SPTM-Letter-to-PMC-reg-draft-DP

25th June, 2013
The Municipal Commissioner,Pune Municipal Corporation,Shivajinagar,
Pune 411 005

Subject: Suggestions / Objections regarding the draft DP for Old Pune City (2007-2027)
Dear Sir,

SPTM, Save Pune Traffic Movement, is an NGO working for the transformation of traffic conditions of Pune and our feedback and suggestions are focused on the Traffic and Transportation part of the draft DP for Old Pune City (2007-2027).

SPTM collaborates with PMC's traffic planning and management officials to effect improvements required in the traffic infrastructure in order to improve safety, accessibility and efficiency of usage for pedestrians and vehicle users. SPTM has also submitted a detailed proposal to PMC, in November 2011, for revamping the traffic signaling system.

Please find enclosed feedback/suggestions from SPTM regarding the proposed revised CDP.
 
Yours faithfully,
Rajendra Sidhaye
Chairman,Save Pune Traffic Movement

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SPTM’s
 
Feedback/ Objections regarding the draft DP for Old Pune City (2007-2027)

Regarding the approach and time provide for review and providing feedback

First of all, the time provided by PMC for this purpose is too short. If you want to really invite suggestions & feedback from stakeholders, which requires that they study the voluminous documents, analyze them, have internal consultations before providing the feedback, you should provide minimum two months.
(A1) Objective of DP / this document
 
What is the Objective of this document? This should be made clear right in the beginning. The document starts by giving History of Pune City (Chapter 1) and its Climatology (Chapter 2) etc. But Why? Even Chapter 3 which, starts with 'Introduction', fails to give any Objective and the chapters 3 to 7 which talk about historical information about various plans fail to give any context for this document.
 
This shows complete unprofessional approach about this planning and the completely confusing way in which it is presented to the citizens of Pune.
 

(A2) What is the relation with CDP?

 
Just 2 months back, PMC had invited feedback about another planning document called 'City Development Plan (CDP) of Pune City -2041 under JNNURM'. What is the relation between that planning, that document and this draft DP document? Why this enormous duplication of effort and wastage of resources?
 
Since this Draft DP document has come later, it ought to explain, right in the beginning, how the two documents relate to each other and what was the need of doing these two separately.
 
Again, this shows complete unprofessional approach about this planning and the completely confusing way in which it is presented to the citizens of Pune.
 

(A3) Chapters 13 and 14 ( Traffic and Transport )

 
These chapters include completely unnecessary and redundant information since CMP of Pune, which has been approved by PMC, addresses everything related to Traffic and Transport, in terms of historical studies, current measurements, projections, and detailed recommendations to make sure that the measures taken up for Pune's traffic and transportation are sustainable and in tune with NUTP.
 

So, this Draft DP should only mention that Pune has CMP and should only mention:

 
(a) Which all recommendations of CMP have been completed so far as per the plan.
(b) Which all recommendations of CMP have not been completed so far as per the plan and why
(c) Projections / Plan regarding the future implementation of the recommendations of CMP
 
(d) If there are some things which PMC plans to implement, which contradict CMP, then the studies and justifications (including actual measurements and analysis, conducted to support these) MUST be included.
 
In fact there are many points which have been listed in the Draft DP, which contradict CMP without giving any justifications to support these. This again shows complete unprofessional approach about the planning and actually giving encouragement to the growth of private vehicles, while giving just a lip service to NUTP and sustainable transport. We mention few of such points which contradict CMP, below:
 
1. Adherence to the Comprehensive Mobility Plan (CMP)

1.1. Standing of the CMP

Please refer to chapter 13.5, page no 202 and chapter 13.5.10, pages 212 and 213. The DP refers to the Comprehensive Mobility Plan (CMP) for Pune as a "study". It should be noted that the General Body of PMC has approved the CMP, so it should not be noted as a mere "study".
The DP should explicitly say that the CMP would be followed. The DP should also explicitly say that

? Only the projects in the CMP would be implemented and

? Projects that are not in the CMP would not be implemented
 
1.2. Achieving desired modal share as per the CMP

The study and report by IIT Bombay and the CMP provide the status and objectives of the modal split of transportation as follows:

Modal split in 2008 as per Study and report by IIT Bombay)

Objective as per Comprehensive Mobility Plan (CMP)

Public transport (including rickshaw)

13%

40%

NMT (cycling and walking)

34%

50%

Personal vehicles

45%

10%

It is evident that Pune needs the following plans:

1. A plan to increase share of public transport,
2. A plan to increase modal share of cycling,
3. A plan to decrease modal share of personal vehicles.
 
The DP should include these 3 plans, which are totally missing from the DP. Further, several proposals in the DP will in fact increase the modal share of personal vehicles and thus go against the CMP. More about it in the following sections…

2. Contradictions with the Comprehensive Mobility Plan (CMP)

The following specific proposals in the DP contradict the approved CMP as well as are against the line of thought of the National Urban Transport Policy, hence they should be deleted from the DP:

2.1. Delete Statement 14-5 (30 flyovers)

Statement no 14-5, page 271 suggests 30 flyovers in the city. The CMP suggests only 10 flyovers and that too as a temporary measure. In fact, the CMP categorically states that flyovers encourage more use of personal vehicles and increase traffic congestion in the long run.
These 30 flyovers therefore contradict the CMP and will not fit in any plan to reduce modal share of personal vehicles. Further, no quantified justification or study has been provided as to why these flyovers are needed. As such, this proposal of 30 flyovers is completely ad-hoc and should be removed.

2.2. Delete Statement 14-6 (11 foot over-bridges)

No quantified justification or study has been provided as to why these over-bridges are needed. Foot over-bridges already built in the city are hardly used. Most of them are also not handicapped friendly and therefore discriminate against persons with disabilities as per the Persons With Disabilities Act, 1995, Chapter VIII. As such, this proposal of 11 foot over-bridges is completely ad-hoc and should be removed.

2.3. Delete Statement 14-7 (30 subways)

No quantified justification or study has been provided as to why these subways are needed. Subways already built in the city are hardly used. Most of them are also not handicapped friendly and therefore discriminate against persons with disabilities as per the Persons With Disabilities Act, 1995, Chapter VIII. As such, this proposal of 30 subways is completely ad-hoc and should be removed.

2.4. Delete tunnels and roads through/ on hills

The file Sec26_DP_SEC_II_TO_VI_26march2013_5.jpg (Map no/ Sheet no 5) shows a proposed tunnel through the Vetal Tekdi. Likewise, file Sec26_DP_SEC_II_TO_VI_26march2013_8.jpg (Mapp no/ sheet no 5) shows a proposed tunnel through the Waghjai/ Parvati hill.
These 2 files together also show a proposed road behind Balbharti that connects Senapati Bapat Road to Paud Road.
No quantified justification or study has been provided as to why these tunnels and roads are needed and how they will help Pune achieve the transportation objectives stated in the CMP. These tunnels and roads are not mentioned in the CMP. They will adversely impact Pune's already fragile ecology. Therefore these proposals are completely ad hoc and should be removed.

2.5. Delete proposal to subsidize parking

Chapter 19.3.1, page 330 of DP says that FSI or TDR will be given to builders who build parking facilities. This, in effect, subsidizes parking for personal vehicles and promotes their use. This proposal is also in contradiction with the objective of treating parking as a commodity, mentioned in the DP (Table 16-2, page 303). The said proposal also contradicts NUTP & CMP.
Therefore chapter 19.3.1 should be deleted OR amended to categorically say that the users (personal vehicles) will have to bear the cost of parking.

3. Issues with FSI of 4 proposed on Metro corridor

3.1. How to support the FSI, and from when?

Chapter 14.3.2 proposes an FSI of 4 for an area within 500m of the Metro corridor. This FSI will lead to a huge increase in the population of the corridor. However, the DP does not mention how facilities and amenities like sewerage, open spaces, schools, hospitals etc will be provided to this population.
Further, since the increased FSI assumes that the Metro will be built, sanctioning the increased FSI must be tied with the Metro's construction. What if the Metro proposal does not get approved for some reason? Therefore the DP must include the following:

1. A plan to provide facilities and amenities to the increased population.
2. A categorical mention that the increased FSI will be available only after the construction of the Metro begins.

3.2. Why 4 FSI and why within 500m of the corridor?

There is no justification provided about the number 4. Why not 3 or 2.5 or any other number? As such the proposal to provide FSI of 4 is completely ad hoc and should be removed/ justified.
The distance of 500m presumably comes from the notion that it is a walkable distance to reach the Metro station. This notion should be explicitly mentioned, else the distance of 500m is perceived as arbitrary.
Even in that case, people are going to walk upto the Metro station and not the corridor/ track. Therefore the increased FSI should be granted to an area within 500m of the Metro station and not the corridor.

4. Land reserved for PMPML is insufficient

The list of reservation shows only 20 Ha area reserved for PMPML. All PMPML depots in PMC area add up to 12 Ha today (and only 2 Ha in PCMC). Considering that:

  • PMPML has about 1500-1600 buses today and needs about 4,000
  • About 10% of PMPML buses have to be parked on roads today and not in the depots

It is evident that PMPML needs about 20 Ha additional space right now (total about 30-35 Ha. By 2027, PMPML's requirement would need about 60-70 Ha space. But he DP provides only 20 Ha space.
The DP should reserve about 50 Ha space for PMPML, over and above the reservations listed as of today.

5. Existing and proposed land use does not match

Statement no 20-7, page 356 says that the proposed land use for roads (Sectors I to VI) is 13.66% whereas as per Table no 7-9, page 102, the existing land use for roads is 15.99%.
The following 3 possibilities exist:

1. The ELU figures are incorrect,
2. The PLU figures are incorrect,
3. The DP proposes that some roads be removed.

The DP should be amended accordingly. In case of possibility no 3, the DP should state which roads are to be removed.

6. Proposals in DP are not NMT friendly

6.1. Wide roads are difficult to cross

The DP proposes some very wide roads as well as widening of existing roads. Pedestrians find it very difficult to cross wide roads. What provisions are proposed so that pedestrians can cross these wide roads?

6.2. Insufficient width of footpaths and cycle tracks

Please refer to the cross sections of various types of roads, provided at the end of the DP. They typically show a "pedestrian + cycle track" of 3.75m to 5.75m to be shared between pedestrians and cyclists. The issues are:

1. If the area is shared with pedestrians, it significantly slows down the cyclists and hence does not promote cycling. Pedestrians and cyclists must be granted dedicated ROW.
2. A width of 3.75m to 5.75m, even if there were no cyclists, cannot accommodate heavy flow of pedestrians, typically envisaged near Metro and BRT stations, especially considering that some of the width is lost in stairways and such structures that provide access to the public transportation.

It should also be noted that the PMC is getting street design guidelines developed from consultants.
Therefore it should be explicitly mentioned that these "typical" cross sections are only indicative and the micro design of the roads, including widths of footpaths, should be governed by IRC:103-2012 (Pedestrian Facilities) and other applicable IRC guidelines, the street design guidelines as well as the local situation.

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