DRAFT PARKING POLICY OF DELHI GOVT : SUGGESTIONS

DRAFT PARKING POLICY OF DELHI GOVT : SUGGESTIONS

12th July, 2017

Special Commissioner Transport

Room No. 208, Second Floor,

Transport Department, GNCT of Delhi,

5/9 Underhill Road, Delhi-110054.

Dear Sir,

You can decide and Fix any parking charges for the parking of vehicles in the Markets, Commercial places, multilevel parking, to de - congest the roads and to control the pollution.

But you should never allow any Day, and / or Night parking charges from the residents for parking their own vehicles outside their own homes. Please note as below in this regard:

1.  Please note, for every sale of all such vehicles Govt has already earned a huge share in VAT, EXCISE, Registration charges, Road Tax as well the service tax on the insurance policies of these vehicles, and the Income tax from the genuine buyers. They are already earning a lot on the sale of Petrol and Diesel for all these vehicles. Even after the GST regime, they still have a huge share out of the 28% levied on vehicles.

2.  It’s sad and shocking that now Govt is eying the parked vehicles of the residents, outside their own home. They are absolutely wrong in saying that residents are using Free of charge space for parking their own vehicles, outside their own homes.

3.  When the colonies were developed years ago, prices of plots were decided on the basis of the size of inner roads in that area. The posh localities had wide inner lanes and therefore cost of plots was on the higher side. The middle / upper middle colonies had a bit smaller roads and therefore cost of plots was lesser than the posh localities. Whereas, the lower colonies had narrow lanes, and hence the cost of plots was also on the lower side.

4.  Now after 40 – 50 years, if Govt says that these colonies are using the public land Free of cost, THEY ARE ABSOLUTELY WRONG, as we have already paid the price of such inner lanes via the purchase price of our residential plots. Do you think that developers of these colonies were that much fool to offer inner lanes free of cost, causing huge losses.

5.  Moreover, there is no traffic in the inner lanes, except in the commercial areas, and no one is degrading the pedestrian environment in any way. Instead, it’s the policies of the Governments that degrade everything to levy a charge later on.

6.  Sometime Emergency vehicles face some problem while entering the inner lane, and it must be given a serious thought that how Govt can purchase such emergency vehicles that can easily enter the narrow inner lanes. But how do they think that by charging the parking charges, way for the emergency vehicles will be opened automatically ?

7.  Instead of restricting the sale of new vehicles in Delhi, Govt is now eying to earn more by way of HUGE PARKING Charges on all the vehicles parked by residents, outside their home.

8. The problem has erupted as  Govt has not formed any  vehicular policy for the sale and purchase of Vehicles. Everyone is free to buy any number of vehicles as Govt is GETTING HUGE SUMS BY WAY OF VAT, EXCISE, ROAD TAX,  SERVICE TAX and, GST NOW of 28% and that too after paying Income Tax. Why don’t they attach the vehicles with the Pan Card to check and control the sales of vehicles ?

9.  A typical vehicle stays parked 95 per cent of the time. A 2006 study by the Central Road Research Institute in New Delhi estimate that of the 8,760 hours in a year, an average car’s steering time is only 400 hours. This means it is driven for only about an hour a day. In Delhi this may be 3 to 4 hours a day. It clearly means that while parked at home, these vehicles for the 95% of time are not contributing to any Congestion or pollution.

Therefore, Govt must concentrate on the 5% time of these vehicles while they are either congesting the roads or polluting the environment and hence must levy hefty charges and penalties so that residents are forced to leave them in the parking itself.

It will automatically discourage the sale of new vehicles, though Govt may be against this policy as it will impact its own kitty. 

Therefore we are absolutely against the imposition of any parking charges from the residents, for the parked vehicles outside their home as it will lead to unnecessary harassment and chaos.

Thanks & with best regards,

B S Vohra

President,

East Delhi RWAs Joint Front

http://www.rwabhagidari.com/

Suggestions on Draft Parking Policy in Delhi - Last Date - 13-07-2017

DATED: 12-07-2017

To

Special Commissioner Transport

Room No. 208, Second Floor,

Transport Department, GNCT of Delhi,

5/9 Underhill Road, Delhi-110054.

Subject:- Response / Suggestions on Draft Parking Policy in Delhi

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.

Dear Sir,

This has reference to the Advertisement published on 12^th July 2017 in various News Papers on the above subject.Following are my suggestions .......

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

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 utilised multiple times, giving a fillip to Business.DEAD PARKING should 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. PARKING FEE BASED ON SIZE OF CAR – To encourage use of small cars Parking Fee should be charged based on length of car, as one BMW occupies twice as much space as an I10.

3. 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.
4. STOP FLEECING BY AUTO/ TAXIS AND SURGE PRICING BY UBER / OLA: 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. If citizens can be fined Rs. 2000/- then Service providers should also be penalised for Malpractice. INTRODUCE UNIFORM PRICING.
5. 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.
6. REMOVE BOTTLE NECKS ON ROADS – Potholes; Encroachments/Vendors; Parking on Roads; Religious Places; Trees; Defunct Electricity Poles etc. create congestion and slows the traffic.

MEDIUM TERM:-

1. CREATE HALTING ZONES FOR AUTOS, 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. 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.
3. PUT THE PUBLIC TRANSPORT INFRASTRUCTURE IN PLACE – Multiple modes of Public Transport adhering to a strict timetable be introduced in consultation with experts.

4. 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 manifold increase in Pedestrian Traffic, so this aspect MUST GET PRIORITY.

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

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. BAN PURCHASE OF VEHICLE (PRIVATE OR COMMERCIAL) WITHOUT PROOF OF PARKING SPACE – 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.

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

5. VERIVICATION 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.

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 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 more 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 manoeuvring area.

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 ROUND 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

DERC Business Plan Regulations 2017 - As Good as Throwing Out Sec.61 of EA, 2003

To

The Secretary,

Delhi Electricity Regulatory Commission,

C-Block, Malviya Nagar, New Delhi.

Sub: DERC Business Plan Regulations 2017

IF PASSED - MIGHT AS WELL THROW OUT SECTION 61 OF ELECTRICITY ACT 2003 INTO THE DUSTBIN IN ITS ENTIRETY.

Section 61 of the Electricity Act, 2003 stipulates that the Commission shall be guided by the factors which would encourage competition, efficiency, economical usage of resources, grid performance and optimum investment in specifying the terms and conditions for determination of tariff.

In terms of the Section 61 (g) of the Act, the Appropriate Commission shall be guided by the objective that the tariff progressively reflects the efficient and prudent cost of supply of electricity.

Sir,

DERC does not have full strength and without a Chairman for a few years now, I am APPALLED to note that a matter of such importance is being taken up Single Member.

There are many important issues that have been put on hold citing lack of full representation in DERC, here Business Plan Regulation that will impact future control of DERC over DISCOMS Accounts &  Audit is being compromised.

We are aware that the Commission has stated in an Affidavit in High Court that it lacks the Competence to Audit DISCOM Accounts, that does not mean that DERC introduces and passes a Regulation that binds DERC in accepting Accounts submitted by DISCOMS ……. This begs the Question …… Why have a Commission at all ?????

PLEASE PUT ON HOLD THIS REGULATION IN VIEW OF ABOVE STATED FACTS …….. If the proposal to bring about changes suggested in the Draft are anything to go by then MIGHT AS WELL THROW OUT SECTION 61 OF ELECTRICITY ACT 2003 INTO THE DUSTBIN IN ITS ENTIRETY.

These are preliminary submissions, I request you to give me an opportunity to elaborate in person before a final decision is taken.

Warm Regards,

s/d

Rajiv Kakria

Member GK-I, RWA

Objections DERC: Renegotiate DISCOM’s Contract to Check REGULATORY ASSETS

To                                                                                                                                             
The Secretary,
Delhi Electricity Regulatory Commission,

C-Block, Malviya Nagar, New Delhi.Sub: Petitions for True Up of expenses for FY 2014-2015 & FY 2015-2016 and Aggregate Revenue Requirement and Tariff for FY 2017-2018 filed by the utilities of Delhi

RENEGOTIATE DISCOM’S CONTRACT TO CHECK REGULATORY ASSETS ……

If Long Term Power Purchase Agreements Can Be Renegotiated, WHY NOT the terms of contract guaranteeing 16% RETURN ON INVESTMENT to DISCOMS ????? that too for capital raised from Public Institutions at far lower rate of interest …… A SENIOR CITIZEN GETS 7% IN A FIXED DEPOSIT.

EXAMPLE – Noida Toll Bridge contract was the Brain Child of a similar set of people and borrowed its Content from the DISCOM Contract with Delhi Government. NBTL invested Rs. 200 Cr, has collected Rs. 450 Cr in Toll Tax and still claim a Loss of Rs. 850 Cr approximately.

Supreme Court has ordered a Ban on Charging Toll Tax on DND Flyway on a Petition filed by Citizen Groups ……. WE EXPECT DERC TO ACT ON BEHALF OF CITIZENS ……. As mandated in Section 61 of the Electricity Act, 2003 which stipulates that the Commission shall be guided by the factors which would encourage competition, efficiency, economical usage of resources, grid performance and optimum investment in specifying the terms and conditions for determination of tariff. 

Sir,

THANK YOU FOR THIS OPPORTUNITY AFTER A LEAP YEAR ……. THIS YEAR I AM SEEKING ANSWERS TO 8 QUESTIONS FROM DERC,the answers for which I have been seeking for many years. Please read all my past Objections in your records and make them part of this year’s Objections as well.

1. REGULATORY ASSETS – 8% Surcharge was introduced in 2012 to eliminate Regulatory Assets.

a) COAL and GAS -  prices have been coming down steadily for the past three years, but we see no softening of strain on Regulatory Assets.

b) POWER PURCHASE COSTS - have come down and the 8% Surcharge is charged on Retail Cost that has remained unchanged.

c) DEFAULT OF TRANSCO DUES - DISCOMS have not cleared their dues to TRANSCO’s and threaten Blackouts.

d) BAIL OUT PACKAGE - Regulatory assets have continued to mount despite 500 Cr Bailout.

2. CAG AUDIT – citizens are paying a heavy price for the CAG Audit being stuck in Supreme Court. DERC should intervene and ask for early resolution as DISCOMS are profiteering at the expense of hapless citizens.

3. PRUDENCE CHECK – seems to be the least of DERC’s concerns as we have been demanding for many years. The process of appointing an Institution has been advertised but no concrete action taken.

4. Private DISCOMS - were brought in to Delhi in 2002 to bring Private Investment (Money), Efficiency, Curb Power Theft and Reduce Tariffs ……. in place of a Bleeding, Inefficient and Theft Prone DVB.

Private DISCOMS have failed on all four counts .....

a) PRIVATE CAPITAL -  this is the biggest fraud on the citizens, instead of bringing Private Capital, they took the Sovereign Guarantee of the Delhi Government Contract and raised money from Public Sector Financial Institutions, on top of that, DISCOMS were Guaranteed 16% ROI, so WHY IS DERC ALLOWING THE INTEREST ON LOAN TO BE ADJUSTED IN TARIFF.

b) REDUCE TARIFFS – Tariffs have increased manifold, including enhancement of Fixed Charge, which used to be Minimum Charges and adjusted in the bill amount exceeded minimum charge.

c) EFFICIENCY- No doubt it has improved but not to the extent promised, we still have long power cuts and have to depend on inverters; DISCOMS were supposed to take all transmission cables underground.

d) THEFT CONTROL - although the Average Power Theft is down to 15% from 60%, a third of Delhi is still showing over 65% to 98% theft, no BENEFIT TO HONEST CUSTOMER as Promised.

5. Fast Running Electronic Meter: Please refer to my Petitions from 2009 onwards, I have constantly asked for an Audit/Field Survey by an Independent Institute of Repute involving the Petitioners, be conducted. Transformer wise Audit of Units supplied and billed for the past three years of Peak Load Periods in Winters and Summers. Excess billing if found should be refunded to the consumers and Punitive Penalty imposed on DISCOMS for breach of trust and willful fleecing of Consumers.

After three years of sustained efforts this issue was addressed by DERC by inserting an Ad. in news papers on 24th Dec. 2011, putting the onus of correcting the flaw on the consumer. The Supply Code clearly states that it is the Duty of the Service Provider to provide a separate Neutral up to the Metering Point. DERC tried to legalise this unearned Profit by excluding this provision for existing consumers of less than 10kw in the Draft Performance Standards.

PLEASE REPLY IN YES OR NO whether the Electronic Meters have been installed as per Regulation 41 of CEA's Regulations of 2010, which are the statutes in replacement of IE Rules 1956 under section 53 read with 177 0f the IE Act 2003.

Implementation of regulation 41 of CEA provides the complete solution to this point being raised by Delhi Consumers ever since the electronic metering has been introduced and not addressed by DERC for reasons best known to them.

6. BILL PAYMENT AT PSU BANKS: Power Bills should be collected at PSU Banks, that will bring transparency & Accountability of DISCOM dealings as money collected due to fast running meters gets concealed on account of recording Unutilised Current in Common Neutral due to RESIDUAL BACK FLOW. Delhi Government had written a letter to DERC in 2016 and was also reported in The Hindu.

7. END MONOPOLY - Both Mr. Modi and Mr. Kejriwal had Promised Delhites during Election Speeches that to curb the Profiteering DISCOMS they will END MONOPOLY and bring in Competition, as in case of Mobile Phones, therefore High Tariffs will be tamed.

8. Conduct Energy Audit: Ensure Metering of Self Consumption by DISCOMS and Government ……

Like Air and Water, Power too is essential for existence and scarce resource needs to be conserved. The Energy Audit should identify what percentage of Power is being consumed for Domestic use, Industrial / Commercial use, Public Utilities and Government office Buildings and how much Power is being consumed by bureaucrats in Lutyens Delhi and at what price.

The Energy Audit should also look into the Energy Guzzlers in Industry, Commercial Establishment, Street Lighting, Neon Signs, Hoardings etc. The industry and Commercial establishments recover the Energy Component from the consumer in the form of the Final Product Cost.

We see no reason that Energy Guzzlers like Government Departments, Hospitals (both Govt. and Private), Private Schools, Corporate Offices, Malls, Banquets, Farm Houses etc. be allowed to burden the Domestic Consumer by way of eating up the Cheap Power Quota Available from NTPC, SEBs etc.

Delink Power consumed by Domestic consumers and let Power Guzzlers buy power from open Market, right now there is no incentive for them to conserve energy as they recover their life style from the cost of their Product or Service.

These are preliminary submissions, I request you to give me an opportunity to elaborate in person before a final decision is taken.
Warm Regards,
s/d

Rajiv Kakria
Member GK-I, RWA