Saturday, June 9, 2018

DDA Modifications - Suggestions / Objections - to Save our City Delhi !

9th June 2018

Commissioner Cum Secretary,

Delhi Development Authority,
B Block, Vikas Sadan,
New Delhi - 110023

Subject: DDA Modifications - Suggestions / Objections - to Save our City Delhi !

Dear Sir,

Please refer your Advertisement dated 26th May 2018 seeking suggestions/objections to the proposed modifications in the Master Plan of Delhi 2018. In fact, we are more than shocked to find that your Advertisement for modifications of the MPD 2021, clearly shows that every thing will be regularised on the payment of certain levies :

5.6.2 clearly says that - The existing built-up commercial centres may be redeveloped if need be with enhanced FAR subject to payment of appropriate levies.

5.6.3a clearly says that - such excess FAR shall be permitted subject to payment of penalty charges amounting to 1.5 times of the applicable charges.

5.6.3b clearly says that - Payment of Use conversion charges from Residential to Commercial shall be applicable as prescribed.

5.6.3d clearly says that - additional FAR shall be permitted on payment of additional FAR charges as applicable.

5.6.4 clearly says that - upper floors can be converted to commercial use after paying the applicable charges.

5.6.5 about basements clearly says that - such excess FAR shall be subject to payment of appropriate charges.

Even though they can not provide any parking facility to most of the commuters, 5.6.7 says that One Time parking charges shall be paid either as down payment or in maximum four instalments.

While 15.9 (V) asks for the Penalty, 

15.12.3 (vii) is again subject to the payment of appropriate charges.

Under such circumstances, the Suggestions / Objections being filed by us, as the Joint Resolution of RWAs - NGOs - Activists, to Save Our City, won't have that much impact as the things look pre-decided as well absolutely biased towards urbanization of the City with a clear message that anything can be done on the payment of certain levies.

Strange & Shocking, there is no mention anywhere, that how you will control the Traffic Jam, Congestion, Pollution, Open Dhalavs, Open Landfill sites, Water Logging, Encroachment, etc., due to the excessive load on the infrastructure due to the excessive FAR all over in this city, which is already world's most polluted & most congested. As per WHO, over 30,000 persons are killed every year due to the impact of Pollution in Delhi NCR, but we could not find any modification in the MPD 2021.

The Lifeline of Delhi - The Yamuna river has no more Life in its Dirty Drain water. Clause 9.1, NATURAL RESOURCES of MPD 2021 itself says that, The Yamuna river and the drains are highly polluted; the capacity to treat wastewater is grossly deficient; The actual quantity of wastewater treated is much below the installed capacity; The planned reuse of treated wastewater is minuscule; A large number of the traditional water bodies in the form of ponds, etc. (excluding areas of unintended water logging along railway tracks, highways and canals etc.) have been encroached or have otherwise become defunct. The average annual rainfall in Delhi is 611 mm. However, recharge of groundwater gets limited due to decreased availability of permeable surfaces owing to urbanization, but we could not find any modification in the MPD 2021.

Under such circumstances, the last try to Save our City, lies only in the clause 5.6.10 that says, in case there is no parking facility available in the vicinity, the concerned local body may declare such areas as the pedestrian shopping streets/areas. Public transport authority shall ensure last mile connectivity to these areas.

As almost every locality of Delhi has a market, may be big or small, we are sure that you have done enough surveys for all the areas before issuing the notification for the modifications in the MPD 2021.

1. Therefore, please let us know the areas that have the parking facility suitable to the quantum of vehicles of that area so that we can approach the Local bodies to declare the rest of the areas as the pedestrian shopping streets/areas with immediate effect.

2. Moreover, by yet another modification, the term 'may' above (in 5.6.10), must be changed with the term 'must', to ensure relief to the residents/shoppers.

3. As mentioned above (in 5.6.10), the Public transport authority has to ensure last mile connectivity of these areas. Therefore, please let us know that how long it will take for the public transport authority to ensure the last mile connectivity for all those areas and your approval to the modifications to the MPD 2021 must wait till the last mile connectivity is achieved for all the areas.

4. May we request you to please ensure that all those areas of Delhi without a suitable parking facility are declared as the Pedestrian Shopping Streets / Areas, at the earliest possible. The main benefit of declaring such areas as the Pedestrian shopping streets/areas will be the reduction of congestion & reduction of pollution, that will save the most precious lives of all those who are on the verge of collapse due to various respiratory ailments, heart diseases, Cancer, Brain stroke, etc.

5. But we just could not understand and would like to know that why the Extraordinary Notification Number 149, published in the Gazette of Delhi, on Friday 15th September 2006 / Bhadra 24, 1928, declaring a huge lot of roads as the Pedestrian Shopping Streets, has not yet been implemented? 

6. We would like to know that who are the persons responsible for the non-implementation of this published notification in the last almost 12 years, and what were the reasons for the non-implementation of the notification, that was published in the Delhi Gazette on 15th September 2006?

7.  We would like to know the extent of damages occurred to the Environment of the city, due to non-implementation of the above-said notification, that was published in the Delhi Gazette on 15th September 2006?

8.  You have added in the Clause 15.7.1 that other services which are non-polluting, non-hazardous, and not prohibited by law in the residential area, shall be permitted, but we could not understand that why you have not imposed any check on the number of vehicles that is one of the main cause of Congestion & Pollution in the city?

9. Moreover, Under the Clause 5.6.7, you are asking for the One-time parking charges. But how can you claim such one-time parking charges, until & unless you have identified the Parking space under 5.6.8 as well as under 5.6.9

10. Does it mean that you want to collect the Parking charges, even without having any parking space, even without identifying any parking space, and even though that area is most likely to be declared as the Pedestrian shopping street/area under clause 5.6.10?

11. Please empower the RWAs for some constructive efforts. RWAs have enough brains but no miraculous powers to identify the parking space, where there is no space at all.

Looking forward to your reply as well an invite to the Public hearing, if any, though not expected, as the things look already pre-decided and pre-settled in the favour of Urbanization of the City.

And if that's true, please at least make an ESCROW fund with all the collections done for permitting all the Enhanced FARs, Basements & the collection of Used conversion charges, ensuring to be spent only on the maintaining of Parking (if any in that area), maintaining of the Roads as well as the Pedestrian shopping streets/areas and in providing the last mile connectivity, without any deviation of funds.

With best regards,

B S Vohra

East Delhi RWAs Joint Front - Federation
F-19/10, Krishna Nagar, Delhi - 110051

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