, that includes Parking...... MCD while collecting Property tax under the Unit Area Method has already included such super areas in consideration while categorizing each colony. Therefore, MCD is prohibited from imposing parking charges over and above property tax. FURTHER, how can MCD allocate space on a permanent basis, outside private residences to those living some distance away???  No way will Home Owners forfeit their right over common space. The age-old custom of First Right for the Occupier of property in whose front, the said Public Space is situated has been a well-established convention. However temporary Parking for a short duration is understandable, on First Come First Served basis.

2. ALL ABOVE SUGGESTIONS REGARDING PARKING FEES ARE ON FIRST PROVIDE THEN CHARGE BASIS- Authorities have in the past Taxed citizens in the name of providing infrastructure but have miserably failed to provide the promised infrastructure. Road Tax, One Time Parking Cess, Conversion Charge etc have all been collected without any accountability. IT IS IMPERATIVE THAT BEFORE ANY NEW LEVIES ARE IMPOSED ON CITIZENS, MONEY COLLECTED THUS FAR UNDER VARIOUS HEADS, SHOULD BE UTILISED TO DEVELOP INFRASTRUCTURE, like Parking Lots, Halting / Charging Stations, Streamlining Public Transport, Reigning in Errant Auto/Taxi Drivers etc.

3. NO CONFIDENCE IN MCD's ABILITY TO IMPLEMENT- We fear Inspector Raj, open to corrupt practices being encouraged, where Law abiding citizens will suffer while a Blind Eye is given to Misuse on illegal gratification which is rampant even today. Anyway MCD is not known for Financial Prudence, going by how Conversion Charges in ESCROW Account were misutilised.

It seems, till now Governments and Municipalities were only interested in creating money making avenues for their Staff and Contractors. Citizens did not figure in their scheme of things ...... HOPE THIS TIME AROUND THE POLICY WILL BE HOLISTICALLY THOUGHT THROUGH. These are preliminary submissions, I request you to give me an opportunity to elaborate in person before a final decision is taken.

Warm Regards,

RAJIV KAKRIA

Member, GK-I, RWA