�Guidelines� for Delhi�s �third� Master Plan

DDA has invited (at
<http://www.ddadelhi.com/docs/310703-GuidelinesMPD2021.htm>)
comments / suggestions about Master Plan ?guidelines?
announced on 28.07.2003 and hotly debated ever since.
The following is the text of my letter to DDA Vice
Chairman - not really to comment on the content of
?guidelines? but to make in their context some urgent
requests about the due process of Plan revision.
For information, also to the eml id mentioned on DDA?s
website for comments/suggestions.
Gita Dewan Verma / Planner / 03.08.2003

------------------

Dear Sir,

Firstly, this is to request you to make public the
status of Delhi Master Plan revision expected of DDA
by due process of law, inclusive of basis in planning
data (civic surveys under s.10 of the Act and
implementation monitoring under Master Plan provisions
for Plan review), duly considered by sectoral experts
and authorities for synthesis into holistically
considered scenarios for a draft for public comment. I
make this request in view of confusion created by
?guidelines? announced on 28.07.03 even as their
announcement frustrates due process of Plan revision
as well as public notice, judicial and Parliamentary
processes currently underway. A letter to the Minister
in this regard is at Encl.1.

Secondly, this is to ask why DDA has invited comments
on these ?guidelines?. Since the ?guidelines? are not
of the type MoUD issues for minding DDA?s statutory
mandate as its nodal ministry, there is no basis to
treat them differently from other suggestions. And
inviting comment, except on the draft through due
process of Public Notice, is extra-legal and calls for
transparency about purpose and mechanism. Also,
comments were similarly invited on ?recommendations?
in 1999 and a cursory perusal reveals that 11 of the
17 ?guidelines? of 2003 reiterate ?recommendations? of
1999 while 4 are perfunctory and 2 arguably premature
(Encl.2). I am sure you will appreciate this places a
question mark on four years of work on the Plan
revision and calls for clarification of why these
?guidelines? are receiving special attention by DDA
and being strongly advocated in the media by its
Chairman.

Thirdly, this is to request that analysis of surveys
and monitoring be made public if DDA wishes to invite
comment prior to Public Notice stage as otherwise
meaningful suggestions are not possible, as obvious
from ones made in the ?guidelines?. 4 of the
?guidelines? (about NCR, unauthorized colonies, Plan
implementation, and built/natural heritage) merely
restate existing Plan provisions and 2 do so in
?liberalized? versions (old city redevelopment instead
of management and flexible land use instead of
regulated mixed use for flexibility), while suggesting
these are new ideas and so skirting accountability on
implementation failures. The ?guideline? on slums and
the parts of the ?guideline? on flexible land use
relating to industries, likewise, skirt accountability
on 5000 hectares meant for low-income housing and
industries. The ?guidelines? about greater FAR along
metro corridor, vertical construction, private
developers and change in land policy are completely
contrary to the overall structure of the Plan and
since radical modifications are not permissible under
the Act they can only be commented upon with reference
to the holistically considered basis for proposing
them. It must be emphasized that due process of Plan
modification guarantees citizens accountability on
Plan implementation and safeguard against radical
changes amounting to abandonment of the Plan to sweep
implementation failures under the carpet. In view,
especially, of the obfuscation of planning failures
and implementation failures in the ?guidelines? as
well as by several ?experts? being quoted by media,
the publicity being given to the ?guidelines? needs to
be matched with awareness about the Plan and its
implementation so that the discourse is sensibly
informed in widest public interest. I have been
requesting a more structured and
accountability-ensuring approach to public
participation since 1999 (see Encl.3) and would deeply
appreciate a response at least now.

Fourthly, this is to seek assurance that comments
sought will be considered. I am constrained to ask
this because over the last four years techno-legal
objections and suggestions made in conformity with the
premises of the Plan and the process of its
modification through letters, reports, responses to
Public Notices, court cases, etc, on nearly all the
matters covered by these ?guidelines? and others as
well have not been considered. If comments and
suggestions of others are to be considered only if
they ?endorse? suggestions already made by some in
1999 and periodically repeated at press conferences,
then this should be specified. If comments are
genuinely sought to refine the Plan revision in public
interest, then assurance of this requires DDA to first
respond to techno-legal objections already raised
(illustrated in Encl.4) in matters covered by these
?guidelines?.

Lastly, I request caution (since how seriously DDA is
seen taking suggestions about land use affects real
estate trends and investments once made can create
pressures on the Plan revision process) and conscience
effort to ensure that ad-hoc extra-legal initiatives
for public participation do not undermine the public
notice process (which remains the only legal and
inclusive mechanism for citizens? participation in
planned development).

Yours sincerely


__________________________________
Do you Yahoo!?
The New Yahoo! Search - Faster. Easier. Bingo.
http://search.yahoo.com



Partial thread listing: