Affordable Housing Uncertainty Continues

- Response of Nivara Hakk to Development Plan 2034

It is heartening to note that for the first time Mumbai’s development plan has recognised the importance of mass housing by introducing ‘Affordable Housing’ (AH) as a new reservation.

However, on the ground, reservation for ‘affordable’ housing is a mere token with only tiny pieces of land identified across various wards. The draft DP in fact concedes that these reserved parcels when developed will yield only 25,000 affordable units. It is pertinent to remind the government that it has estimated the shortfall in affordable housing in the city at 9 lakh units.

Further, the DP 2034 suggests 3330 hectares (ha) (130 ha. salt pan + 1100 ha. TDZ+ 2100 ha. NDZ) of NDZ land as earmarked in the 1991 DP, as potential land for affordable housing development. But this ‘potential’ is highly speculative and uncertain. There is no clear demarcation in the 2034 development plan of these NDZ lands as ‘reserved for affordable housing’.

The government hopes that the landowners will be lured by an incentive FSI of 3.0 FSI (currently entitled to 0.20 FSI) being offered if they come forward to develop their land for affordable housing. The 3330 ha of land in the DP ’34 continue to be reserved as NDZ and not changed to ‘AH’. This shows lack of commitment and mere lip service to ‘affordable housing’.

There is also clever sleight of hand in the math. DP 2034 suggests only 25% of the NDZ land to be developed for affordable housing, while 34% is permitted for any other development of the owner’s choice. Almost this entire NDZ land is privately owned. Assuming that all the land-owners of the 3330 ha NDZ land come forward to take advantage of the FSI-3 being offered, only 25% of that land, i.e. about 830 ha is available for affordable housing translating into 85,000 affordable units.

Sadly, the government has ignored the vast potential for developing affordable housing through redevelopment projects, especially on slum lands and under-utilized and decrepit MHADA colonies. Focused development of these lands by government agencies will not only rehabilitate the original inhabitants, but will generate housing for other poor and middle class families too. Instead, the government prefers to hand over these lands to private developers at no cost to allow them to reap a rich harvest under the concept of ‘cross-subsidy.

Nivara Hakk has submitted detailed plans and calculations for the redevelopment of the 3000 ha slum land and the 2000 ha MHADA land, wherein it is possible to construct 9 lakh affordable units (in the range of 300-700 sq ft per unit), thereby wiping out the entire housing deficit in the city. It is for this reason that Nivara Hakk has consistently demanded slum land to be reserved in the DP for affordable housing. But the authorities have not accepted this solution.

FSI hike and the build-more syndrome: Another distinct feature of the DP 2034 is the FSI hike allowed in both the city and suburbs. Government bureaucrats who unveiled the new DP argued that this measure will increase housing and office facilities and create 8 lakh jobs. We wonder on what this math is based on? Will the affordable housing shortage vanish by merely increasing construction volumes? Currently there are over 5 lakh vacant apartments, and over 30 percent of commercial premises in the city are unoccupied. Even if the FSI is hiked to infinity, will the developers keep building when there are no buyers because of unaffordable prices?

The new DP has also ignored the need to develop infrastructure and civic amenities in proportion with the increase in FSI. The government has in a creeping way been pushing up the FSI without planning for transportation and infrastructure. Jostling high-rise buildings coming up without adequate open spaces and amenities are further ‘slummifying’ the city.

Transit Oriented Development (TOD) with higher FSI, which was rejected by independent town planners and citizens groups in the draft development plan, has been re-introduced in the new DP 2034. This is another step towards irrational densification of Mumbai. Areas around existing railway stations are already bursting to its seams. Arriving and exiting from stations is a currently a nightmare for the city’s 7 million daily commuters. Congestion is high around all the 54 railway stations.

On what grounds is the government granting higher FSI along the city’s most dense transit corridors? Similarly, most metro lines are being constructed over or under the few major roads that we have. These roads are already congested. Traffic movement and dispersal is poor. Can we imagine the devastating impact of new buildings coming up with higher FSI along these corridors?

Overall, the DP 2034 has failed to address the crying needs of the people of Mumbai. The long-term adverse consequences on the lives of people and the environment will certainly be a matter of concern for now and the future.

P.K. Das
For ‘Nivara Hakk’
27th April 2018

Please Note: The implementation of DP 2034 has been announced through summary press presentations, but the entire document is not yet available to the public. Our reactions are thus based on these announcements. Once the entire Mumbai DP 2034 is made available, we will revert with a more detailed analysis.