Mumbai makeover: Higher FSI can erase slums, heritage too

The new plan seeks to allow FSI to be generally raised to 3.5 for nearly 58 percent of the city, to 5 for another 32 percent of the city, to 6.5 for about 5 percent of the city and whopping 8 for a small 0.5 percent of the city which are transit points.

The plan has a host of other features but this FSI increase alone has justifiably triggered huge concern among citizens on fears that the higher FSI will mean more houses that will stretch the already woefully inadequate infrastructure of roads, open spaces and other amenities.

The plan claims to be based on a GIS-enabled data base, and a painfully collected land use map. It further claims to have been written after a massive consultation process with citizens groups.

Despite this consultation with citizen groups, citizens have raised some fundamental objections. That the supposed map is full of errors, disregards heritage properties and ignores fundamental environmental concerns.

Cyrus Guzder, Founder Member, Citizens for Justice and Peace says an FSI as high as 8 is not the most worrying thing here. It is the manner in which it is being done – the general increase in FSI across Greater Mumbai, where it has been increased from 1.33 or 2 to 3.5 and even up to 6 - that is worrying.

The problem, according to him, is that there is a huge lobby that is in favour of FSI since they think that is the way to solve the housing problem in Mumbai. "But the thing is, if you are going to introduce say 100 units of new built-up area, then as per rule of thumb you need to put aside about 30 percent of that for amenities which are roads, schools, hospitals, dispensaries and above all open spaces, parks and gardens, which is not happening in this case," Guzder told CNBC-TV18. 

However, Sanjay Ubale, former IAS Officer, CEO of Tata Realty does not seem to have an issue with FSI. "There seems to be a bit of a mistake in the way we consider FSI to be. A lot of the FSI which used to be disguised FSI, which used to get added up into built-up space - all of that now has been added together," he says.

Shockingly, one of the most majestic edifices in Mumbai - The Town Hall, popularly known as The Asiatic Society - it houses is among the few Victorian architectural reminisce. This along with the 19th century neo-gothic buildings in the Fort prescient, the iconic Mount Mary Church in Bandra and hundreds of such landmarks are in danger of losing their heritage protection. Around 40 percent of the heritage structures in Mumbai have been excluded from the DP. Only those structures mentioned in the BMC’s land use plan will be preserved and protected. In effect, for instance, the 100 meter radius buffer zone won't remain, allowing for rampant construction.

Urban planners and conservationists say while efforts are being made to notify some of these as UNESCO World Heritage sites, the civic body instead of protecting architectural legacy is only rendering them more vulnerable.

Worst still grade 3 heritage structures could be up for redevelopment, leaving the city's vernacular architecture like Khotachi Wadi in Girgaon, Mathar Pakhadi in Mazgaon or the 12th century Banganga Tank and temples at risk.

V Ranganathan, chairman, MHCC, says: "It will be a pity if all this heritage presence lose their heritage character and get redeveloped and become the kind of urban concrete jungle which the rest of the city is fast becoming."

The heritage conservation committee that is taking its case to the BMC, hopes better sense will prevail.

Guzder believes that the BMC and the planners are not ignorant of anything. Looking at the glaring omissions, it is obvious that they are either the result of absolute inaptitude or perhaps the intent to support vested interest which is not currently visible on the plan, either way it is very objectionable, he adds.

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Below is the verbatim transcript of Cyrus Guzder & Sanjay Ubale’s interview with CNBC-TV18’s Latha Venkatesh

Q: Is your prime concern that the FSI in certain pockets has been raised to 8 and that too in places like Dadar which already feel like you are going into a rally. Is that your main concern with this extraordinary increase in FSI?

Guzder: FSI increase as a whole in the DP is a very big worry, perhaps one of our biggest worries but not FSI 8. FSI 8 is a relatively small and selected area in which this humongous FSI is proposed. In fact it is proposed in extremely dense areas already it is over crowded around railway stations. So, that FSI 8 might not materialise immediately and if it does it will create utter havoc. What is much more worrying is the way in which there has been a general increase in FSI across Greater Mumbai, where the FSI has been increased from 1.33 or 2 to 3.5 and even up to 6.

The problem with FSI is that there is a huge lobby in favour of FSI because they think that that is the way to solve the housing problems of Mumbai - provide more built-up area and you accommodate more people. However, in a rather simplistic and in a puerile manner it ignores one of the fundamental tenets of any planning which is that you don’t plan increases in built-up area to the exclusion of amenities that you also need to plan for to support that built-up area.

There is a rule of thumb that if you are going to introduce say 100 units of new built-up area then you need to put aside about 30 percent of that for amenities which are roads, schools, hospitals, dispensaries and above all open spaces, parks and gardens.

The shocking thing is that if you look at all the amenities across the board - particularly open spaces, seats in schools, beds in hospitals, green areas, they have been further diluted below what the standards are today.

Let us talk one parameter, let us take open spaces, it is a general convention that you need about 6-10 square meters of open space per person. In Mumbai, we have just now somewhere around 1 square meter. The plans look at 2 square meters but the 2 square meters take into account definition of open spaces which in my opinion is also very misleading because they have included large areas or tracts of land which are not accessible to public such as Raj Bhavan, TIFR and so on and then if you exclude all of those areas then we really have diluted the open space standard while we have increased built-up area.

Q: What exactly is the diluted number, you said that the plan aims at 2 but actually what is the average open space per capita that the plan looks at?

Guzder: It dilutes to, it is 0.1. They have put 2 square meters as a norm because they found some area in Hong Kong where they have 2 square meters but they ignored the fact that the average of Hong Kong today densely crowded as it is, is around 5 square meters per person. They have taken a small sector in Hong Kong which is very densely crowded and there is no availability of land - that is where it is 2 square meters. They want to apply that to the whole of Greater Mumbai. London and UK is in excess of 10 square meters, New York is 25 square meters.

There are Indian standards setup by the National Housing Board which are about 6 square meters for India.

Q: Amount of open space worldwide, even in India is 6 square meters per human being. Mumbai is going to head towards 0.1 square meters. In that case I don’t think we are going to produce Sachin Tendulkar’s any more because there will not be any more Shivaji Parks if at all we can preserve what is there. What is your major objection, is it FSI, generally what is your objection to the plan or do you think it passes muster?

Ubale: I don’t really have a serious issue with the plan. There seems to be a bit of a mistake in the way we consider FSI to be. First of all a lot of the FSI used to be disguised FSI, there used to be balconies and there used to be these open spaces all of that now has been added. Parking is not a part of FSI, in fact parking has been reduced.

So, a lot of the FSI which used to be disguised FSI, which used to get added up into built-up space all of that now has been added together.

Typically, you can say that if at all we were to compare, 8 can probably be compared to 6 may be, but even then it might appear to be high. Second thing is that world over there is something called as transit-oriented development. What it means is that wherever there are transit nodes, around the transit nodes you must have larger concentration of people so that they don’t spillover into the city, they can use the public transport.

So, if you look at Dadar, the 8 FSI that you are talking about is around the railway station - the transit nodes. So, it is actually densification of the transit nodes where this increased FSI will happen.

Let me also just give you another perspective, FSI very often it is opposed. However of you look at South Mumbai for example, South Mumbai used to have an unlimited FSI. Even today when you look at South Mumbai’s plan, Nariman Point has an FSI in excess of 4. Bhindi Bazaar used to have an FSI of 4.5. So, high FSI used to be always the case. However what happened was in 1971 when it was thought at that time that Mumbai’s population is becoming too big, FSI was actually brought down to 1.33 and the slumification of Mumbai actually started with that.

So, wherever you have a scarce resource you have to efficiently use that resource, you have to intensively use that resource in order to optimise its scarcity value.

So, per se you should probably not be opposed to increased FSI. What I think you are talking about is that commensurate with the FSI you must have all the amenities also, we should be in a position to absorb and accommodate that FSI so that people can freely move about. That is a good point which seems to be probably missing in some of those areas.

The infrastructure plan - the linkage to increased FSI is probably missing.

Q: You must have just heard the details about some of the heritage sites that are in danger. Can you tell us more since you have spent a lifetime caring for heritage sites and speaking up for them, tell us what are your worries about heritage sites that can be endangered because of the new plan?

Guzder: I don’t think that the planners and the BMC are ignorant of anything. One can only say that if you look at all these glaring omissions, they are either the result of absolute inaptitude or perhaps the intent to support vested interest which is not currently visible on the plan, either way it is very objectionable.

On heritage, Mumbai was the pioneer in city heritage legislation. In 1995, the city enacted a heritage list which has stayed and endured right up to today. Initially, it had some 680 buildings on it, graded as 1, 2 and 3 with the highest level of protection given to grade 1 and grade 3, allowing substantial modification but not the demolition of the building.

Subsequently in exercises carried out by expert bodies such as the Mumbai Metropolitan Region Heritage Conservation Society, probably the highest expert body in the city after the Mumbai Heritage Conservation Committee, there have been additions to the list. Couple of textile mills, all the Parsi Fire Temples, some more public and private buildings and now the total number of building on the list which have the force of law is about 1480.

What has happened in this DP is 1,000 buildings have just disappeared from the plan. So, they have obliterated roughly three quarters of the heritage of Mumbai. The implication of this is that either all of the buildings that they have their eye on are slated for redevelopment or it means that they simply don’t believe that heritage is worth conserving anymore.

The sad thing about this is that in the long run it is the preservation of urban form and heritage that gives the city its sense of history and its sense of belonging. If you want to obliterate this then you will convert the whole of the city into large tracts of what we see today as suburbier without any sense of character or urban form.

There is a heritage list, how this DP can supersede that list is a legal issue which we haven’t understood and is exposing the BMC wide open to challenge.

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Q: What is your sense, since you have been in government as well, will a plan like this fall because an earlier heritage law protects these heritage sites or do you think since the plan is the later one in law, it might even supersede the earlier list?

Ubale: No, not really. In fact it seems to be a glaring error that some of these heritage sites have actually not been shown as a part of the existing land use.

Q: You don’t think they are in danger?

Ubale: I don’t think they are in danger at all. It is just a matter of getting it corrected, either it could be by sheer oversight or deliberate I don’t know but it is an error that can be corrected.

Q: Let me come back to the issue that we were discussing about the availability of open space. Over there it is not a question of providing amenities. Even reducing that to below 1 square meter per capita, do you not think that it will deny to succeeding generations of children the existence of a playground and therefore for generations we are not going to have sportsmen from Mumbai.

Ubale: One of the errors to my mind in the DP is that there were number of reservations which have been subsequently encroached and those have been in this plan have been actually removed. The important thing would be to restore those reservations back. To my mind probably all of them can be – and what seems to have happened is that wherever these reservations were there, under the new plan they have been either converted into residential or commercial zones. It is necessary to restore them back and those could be compensated with slum rehabilitation scheme, similar schemes can be worked out for these but it is important to preserve those spaces. Whatever space there is and whatever space was earmarked for open space that needs to be restored back.

Q: In that case what would be your top 3 or 5 objections or recommendations for changes in the plan keeping in mind provision of something as important as open space?

Ubale: I just gave you two major considerations. Secondly, wherever reservations existed on the site and those by virtue of this DP are likely to be removed, I think those need to be restored back. I have two or three major objections to this plan.

To my mind I don’t think the plan is ambitious enough. To me I think this city- Mumbai is a financial centre, Mumbai is a global city. I don’t think the plan looks at it as a global city at all. All cities compete with each other, Mumbai competes with Hong Kong, Shanghai and Dubai. I think what we are trying to do and I have mentioned it in one of my interactions also, it is a provisioning plan, that means the population is going to be this much and therefore we need to provide for this much housing, but 20-30 years down the line where would Mumbai be, can it take its rightful place as a world city - that is something that we are not talking about. There are few things that could be certainly done for that.

To my mind one of the suggestions that I have is, say for example Nariman Point used to be the prime CBD, it is no more, almost about 40 percent of the space is vacant there. The reason why it is the case is the buildings that are constructed there are old buildings, there was not enough parking in that, in fact the FSI consumed there was almost in excess of 4. So, revamping all of that because the best infrastructure is this side, a lot of people are moving out of this place into the suburbs where the infrastructure is not as good as this. So, restoring some of that back here is to my mind – therefore giving a boost to Nariman Point, reinventing Nariman Point to my mind should be first.

Second, the plan does not talk about a couple of other important places that are coming up, one is the port area, it is almost about 1600 acres which is waiting to be developed, that is going to be the new gateway to Mumbai. Unless we integrate that into the city of Mumbai – that seems to have been kept out obviously because it is a part of the port land but that entire infrastructure load will have to come on to Mumbai and Mumbai can probably take part of that space for its own development.

Q: All the areas that come under certain authorities like MMRDA is not included in the plan because it is another authority.

Ubale: Absolutely. The third is that Mumbai doesn’t exist in isolation. In fact Thane has almost become a part of Mumbai, Navi Mumbai has become part of Mumbai…

Q: Do you think connectivity to Uran or to the mainland should have been the centre part of the plan?

Ubale: Absolutely. That is not only the Trans Harbour Link but the infrastructure plan and I heard Guzder also saying about it, that the amenities that he was talking about, infrastructure, how exactly the infrastructure plan is going to go along with the land use plan is something that is not a part of this plan, unless that is integrated I don’t think we will really have a holistic plan.