Hyderabad Metropolitan Development Authority
Dear Sir, Sub: Your Revised draft Master Plan for Core Area.
Our visit to HMDA office at Green lands to inspect Master Plan ( M.P.) displayed.
Some initial comments.
Our fundamental objection to the Master Plan remains namely, absence of any plan to spread balanced growth throughout the State and concentrate on Hyderabad, now further narrowed down to ‘Core Area’ concept. This approach can never solve the problem of the so-called core area unless this plan of the so-called core area is made part of the master plan for the entire state and as part of a M.P to develop anti-magnet towns and cities. Subject to this comment, some comments on details of the exhibits are made below.
1. Circle-wise maps have been displayed. We need to obtain a copy each of these with better resolution for close study. We also need a copy each of the earlier circle-wise maps to compare the two sets and locate the changes.
2. In the map of Circle IX covering Begumpet and Umanagar, the name of the ST Francis Girls’ college has been wrongly stated as St Annes College. Also, the Country club is shown as a heritage building in a residential zone, whereas the club is functioning on a fully commercial basis.
3. Land use zoning regulations are ambiguous. It is stated that “the uses are not to be treated as exhaustive”. Some ambiguity in their definition cannot by the nature of things be avoided, but further clarity should be tried. A few examples:
I) hostels & boarding houses : banks; post offices; religious premises; clubs; appear under uses permitted under Residential Zone. Whereas, Hotels, banks, guest houses, restaurants, boarding houses, colleges, religious places, post offices, religious buildings, clubs, appear under uses permitted under Commercial use Zone also. Hotels, religious buildings, restaurants appear under Multiple Use Zone also. We consider, some scale of operations be prescribed in respect of these uses which are common to under different different types of land uses, such as number of staff employed, parking space required, requirement for independent premises site, minimum plot size requirement, width of road, etc., should be prescribed for permission in each zone.
II) Terms such as ‘service establishments’ under Use for Residential zone , ‘offices’ under Commercial use zone , ‘computer software and Hard ware units/ITES/ IT enabled services’, ‘work centres’, ‘computer software and hardware units’ should be clearly defined. Are ‘offices’ permitted in residential use zones? What about using a part of the residence as a resident’s own use eg, in the case of lawyers, doctors, consultants, etc?
4. The requirement of ‘green building’ should apply not merely to new government buildings but to all new buildings above a prescribed square metres ( reference para 4 (v) on page 13.
5. Water Bodies Zone ( para 7 ): The term ‘construction’ not permitted in the FTL and the buffer belt around the FTL should be clearly defined as “ any type of construction, permanent or temporary , and using any material not necessarily cement”.
6. Sites specifically reserved as Heritage Sites: Item 9 A) i) should mention under ‘special exemption’ incentives for owners/users of heritage buildings and sites. An incentive package should be prepared without further delay on the lines of the recommendations made by INTACH Hyderabad, chapter on 11.3.05.
7. Parking requirements ( page 20), item no b): It should be expressly stated that built-up areas must provide for visitors’ parking, parking for non-residential uses, etc. As of now, residences , on the contrary, display sign boards stating ‘visitor’s vehicles not allowed’ and security guards do not allow visitors’ parking in the parking space provided in a premise and compel them to park on the road.
C.C to: The Commissioner, Greater Hyderabad Municipal Corporation, Hyderabad
Hyderabad Metropolitan Development Authority
Dear Sir, Sub: Your Revised draft Master Plan for Core Area.
A large number of households do not have toilet facilities in their households, either individually or on a common basis. Particularly, migrant labour to Hyderabad mainly for construction work are not provided such facility either at their place of stay or during working hours. Please include a plan for provision of ample toilet facilities to each household either on an individual or sharing basis. Also, for the migrant labourers at their place of stay and at work site. And fix a suitable norm for such provision, such as number of persons to be served by a toilet. Please let us have your advices in the matter at an early date.
| Date: 29.12.09
The Hon’ble Minister for
Municipal Administration & Urban Development
D Block No: 345
Dear Sir, Sub: A stock-taking after expiry of BPS / CDS. Some observations and suggestions
A principal avowed objective of the CDS/ BPS scheme was to do away, once for all, all unauthorized constructions in GHMC / HMDA/ area and the areas of the other local municipalities, by regularizing those that conformed to certain prescribed requirements, and by eliminating those that did not, and to take effective steps so that in future, no further irregular construction takes place. Yet, a year after the closure of the scheme, we observe that this objective has been defeated. We make the following comments and suggestions re Buildings constructed in violation of the extant building regulations. In this connexion, we refer to our discussion with the Secretary, MAUD, cum Commissioner, HMDA on 10.12.09.
a large number of buildings which are irregular, completed prior to the last date prescribed for applying under the scheme, have not been applied for compulsory declaration under the scheme. Most of these have got undetected.
Detection of all such buildings may be a Herculean task. At the same time, at least on a sample basis, some could be easily detected; For example, those that are located within an apartment complex where owners of some flats have applied for BPS, the others who have not can be easily detected. Also, whether such a building has any floor in excess of the sanction may be checked This will be a signal to others. Deterrent action can be taken in such cases.
A large number of buildings were completed after the expiry date of the BPS, in the hope that these would also be similarly regularized in course of time if a situation of fait accomplice is created for the authorities as in the past. New constructions are still being made in violation of the building rules. These cases have not been detected to any substantial extent.
It is possible to do so by reference to aerial maps which GHMC reportedly has on or recent to 15.12.08 , and compare them to their latest map, to detect (a) new buildings that have come up and (b) whether these are as per sanction. Even the height of a building indicating the number of floors could be ascertained from such maps. If such capability do not exist in GHMC now, it should be built within a specific time period.
GHMC often pleads lack of adequate field and office staff to monitor and detect cases of violation.
This may be true to a large extent. And the problem of "paucity of staff" will remain for some time. We have to learn how to maximize the effect of the resources. One way is selective and sample intelligence gathering, an example of which is given under the first suggestion above (namely, scrutiny of multi-storied apartments where not all apartments' owners have applied for BPS). Another way is taking of action with promptness in cases detected so that a message goes that action will be taken and many others are deterred from violating. A third way is to increase the network of intelligence through liaising with residents' organizations and forming ward committees. Finally, all complaints received from civil society groups/ individuals should be promptly looked into and action taken. This will have a deterrent effect on delinquents. At present the message on the contrary is that violations will go with impunity, and that complaints will not be looked into. This breeds a culture of permissiveness among builders/ owners and a sense of despair among sincere complainants.
Another plea taken, often rightly so, is that of interference by corporators, M.L.As, MPs and even Ministers, and higher officials in protecting violators selectively. Very often corporation is prevented from initiating legal action; This is indeed a real problem
A way to overcome this phenomenon is to bring such cases into the public domain. Here, civil society can play a major role. CSOs may inform the press, to make stories; confront the concerned public representatives/ officials by writing letters to them and asking for information even under RTI. C.S.Os may take up such matters with the party chiefs or the departmental principal secretary or even the Chief Secretary. Ward committees as well as Area Sabha Committees should be formed in the manner prescribed under GHMC Act. Municipal Act(s).
GHMC/HMDA may give such information leads through the aforesaid ward/ area sabha committees. The latter bodies may also review all cases of violations.
On the contrary, there is often complaint by builders that Municipal officers, particularly at junior levels and at zonal office levels insist on bribes even for clearing a plan prepared as per regulations. Also, they selectively inspect buildings where payment of bribe money is refused and overlook buildings where underhand money has been paid.
No action was contemplated in the earlier BRS / BPS or CDS against the builders while the builders are the ones who have actually corrupted the supply side of the market, so much so that for an honest buyer it is hard to find any building, which does not violate the building rules in some way or other, such as insufficient set back/ additional floor(s)/ pent house, etc. Further, the builders have cleverly built into their pricing the cost of forfeiting a floor kept under lien under G.O 86.
The Corporation therefore should have a mechanism to register meticulously applications for approval and monitor applications pending beyond one month. This list should also be placed before an appropriate higher authority to be prescribed and may be reviewed periodically (say quarterly) by the concerned ward committee..
The Ward/ Area Sabha committee should be carefully constituted as per provisions and so that they are bereft of partisan considerations/ vested interests and do not pressurize for payment of bribes. Levied as processing charge.
A suitable G.O. should be issued to take measures against any builder who violates the building regulations in any manner. To start with, heavy fine should be imposed equivalent to twice the value of the additional construction. There should be provision for forfeiting the license of a violator builder
Also, there should be a system of supervising all buildings above a certain value, and a good percentage (say 10 %) of other buildings, through authorized agents.
vii) It is not clear from the CDS cum BPS what action is contemplated in respect of i) those buildings that were not declared under BPS or ii) which do not qualify for regularization on payment of penalty, iii) or which have been constructed after the expiry of the last date of application under the scheme. Will these be demolished? Will they be fined at a far higher rate than that applicable to those that applied and qualify?
We propose following action:
i) Sample checking of apartments in a multi-storied complex should be conducted; the suitability or otherwise of regularization of deviations should be examined. If deviation permits of condonation by paying penalty, the penalty should be levied thrice the amount which would have been payable if the apartment would have been declared on time for regularization. In cases, where the deviation is beyond the scope of regularization, demolition of the additional built portion with fine plus recovery of cost of demolition, may be considered.
ii) It is not necessary nor feasible to do such checking for all buildings, but if sample checking on a random basis is done, it will have the desired effect.
iii) Buildings constructed, or additions made to existing buildings, after the expiry of the last date of application under the scheme should be demolished partly or wholly, covering constructions in violation of sanctioned plan, plus recovery of the cost of demolition and penalty for making unauthorized constructions.
iv) The High Court should be approached in advance to issue instructions to the lower courts that no stay can be granted by lower courts against an order of the concerned governmental authority and that such discretion will lie only with the High Court ( if such an order has not already been passed).
Simultaneously, the accountability of section officers, planning officers of the GMHC/ HMDA/ Municipalities should be examined for violations in their area(s) of operation, and an assessment of their performance made on the overall compliance with building regulations in their respective areas.
In this connexion, we have also to point out that the following undertakings given to the Court on behalf of the government, in respect of W.P. No 1069 of 2008 were not complied with:
Counter affidavit dated 9.2.2008 on behalf of Pr. Secretary to Government, MAUD: Paragraphs 4, 6 – a, b, h, k, m. 10, 13. In similar vein, undertakings dt 6.2.09 Commissioner, Vijayawada Municipal Corporation in 7. 8. 9. 1 was not complied with. We would like to have your specific comments in respect of such undertakings. The affidavits are copied and enclosed for your ready reference. The statements made by the Secretary, MAUD to the A.P. High Court in its counter affidavit dated 9.2.08 in W.P. No 1069 of 2008 do not reflect the true state of affairs and remain mere statement of intentions. For example, in reference to paragraph 6 thereof, in how many cases has there been any enforcement of the “stringent provisions” of G.O. no 86 dt 3.3.2006? Such as, non-connection of electric power, water supply, drainage & sewerage; inspection by Fire Services Department and abiding by their report; Issuance of occupancy certificate; “summary demolition” of violated portion of a building; administration of warning followed by de-licensing of habitual violator builders; check by Enforcement Authority against violations; constitution of Building Ombudsman? None of these provisions have been enforced, and there seems lack of a will to do so. The violation, contrary to the counter-affidavit dated 6.2.08 by the Commissioner of Vijayawada Municipal Corporation do “hamper the basis idea of urban planning”.
The whole exercise in BPS so far seems to be only a game for raising money, without fulfilling its ostensible purpose of making Hyderabad and the State clean, once and for all, of unauthorized constructions. Hyderabad continues to be infested with illegal structures. On the contrary, the BPS and its lack of enforcement has encouraged start of further unauthorized constructions as no substantial action has been taken against the violators in a visible manner. It gives a message that violation pays, as the cost of regularizing through penalty is less than the cost of violations and / or that violations will largely go unnoticed / unpunished. There is consequential damage to civic amenities, such as use of road, drainage, sewerage, water supply, open space, environment, etc. The balance between ‘compassion’ for the violators and the clean living environment for the law-abiding citizens has been lost in favor of the former.
In this connection, we refer to the Hindu report dated 30.8.09, captioned “Stop political support for illegal constructions – Builders have scant respect for regulatory laws: Supreme Court”, particularly paragraph 1 thereof. A copy of the news item is enclosed.
| Date: 24.2.2009
To Date: 24.2.2009
Shri V. Premchand
Chief Executive, Secunderabad Cantonment Board.
Dear Sir, Sub: Trees block SCB road widening.
We refer to a report under the above caption appearing in the Deccan Chronicle of date , stating , inter alia, that you may require to remove over 600 fully grown trees , some of them around 100 years old, along either side of the road from Mahendra Hills to Rashtrapati Nilayam and from Safilguda railway crossing to the Secunderabad club to widen the roads. We are encouraged to note that you are considering the option of transplantation and translocation of these trees as far as possible, and have provided funds for there for. Such translocation should be made as near the existing site as possible.
A copy of the press report is enclosed for ready reference.
In this connection, we would like to bring to your notice that as a result of protracted negotiations between us together with other civil society groups and the various wings of the state government, such as the R & B department, HMDA, HMWS & SB etc, and under the guidance of the State Chief Secretary, and the Forest department , an arrangement has been arrived at under which it will be feasible to preserve the existing trees while widening the roads. G.O. No. 539.Dt. 11.12.2008 lays down detailed guidelines considering all possible circumstances , in this regard. We enclose a copy of the G.O. for your perusal and request your strict compliance therewith.
In this connection, we also wish to mention that successful transplantation has taken plantation at Hyderabad at moderate cost. The particulars of such project (s) are attached.
We are sure you will take immediate steps so that not a single tree is felled along the route, and strict compliance is ensured with the above-mentioned G.O. Utmost importance needs to be given to conservation of trees. For any further discussion in the matter, please call us and we can meet at our mutual convenience.
| Date: 24.2.2009
Dr.K.S.Jawahar Reddy, I.A.S
Hyderabad Metropolitan Development Authority
Greenlands Guest House, Begumpet
Dear Sir, Sub: Master plan for Hyderabad Metropolitan Area.
We understand that you have taken up the preparation of a master plan, and that the work of preparation of a plan is in an advanced stage. We consider that the concerned civil society groups should be informed and closely involved in the process of planning so that there is democratic participation in the process of planning and the inputs and concerns of various stakeholders and affected parties are duly factored into the plan. We are sure you will agree with this approach. A contrary approach will create problems for all and delay matters. We await your advices in the matter.
| C.C to : Dr. C.V.S.K.Sarma, IAS, Prl.Secretary to Govt.MA & UD., Secretariat, Hyd.
| Date: 24.2.2009
Sri. S.P.Singh, I.A.S
Commissioner & Special Officer
Greater Hyderabad Municipal Corporation
Lower Tank Bund
Dear Sir, Sub: Master plan for erstwhile MCH area.
We understand that you have taken up the preparation of a master plan covering the area of the erstwhile MCH, that you have engaged the services of IIT, Kharagpur for drawing the plan and the work of preparation of a plan is in an advanced stage. We consider that the concerned civil society groups should be informed and closely involved in the process of planning so that there is democratic participation in the process of planning and the inputs and concerns of various stakeholders and affected parties are duly factored into the plan. We are sure you will agree with this approach. We await your advices in the matter.
1. Dr. C.V.S.K.Sarma, IAS, Prl.Secretary to Govt.MA & UD., Secretariat, Hyd.
2. Dr.K.S.Jawahar Reddy, IAS., Commissioner, HMDA, Greenlands Guest House, Begumpet, Hyd.
The Divisional Forest Officer,
Sub: Annapurna studios, Survey no 403, village Shaikpet, Golkonda Mandal, Area: 22.03 guntas, Town survey no 1, Block no B, Ward no 9.
According to sources, Annapurna Studios is going to have a swanky new entertainment complex on its premises. For implementation of the project, the Studios reportedly plan to cut down the forest, known as 'Seven Acres', which is used extensively for forest scenes in movies. The Studios reportedly plans to build malls and multiplexes on that land.
Please let us know whether the studio owners have applied for any permission to you; whether you have given any permission to him or to anybody else for the felling of trees in the above premises, and if so, the details thereof, including any plan for translocation of the trees. Meanwhile, we request you not to grant any permission for felling the trees, and to cancel any permission if already given.
The Commissioner & Special Officer,
Greater Hyderabad Municipal Corporation,
Sub: Annapurna studios, Survey no 403, village Shaikpet, Golkonda Mandal, Area: 22.03 guntas, Town survey no 1, Block no B, Ward no 9.
According to sources, Annapurna Studios is going to have a swanky new entertainment complex on its premises. For implementation of the project, the Studios reportedly plan to cut down the forest, known as 'Seven Acres', which is used extensively for forest scenes in movies. The Studios reportedly plans to build malls and multiplexes on that land.
Please let us know whether the studio owners have applied for any permission to you; whether you have given any permission to him or to anybody else for the felling of trees in the above premises, and if so, the details thereof, including any plan for translocation of the trees. Meanwhile, we request you not to grant any permission for felling the trees, and to cancel any permission if already given
|Radial ring road survey by the Forum, NGOs , Forest Dept, ORR Engineers
|The surveillance team observing the proposed Radial Ring road map
|the team inspect the requirement of tree transplantation to facilitate Radial Ring Road
|A tree, about to be removed with roots for transplantation
|Tree with roots being shifted to transplantation site
|A transplanted tree
Sri K.S. JAWAHAR REDDY, I.A.S.,
Hyderabad Metropolitan Development Authority,
|Sub: Tree-cutting near Hi-Tech city junction for proposed flyover – Reg
We refer to the report in Times of India of 28.9.08, pages 1 and 3, stating that 15 pupil trees have been chopped off near the Cyber Towers in Hi-Tech city for a proposed fly-over. The trunks, however, still remain. Copies of the reports are enclosed.
We request you to immediately arrange for further suspension of the cutting.
In this connation, we wish to inform you that pursuant to our meeting with the Commissioner & Special Officer, GHMC following the felling of the banyan tree in front of the US Consulate office, the GHMC has suspended all felling of trees for which they had received permission earlier, and has refrained from felling any further trees. In one case, where some trees were felled due to non-communication of their instructions internally, they have transplanted the stubs. The Forest department has suspended all permissions earlier given and are not giving fresh permissions. GHMC has appointed a special experts’ committee to re-examine all approvals earlier granted and new requests proposed. The Forest Department has almost finalized their committee.
Pursuant to our subsequent meeting with the Chief Secretary, and the Principal Chief Conservator of Forests, a decision has been taken at the highest state level to give utmost consideration to the conservation of trees and that an expert committee will be formed to examine afresh all permissions already given or to give fresh permissions. Till such fresh permissions are received, felling of trees will be stopped.
Before applying for permission for felling of a tree, the concerned project authority must examine if any modification of the project can be made so as to save the trees, such as realignment of a road, relocation of a construction, redesigning, etc ( in this case the fly over). For this purpose, it may refer to a suitable technical committee, if it cannot decide on its own whether modification is possible, and where the concerned requisitioning authority states that modification is not possible. If modification in project so as to save the trees is not possible, the project authority will examine the feasibility for transplantation of the trees proposed to be felled. The cost of transplantation of trees should not be considered a bar and should be treated as part of the project cost. Only in the rarest of rare cases, will an application be made for felling of trees, after all options have been exhaustively explored. In those cases, prior compensatory plantations must be arranged sufficiently in advance, of matching species, in a proximate location.
All project authorities must incorporate tree conservation as part of their project plan and project cost and include it in the DPR.
Further, even as of now, WALTA 2002 and the WALTA Rules 2004 provide for obtaining of prior permission for felling of trees from the Implementing Agency, which is the Forest Department. Without obtaining such permission, tree felling is violation of the laws.
We, therefore, request you to immediately stop any further felling of trees for which you may have already obtained permission until such permissions are revalidated by the Committee. Please also appoint an internal committee to re-examine all such permissions after considering all options as mentioned in a preceding paragraph, and submit afresh applications to the implementing agency, Forest department. . Please strictly ensure against any felling without prior permission from the Forest department. Please instruct your officials and contractors to strictly abide by such instructions. Meanwhile, please do not proceed further by uprooting the trunks of the trees whose branches have been chopped off.
We request your full co-operation to conserve and promote the green cover of Hyderabad and the HMDA area
|Cc to: Sri. K. S. RAO. I.F.S. Principal, Chief Conservator of Forests, Sri. M.J. AKBAR, I.F.S. District Forest Officer, Hyderabad & RangaReddy Districts.
Sri K.Jana Reddy
The Hon’ble Home Minister,
Sub: Prevention of discharge of duty of GHMC officials by a group including two legislators – reports appearing in the Hindu, Deccan Chronicle and Times of India, etc.
We are shocked by a report appearing in various newspapers of an incident at Chapel road, Abids on 26.7.08, stating that the officials of the GHMC were prevented by a group of persons led by two legislators, from demolishing portions of a building constructed in violation of rules. One MLA fired two shots in the air from his revolver. This group blocked the road for several hours. Police let go the legislators without filing any charges against them on the plea ( as reported in Deccan Chronicle dated 28.7.08) that no civilian had reported to the police on individuals opening fire. Instead the police filed FIRs against the GHMC officials , including the chief city planner under CPC section 307 ( attempt to murder), 147 ( rioting), and 148 (rioting armed with dead weapons), read with 149 (unlawful assembly). Prima facie, the police’s plea for not filing charges against the legislator firing his revolver is untenable – we are not aware of any provisions of law under which the police was prevented from taking suomoto cognisance when the incident occurred in full view of the police and photographs of the incident appeared in several news papers the next day. Equally unconvincing appear the charges framed by the police against the corporation officials.
When wide publicity to the incident was given in the news papers for several consecutive days, the police booked a case (Cr.no.268/2008) against one MLA under sections of the Indian Arms Act, section 353 and section 506 of IPC, and nuisance case against the group of persons for disrupting the traffic, after having received a complaint from the GHMC officials. According to the police the case against the MLA was booked on the day of the incident i.e., 26.7.08 but this was reported in news papers only on 29.7.08. ( TOI dated 29.7.08). According to some reports the case was booked only on 28.7.08.
As you are aware, there is virtually no effective implementation of the Building Regulations in the twin cities and elsewhere. As a result, the state government had to pass BRS and now BPS, with a hope that hereafter there will be no illegal constructions in the city which aspires to be of world class standard.. Alas, if this is the fate of the law-enforcing authorities trying to perform their legitimate functions , and the law breakers go scot free, which official will hereafter like to perform? Besides, it is shocking that this violation is led by some MLA s who are supposed to make laws, not break them. Any public representative deserves our respect, but no one is above the laws of the land. For the sake of good governance, and to motivate officials and citizens to ensure compliance with law, immediate action is warranted against the persons who created the disturbance and violated the law. Action should be taken against the concerned police officials for failure to act promptly. We request you to order a high-powered enquiry immediately into the incident, and to make public its findings and action taken on its report. Unless these steps are taken, public officials will be highly demoralized and the public’s confidence in the administration will get seriously eroded.
We shall appreciate to receive a response to this letter
Sri.B.Prasada Rao, IPS.,
The Commissioner of Police
Basheer Bagh, Hyderabad
Sub: Inaction of police against two legislators forcibly preventing discharge of duty of GHMC officials by a group including two legislators – reports appearing in the Hindu, Deccan Chronicle and Times Of India, etc.
We are shocked by a report appearing in various newspapers of an incident at chapel road, Abids on 26.7.08, stating that the officials of the GHMC were prevented by a group of persons led by two legislators, from demolishing portions of a building constructed in violation of rules. One MLA fired two shots in the air from his revolver. This group blocked the road for several hours. Police let go the legislators without filing any charges against them on the plea ( as reported in Deccan Chronicle dated 28.7.08) that no civilian had reported to the police on individuals opening fire. Instead the police filed FIRs against the GHMC officials , including the chief city planner under CPC section 307 ( attempt to murder), 147 ( rioting), and 148 (rioting armed with dead weapons), read with 149 (unlawful assembly). Prima facie, the police’s plea for not filing charges against the legislator firing his revolver is untenable – we shall be glad to know under what provisions of law was such a stand taken and why the police did not take suo moto action when the incident occurred in full view of the police and photographs of the incident appeared in several news papers. Simultaneously, the charges against the corporation officials appear unconvincing.
When wide publicity to the incident was given in the news papers for several consecutive days, the police booked a case (Cr.no.268/2008) against one MLA under sections of the Indian Arms Act, section 353 and section 506 of IPC, and nuisance case against the group of persons for disrupting the traffic, after having received a complaint from the GHMC officials. According to the police the case against the MLA was booked on the day of the incident i.e., 26.7.08 but this was reported in news papers only on 29.7.08. ( TOI dated 29.7.08).
The handling of the situation by the police officials was neither fair nor prompt.
We request you to take immediate action in the matter. We shall appreciate to receive a response to this letter.
The Chief General Manager,
Outer Ring Road
We understand that a large number of projects for road widening, and other developmental activities, although sponsored by different departments, such as R & B, etc., have been entrusted to you for execution. Many of them for their execution, if implemented in a routine manner without any imagination and sensitivity, may require the removal of trees on the route / in the area.
Hyderabad is fast losing its green cover and the quality of the environment, which should cause concern, specially in the context of global warming, to one and all, more so to people in decision-making and authoritative positions. A good infrastructure is of no consequence if the environment is polluted beyond tolerance. In this context of the widespread felling of trees in the twin cities for road widening and other projects, we had taken up the matter with the Commissioner & Special Officer, GHMC, the Chief Conservator of Forests, the Secretary, R & B , and also the Chief Secretary. The Commissioner has immediately issued an order for his officials that all permissions received by his office for tree-cutting should be held in abeyance. The Forest department is re-examining the permissions already given and has kept in abeyance issue of further sanctions.
We request you to re-examine the sanctions that may have already been received by you for felling of trees, and defer action on all existing permissions received by you for tree-cutting. Please also refrain from applying further for felling of trees without exhausting all other options .
As a general rule, we request you to consider the following options:
1. Every effort should be made to bypass a tree as is done for sensitive religious structures. And imagination should be applied for re-aligning the roads, without decreasing its width. This is possible .
2. Transplant an existing tree to another location, irrespective of the cost. The technology and local expertise is available for such exercise which is not prohibitively expensive.
3. Before asking for permission for felling of a tree, every other option to circumvent the cutting should be explored.
4. Expert advice should be taken for this purpose.
5. To ensure proper application of mind, a request to cut a tree should be made by a high-level authority and not at a junior level, in a routine manner, as is now done.
6. A committee approach, involving experts and appropriate NGOs, should be taken for arriving at such decisions.
Further, we request you also to make an advanced planning for conservation of trees that would interfere with your projects. For this purpose, please
examine how your projects under the master plan, and those contemplated outside it, which take quite a few years to be finalized, will affect the existing trees on location. If no such scrutiny of the impact of your projects on the existing trees on the location has been made, in terms of the Master plans and your sub-plans, we request you to do so now and advise us.
Of the trees that would interfere with the projects, some trees can be transplanted, for others compensatory plantations can be taken up well in advance, and proximate locations of compensatory planning be earmarked as such, as essential part of the planning for these projects. This would ensure that replacements of the right species and age are ready when a tree has to be removed.
In fact, we insist that any planning should be holistic and should take into account the effect on environment and greenery, and how such adverse impact can be made up.
We request you to kindly take up this crucial exercise now in coordination with the HUDA/GHMC/Forest department.
We are sure that you have noted that the above suggestions are completely practicable and rational and easy to follow.
We trust you will take our request in the right spirit and take urgent, necessary action. We are ready for a further discussion with you. Please keep us advised.
President, Forum For A Better Hyderabad
|C.C to: 1. The Vice Chairman, HUDA, Hyd.
2. The Principal Chief Conservator of Forest, Aranya Bhavan, Hyd.
3. The DFO, Hyderabad and Ranga Reddy Districts.
The Chief Executive Officer
The Secunderabad Cantonment Board.
Court Compound, S.P. Road,
Sub:Road widening – impact on conservation of trees/Protection of heritage structures.
We refer to a report in the Hindu dated 21.6.08 ( copy enclosed) stating that you have received the permission to widen eight roads , of which two roads in the first phase will be taken up soon viz’, the 8 km road from Mahendra Hills to Military College of Electrical and Mechanical Engineering via Military Hospital and another 5 km stretch from Safiguda railway station up to Secunderabad club via AOC gate.
You are aware of the Regulation no 13 of the HUDA Zoning Regulations 1981 under which no Heritage building ( HB) or Heritage precinct ( HP) can be affected in any manner by any developmental activity, without prior approval of the Heritage Conservation Committee ( HCC )appointed by the state government. Please, therefore, examine the location of HB/HP on the routes for widening, and ensure that the former are in no way affected. You may also immediately refer to the HCC .
We also draw your attention to sections 29 (1 ) and 29 (2) and also to 30(1) of A.P. Water, Land & Trees Act, 2002 and the Rules 2004, which state:
29(1) : “ Any person, institution, organization or department, public or private, providing a public or private utility service including Roads and Buildings department, Energy department of the Government and Telecommunications Department shall ensure protection of trees and their branches while developing their infrastructure or carrying on their activities”. This is not enforced.
29(2) : Wherever laying of new roads or widening of existing roads involves cutting of existing trees,, the Authority may issue suitable guidelines for protection of such tree growth as it deems fit.
30(1): The Authority may formulate guidelines for tree plantations along with the road margins, canal banks, tank-fore shores, and water bodies.
Please, therefore, study the impact on trees existing on the routes and you are required to protect these trees under the aforesaid Act and the Rules. In fact, tree conservation should be an integral part of your plans for road widening. For this purpose, as a first option, please align the roads in such a manner that the existing trees are not removed. Please examine this seriously and sincerely and if necessary, take the help of outside experts. In case this is not found feasible, as a second option, please arrange for the transplantation of the trees( 2(11) of WALTA) to a nearby location - technology and local experts are available for such purpose, and the cost which should be of no consideration, is not prohibitive. You may refer to us for contacts of such expertise.
If you at all have to apply to the Forest authorities, who are the Implementing Agency under WALTA for trees, for removal of trees , you may explain in detail the exercises you have undertaken before so applying Further, we request you, independent of our aforesaid representation, to plant a canopy of trees along the roads to create the much – needed green cover, as suggested in the Hindu dated 21.6.08 under the caption “ Line up the green goblins to welcome you”. A copy of the relative item is enclosed.
We trust you will take our letter in the right spirit and sincerely work to save the existing trees on the roads proposed to be widened. Meanwhile, please send us a detailed map of the routes of the proposed road widening.
Thanking you in anticipation
President, Forum For A Better Hyderabad
|C.C : 1.The Chairman, Heritage Conservation Committee for suitable action.
2.The Principal Chief Conservator of Forests, A.P.state government, for suitable action.
3.The DFO, Hyderabad and Ranga Reddy Districts, for suitable action.
4.The Vice Chairman, HUDA, Hyderabad, for suitable and immediate action. Such action should be taken before inviting tenders for the work and notifying changing the Defence land from category A-1 to C to permit widening.
5. The Commissioner and Special Officer, GHMC, for suitable and immediate action
Sri Koneru Ranga Rao
Hon’ble Minister for Municipal Administration
and Urban Development
Govt. of A.P., Secretariat
Dear Shri Ranga Rao gaaru,
Sub: Building Regularisation – Concerns/Objections
|We would like to take this opportunity to raise our concerns on the proposed Building Regularization Scheme being proposed and as per the news paper reports this scheme has been approved by the Cabinet of which you are a senior member. Sir, as per the same news paper reports we have come to know that the government is about to issue these orders to regularize almost all the Building Rules violations across the state by reinforcing the same through an ordinance.
As an organization which has been engaging the government and citizens of Hyderabad and surrounding areas consistently over the years on issues like Master Plan, Conservation of water bodies, pollution etc and even knocking the doors of the court as a last measure we are dismayed and deeply disappointed with the decision.
We fail to understand the reasons behind the decision. If the intention is to safeguard the rights of people in the urban areas of this state as is being declared by some quarters, we fail to see how this decision will serve that purpose. This decision of yours will, on the contrary put law abiding citizens in an unhappy situation and result in hardships to them. It will lead to increased pressure on Environmental attributes and civic amenities of cities which are already in a poor shape. An innocent law abiding citizen will be put into a proverbial pan-to-fire situation.
This decision will also lead to a situation where unscrupulous builders feel emboldened to persist with their illegal ways and continue building many more structures which are not safe and/ or healthy for the inhabitants as well as put the civic amenities under pressure. This decision will lead to more violations in the future as the state will be seen a soft state which cannot take harsh but necessary decisions and enforce the same.
We fail to understand how the government proposes to address future violations if it cannot address them in the present. Instead of initiating action against the builders as well as errant officials in the harshest manner possible to set the standards of administration really high it seems to have opted for an easy way out of the mess for which it is solely responsible. The bonus of hefty compounding fees seems to have been another inducing agent.
Sir, for a few hundred crores of rupees you are embarking on a journey which will forever condemn the fate of Urban Andhra Pradesh by designating it for a haphazard, unplanned, choked and dirty area to live in. The existing building rules are the product of sound scientific principles of planning and sustainability and play a major role in ensuring the healthy growth and survival of a city and its citizens. If necessary, the rules could be changed and made practically applicable. But, while keeping the same rules, accepting violations, now and then, make people lose faith in the rule of law. The previous attempt of regularization still remains unfinished.
In such circumstances, the judiciary also may not recognize such measures as legitimate, if we go by previous judgments. One of the most recent judgments by the Hon’ble High Court of Tamil Nadu in (W.P.Nos.18898 of 2000, 19998 of 2001, 24316 of 2002 and 17646 of 2006) has reiterated the illegality of such acts. In W.P.No 25011 of 1998 the Hon’ble High Court of Andhra Pradesh has declared that regularization scheme announced in 1998 in Hyderabad was illegal. Government in that case promised not to allow regularization in future. In CONSUMER ACTION GROUP -VS- STATE OF TAMIL NADU ((2000) 7 SCC 425) the Hon’ble Supreme Court held that BRS can be allowed only as a one time measure and cannot be continued in perpetuity.
In view of the above, we urge you to initiate consultations with the concerned sections of the society, i.e. the representatives of the residents, owners, builders, architects, town planning officials, police, before launching any new regularization process.
President General Secretary
Forum For A Better Hyderabad Forum For A Better Hyderabad
Mobile: 9848044713 Mobile. 098480 97188
1. The Chief Secretary, Govt. of Andhra Pradesh, Secretariat, Hyderabad
2. The Principal Secretary, MA&UD, Secretariat, Hyderabad
3. The Commissioner & Special Officer, GHMC, Hyderabad.
4. The Vice Chairman, HUDA, Begumpet Hyderabad
5. The Director, Town and Country Planning, Hyderabad
|10th July 2007
|To, 10th July 2007
The Principal Secretary,
Government of Andhra Pradesh, Secretariat
|Sub: - Objections/Suggestions on Revised Draft Master Plan in HUDA Area.
The Round Table discussion held on 9th July, 2007 at Institute of Engineers, Khairtabad from 10 a.m. to 1 p.m. on the proposed Hyderabad Master Plan was participated by a number of Civil Society Organisations and Public-spirited individuals, discussed threadbare issues related to the Master Plan in the interest of the formation of Greater Hyderabad Municipal Corporation and the Hyderabad Metropolitan Area.
A power point presentation was made before the participants, to initiate the discussion. The participants unanimously endorsed the contents of the PPT. A copy of the PPT is enclosed.
The participants overwhelmingly felt that the process of Master Plan preparation by the Ministry of Urban Development, Govt. of A.P., is very faulty and undemocratic. We believe that there are several Master Plans in the HUDA area, some are finalized and some are under preparation. (Viz., CDA, HADA, forming MCH, HUDA, HMA, Cantonment etc.,) No Plan can be prepared for one particular area in such a situation.
The participants felt that the Master Plan should have a statement of purpose, vision, mission and objectives. Reference can be made to the recent MP of Delhi in this regard. The Draft Master Plan for Delhi-2021, put up for Public Notice ( the Gazette of India) by the Delhi Development Authority - ( See link http://www.dda.org.in/planning/draft_master_plans.htm ) has a written Vision and Policy Statement for development of the region around Delhi city ( for balanced regional development and decongestion of the main city ) and approaches adopted in planning various sectors, preceding the land-use maps, which is not provided with the Revised Draft Hyderabad Master Plan. The Plan published in 2003 also has not included the policy stating the direction of growth when compared to the topics covered by the Delhi Master Plan.
Participants felt that the state government must first comply with its undertaking for various measures of local self-government given as per the MOU with the Central Government under the JNNURM. There should be concerted pressure upon the government to do so.
Road widening plans should be undertaken after proper traffic flow study, and after planning for ample tree plantation in lieu of the fast dwindling but yet partially existing tree corridors along some roads which may disappear by Elevated Railways/BRTS.
The participants felt that the absence of a Master Plan permits all parties including the state government to take ad hoc decisions and actions. At the same time it should be framed in the proper manner.
We demand that the Government of Andhra Pradesh should prepare a Single Draft master Plan by incorporating all the existing plans (completed as well as those under preparation) in the coming 3 to 6 months. Such Integrated Draft Plan should be made available in English, Telugu and Urdu for individuals and the public so that meaningful suggestions could be made after public debate. This process cannot be complete without a regional plan for the area.
We also demand the Government of Andhra Pradesh take immediate measures to constitute Metropolitan Planning Committee (MPC) and follow the provisions of the 74th Constitutional Amendment.
Forum For A Better Hyderabad
Mobile: 98480 44713; Fax: 27635644
1. The Chief Minister, Govt. of Andhra Pradesh, Secretariat, Hyderabad.
2. The Minister, Municipal Administration and Urban Development,
Govt. of Andhra Pradesh, Secretariat, Hyderabad.
3. The Chief Secretary, Govt. of Andhra Pradesh, Secretariat, Hyderabad.
4. The Vice Chairman, HUDA, Begumpet, Hyderabad.
5. The Commissioner, Greater Hyderabad Municipal Corporation, Hyderabad
| Date: 7.6.2007
MA & U.D. Department
Need for extending the time for Public comments on the proposed master plan of HUDA.
We observe that the time of 15 days given to the members of the public to scrutinize and comment on HUDA’s Master Plan (MP), displayed centrally at HUDA’s office is too short and not fair to the public for whom the plan is intended and who will be affected by it. The time limit for inspection and comments must be extended . The MP has long standing implications, is central to all other development plans, and the approaches and decisions taken in the MP are usually not subject to change. The MP is of a strategic nature.
When the previous MP was displayed , it was displayed for comments for a much longer time. A printed version of the MP was also available for closer scrutiny. Finalisation of such a plan takes a long time as would be evident from the fact HUDA took so much time to present a revised plan after receiving public comments.
We have to point out the following further points in support of our request to extend the time for Public comments on the proposed master plan.
The public notice inviting comments has not been properly displayed by giving prominent ads in the newspapers and television.
The population of 65 lakhs has been given only 15 days (including holidays) to file submissions.
The maps of the master plan are being displayed only at one place for the public to come and see, which is a very centralized form of display and inconvenient to a large number of population. It is not a realistic approach.
The new Zonal Development Plan maps are not being sold to the public which means the people have little opportunity of going through the details at their own pace and place.
All the maps are exhibited on large display boards that make it difficult for anybody, particularly, the elderly/ physically challenged people to spend time standing in front of them to look at the particulars in the map in detail.
We, therefore, urge upon yon you to extend the time to at least three months. Please also bring out a printed version of the draft plan, within say two weeks from now, which can be purchased by interested persons and organizations for scrutiny at their own pace.
Many other persons and organizations, who are not members of the Forum have expressed the need for extending the time for inspection of the Master Plan and comments thereon
Forum For A Better Hyderabad
Mobile: 98480 44713
| C.C: to 1. Sri.J.Hari Narayana, IAS., Chief Secretary, Govt.of A.P.,Hyd.
2. Sri.Jayesh Ranjan, IAS., Vice Chairman, HUDA, Hyd.
3. Sri.C.V.S.K.Sharma, IAS., Commissioner & Spl.Officer, GHMC, Hyd.
4. Sri.K.S.Jawahar Reddy, IAS., Managing Director, HMWS & S.B, Hyd.
5. Sri.R.V.Chandravadan, IAS., Collector, Hyderabad Dist.,
6. Sri..L.Premchandra Reddy, IAS., Collector, R.R.Dist.,
|14th .June 2007
Sub: - Draft Revised Master Plan – HUDA – Irregularities – Objections
Ref: - 1) Our letter to you Dt: - 08-06-2007
2) Memo No.9225/I1/05 Dt: - 26-05-2007
With reference to our earlier letter Dt:- 08-06-2007 we have requested your office to extend the deadline of the notice given to people to submit objections and suggestions to the Draft Revised Master Plan and have also raised some objections to the way in which the whole process is being carried out.
Sir, We have come across a glaring lacuna in the whole process in reference to the Memo No. 9225/I1/2005 and comparing it to the actual process and found out that the Maps on display at HUDA Premises in Paigah Palace, Rasoolpura, Secunderabad are only Master Plan maps. The existing Land Use maps are nowhere to be seen. On requesting for the same the answer we got was “They are not required to be displayed”. We fail to understand the logic of this statement. The Memo issued by you, which was referred to in the above lines in Paragraphs, marked as No.7 and No.8 clearly specify that the Land Use has to be displayed.
We believe that an Existing Land Use Map is one of the most important documents for people to compare with the Master Plan and try to understand the proposed changes and the impacts it has on the overall development of a Zone/Area. Without being in a position to compare the existing and future scenarios simultaneously how is one supposed to come to any conclusions and accordingly submit suggestions or objections to your office?
In view of the above, we request you to immediately display the Land Use Maps along with Master Plan, come out with a printed version and further extend the date by at least 3 months
(Omim Manekshaw Debara)
Forum For a Better Hyderabad.
C.C to: Sri.Jayesh Ranjan, IAS., Vice Chairman, HUDA, Begumpet, Hyderabad
|15th June 2007
The Principal Secretary,
Sub: - Objections/Suggestions on Draft Proposed Master Plan in HUDA Area.
Ref: - 1) Our Letter Dt: 07/06/2007
2) Your Memo No. 9225/I1/05 Dt: 26/05/2007
3) Our letter Dt. 12.6.2007
4) Our letter Dt. 14.6.2007
With reference to the above letter of ours and memo issued by your office, We have the following Suggestions, objections to the Draft Proposed Master Plan in Non MCH HUDA area: -
According to the provision in "The A.P. Urban Areas (Development) Act, 1975"
Chapter III 6. (2) (a) The Master Plan Shall - define the various zones into which the development area may be divided for the purposes of development and indicate the manner in which the land in each zone is proposed to be used (either after carrying out development thereon or otherwise) and the stages by which any such development shall be carried out.
The stages of development are not given in the maps we have seen at HUDA office at Paigah Palace Rasoolpura
In “The Urban Development Authority (Hyderabad) Rules, 1977” the following provisions are there: -
Rule 12. (3) Any Such plan shall include such maps and descriptive matter as may be necessary to explain and illustrate the proposals in the Master Plan and shall include a present Land Use Map.
Rule 12.4 Soon after the preparation of the draft (Master) Plan for the development area or any part thereof, the authorities shall publish a notice in Form No.1 appended to these rules in a prominent place in at least three local daily news papers inviting objections and suggestions allowing a period not less than 15 days from any person or local authority. The said notice shall also indicate the place and time where copies of the draft master Plan may be inspected. Any person residing or owning a property within the inspected area or local authority operating within the affected area will be entitled to represent in writing to the authority any objections and suggestions which they may have in regard to the Land Use Map or Draft Master Plan.
Rule 12.5: After expiry of the said period, the authorities shall prepare a list of objections and suggestions in Form No.II appended to these rules, to consider the representations so made within the time specified and any other information available to it and finalise the present land use map and draft master plan as it thinks fit.
Rule 12.6 The authority will then submit the land use map and the Draft master Plan to the government, as required under section 9 of the Act for their final approval.
Rule 12.7 After the governments approval the Authority shall publish a notice in a prominent place in at least three local daily news papers indicating the fact of the final approval of the Land Use map and the Master Plan and the place(s) and time(s) where a copy of each of the said land use map and the master plan can be inspected.
Rule 12.8 A land Use map and Master Plan published by the authority under Section 10 of the Act shall be conclusive proof of their having been duly made and approved. Such Land Use Map and master Plan shall have the affect from the date of publication of such notice and be conclusive proof of their contents. The Execution of the plan shall be commenced forthwith.
From all the above paragraphs it is clear that Land Use Map and Master Plan are separate documents and Land Use Map is one of the most important document and only on comparing it to Master Plan will we get an opportunity to understand the impacts of proposed changes. But the display in HUDA office is showing only Master Plan Maps and not Land Use Maps. This we believe is against the provisions of the above mentioned rules.
- The Other aspect is the constitution of "Metropolitan Planning Committee" for Hyderabad Metropolitan Area as a whole, in accordance with Article-243-ZE of the Constitution of India.
The "Metropolitan Planning Committee" for Hyderabad Metropolitan Area comprised in one or more Districts and consisting of two or more Municipalities or Panchayats or other contiguous areas, is to be constituted immediately in accordance with Article 243-P ( c ) of The Constitution of India, if not already done. Without the Constitution of the above
committee approving the Master Plan will be in violation of the provisions and spirit of The Constitution of India
Apart from the above specific points please understand that The Master Plan contains the Spatial Policies , programmes and guidelines to the executing and planning agencies in matters of planning and development, apart from indicating the existing Land Use and the Proposed Land Use , to organise environmentally sustainable future urban growth. T he Spatial Policies for the development will have to be looked into, taking into consideration the National and International standards and practices followed for urban planning and development.
Without coming out with a detailed book containing the above details including maps and other relevant data and making it available extensively as it was done in 2003, would be a gross injustice to the people of Hyderabad.
We have noticed that the Land Use Changes permitted under various categories since 2005 have not been incorporated into the Draft Proposed Master Plan Maps being displayed. We believe that this single decision of the authorities not to show the above mentioned changes has ulterior motives behind it. We demand that the authorities come out clean with an explanation as to why the process is being done in a hurry with incomplete details.
We have approached the office of Vice Chairman, HUDA with a request to grant us copies of the Maps so that detailed examination is possible and concrete suggestions can come from our group of committed individuals and organisations to make the Master Plan a well organised, thought out and people friendly, environmentally friendly document. We have been given a copy of Land Use Zoning Regulations, but they could not give us the copies of the maps and directed us to approach your office for the same. The letter addressed by HUDA is enclosed for your reference. We request you to please provide us the same and also a soft copy map of 1: 10000 scale of the Master Plan.
We reiterate on this occasion our earlier request to you, to extend the deadline given for Public comments and ensure that the people of Hyderabad are given every possible document/data so that an informed citizenry can make a well understood choice.
Forum For A Better Hyderabad
Mobile: 98480 44713; Fax: 27635644
|C;C to: The Vice Chairman, HUDA, Begumpet, Hyd.
Encls: 1) Our Letter Dt: 07/06/2007
2) Our letter Dt. 12.6.2007
3) Our letter Dt. 14.6.2007
Letter from Principal Secretary,MA&UD to V.C, HUDA regarding Revised Master Plan for Non MCH Area of HUDA area call for objections and suggestions Dated:16.06.2007.
Capt.J.Rama Rao VSM, FIE,
Indian Navy (Retd)
Tel: (040) 2332 1350
Mobile : 09393366000
540, Road No.12, Banjara Hills
Hyderabad- 500 034
|2006 July 18, 2006
Vice Chairman & Managing Director,
Hyderabad Urban Development Authority,
1-8-323, Paigah Palace , Rasoolpura,
Secunderabad - 500 003
Sub: Clarification regarding Auction of Govt Land by HUDA in Kokapet Village of R.R.District
Thank you for the Lr.No.8875 / Misc. / Plg. / H / 06 dated 17-7-2006 , delivered by special messenger on 18 Th July, in response to letter dated 6-7-06 on the subject.
The good work being done by HUDA, in respect of urban greening and measures being taken to protect some of the lakes, is very much appreciated. That is why HUDA is requested to examine that the land in Kokapet (V), proposed to be auctioned on 20 th July, does not fall within 10 km radius of the lakes and does not attract the provisions of G.O.Ms.No.111
The following observations are offered on the points clarified in the letter quoted above:
a) Annexure-I giving list of 84 villages: It may be mentioned that the list gives the particulars of villages falling in the catchment area of the reservoirs up to 10 Kms. from FTL of the lakes and does not contain the list of villages within 10 Kms radius of the lakes vide Para 3 (e) of G.O. 111.
b) Moreover the list of villages given in Annexure-I is only indicative of area covered in the catchment of the reservoirs and what needs to be considered is the area up to 10 Kms from FTL of the reservoirs, which can be more accurately assessed these days
c) Prohibition of Polluting Industries: The emphasis seems to be laid on Polluting Industries within 10 Kms radius, and the provision in Para 3 (f) -"There shall be total prohibition of location of industries in the prohibited zone" seems to be ignored.
d) As per Environment Protection Act, 1986, Environment includes water, air, and land and the inter-relationship, which exists among and between water, air and land and human beings, other living creatures, plants, microorganism and property. And also the reference to industries includes other activities that have the potential to generate pollution, which is also
made clear in Para 3 (I) of G.o.111
e) NGRI report submitted in Surana oils case, categorically stated that Hydraulic Connectivity exists across the Dolerite Dyke located in the area, facilitating the ground water movement. In the post monsoon scenario, the ground water table will go up and thereby may result in more ground water flow across the dyke. This aspect needs to be looked into, before clearing any
activity within 10 Kms radius of the reservoirs
f) Even though G.O.111 stipulates that FSI be restricted to 1: 0.5 in the catchment area, directing HUDA to take action for the classification of the 90% of the area as Agriculture which is inclusive of horticulture and floriculture, according EPTRI report, about 200 Farmhouses are reported to have come up in the catchment area of the lakes, more than 50 % of which are used / developed as recreational / resort areas
Finally I would like to refer to the observations of EPTRI in its report on Ecology of Himayat Sagar & Osman Sagar Lakes - "Though the engineered systems can only modify the capacity of a system, but usually result in continued operating costs with negative ecological impacts. It may be concluded that by saying that projected growth should be sustainable otherwise over-development will destroy the ecological conditions around the lakes with existing communities"
It is therefore once again requested to undertake an in depth analysis and careful examination of various aspects of the change of land use, likely to result in due over- development leading to ecological disaster, within 10 Kms radius of the reservoirs
Looking forward for an early response
Capt.J.Rama Rao I.N. (Retd)
1.The Chief Secretary to Govt
2.The Principal Secretary to Govt, Dept of MA&UD
|2006 July 27, 2006
The Vice Chairman & Managing Director,
Hyderabad Urban Development Authority,
Paigah Palace ; Opposite Police Lines,
Begumpet, Secunderabad- 500 003
Sub: Group Discussion on "Environment Protection of Hyderabad "
We thank you for your Letter no. 147 / HUDA / UF / D5 / 2006 dated 26-7-2006, inviting for the group discussion on 29 th July 2006, of the issues concerning with "Development and Protection of Environment", like Greenery, Conservation of Lakes, Protection of Rocks etc in Hyderabad city
Leave Alone Natural Environment
What needs to be done first is to acknowledge that a system of natural ecological infrastructure exists every where, that it functions with or without our presence, and that when we interfere with its functions, the resulting effects are often cataclysmic- despite our attempts to reconstruct, duplicate or mend it. Therefore, it is in our best long-term interests to keep as much of this natural infrastructure -Water Bodies, Greenbelts, Conservation Areas, Rocks etc - as healthy and as intact as possible
Land Use & Environment
The other aspect is the quality of our lives is dependent on the quality of our environment, which is largely dependent on the quality of our Land-Use. Therefore the second and most important lesson to be learned , is the powerful influence that urban land use planning has on quality of our natural environment
Master Plan & Land USE
The Comprehensive Land Use & Environmental Protection should be the integral part of the Master Plan. The Protection & Preservation of natural resources and community's ecological infrastructure should be the major concern of the Master Plan. The Conservation and not mitigation of the damage being done, should be the focus of development, under universally accepted and established "Precautionary Principle" The Zoning Plans and Building Rules should be subordinate to Master Plan. But what is actually happening in Hyderabad is the other way
Urban Land A Commodity
As a result Hyderabad urban land is simply regarded as a Commodity and not part of larger continuum, intimately linked to the surrounding air, water, vegetation and life, inflicting environmental / ecological damage. If Hyderabad city endowed with heritage and nature will have to be saved for the future, comprehensive and integrated land use planning and management are required, instead of treating it as a Commodity for meeting short term needs, which amounts to selling the future of Hyderabad
Failure to Revise and Notify Master Plan 2020
It is therefore a futile exercise to discuss about "Development & Protection of Environment" in Hyderabad, when HUDA and the State Government have miserably failed to modify the Master Plan made in 1980 and notify the revised Master Plans 2010 / 2020, which were being debated since 1994 and resorting to indiscriminate change of land use and auction of all the available vacant lands just to mobilize funds, without public consultation
Capt.J.Rama Rao I.N (Retd)
31 st March 2006
Dr. Y. S. Rajashekara Reddy
Hon'ble Chief Minister of Andhra Pradesh
Sub: Comments on " Hyderabad RevisedBuilding Rules, 2006" and appeal
Dear Dr. Y. S. Rajashekara Reddy Garu,
At the outset Forum For A Better Hyderabad congratulate the team for bringing out the "Hyderabad Revised Building Rules, 2006 [ HRBR-2006 ]" [G.O. Ms. No. 86, Municipal Administration and Urban Development (M) Department, dt. 3.3.2006] while Master plans are lying in the cupboards - without Master plan/Zonal regulations bringing out building regulations is a futile exercise.
1) General: The HRBR-2006 is too generalized and over simplified to cater the needs of violators of laws at the cost of environment & general public. Under Annexures it state " The government by Notification may modify, alter or add to the list of the areas given in Annexures below (Annexures I, II & III) . With this, politicians with the tacit support from bureaucracy of the day can play havoc on building regulations through manipulation of rules - this clause also will protect the politicians and bureaucrats from the Courts. That means, the revised rules worth nothing. In fact, this is in contradiction to Para 15 of G.O. Ms No. 423 M.A. dated 31 st July 1998 , "The government or any other Authority shall have no powers hereafter to relax any site from the provisions of these Building Stipulation either in part or in total". Forum in its letter of March 18, 2005 addressed to Principal Secretary, MA on simplified building regulations urged to include this clause to avoid any mischief by politicians of the day. Forum now also reiterates its' urge to include this clause in the revised rules and also urge to exclude item/clause 5 of the Hyderabad revised building rules - 2006 from any such exemption clauses more clearly.
2) Water bodies: Though it carried separate item (item/clause 5) on water bodies, they lack clarity and highly susceptible to political and bureaucratic games [as presented in 1 above]. Through the destruction of water bodies and gardens the temperatures have already gone-up [contributing to global warming] and that require more power to contain the heat:
(a) Himayatsagar and Osmansagar lakes: These two water bodies are covered under item 5(h) "For areas covered under G.O. Ms. 111 MA dated 8.3.1996 (Protection of catchment area of Osmansagar and Himayatsagar lakes), the restrictions on building and development activity imposed in the said government order would be applicable". However, this is defeated with other clauses in different items. For example: At item 9.1 it states that "High Rise buildings/Complexes shall be permissible only in areas other than those given in Annexures I & II". Under Annexure II (B-2) it states that "List of areas prohibited from high rise buildings - outside MCH area - areas covered under G.O. Ms. 111 MA dated 8.3.1996 (Protection of catchment area of Osmansagar and Himayatsagar lakes) ". Under Annexure III - Sky scraper zone - it says at (item x) "All along the outer ring road up to a depth of 500 meters on either side in areas other than those covered in G.O. Ms. No. 111 MA, dated 8.3.1996" - what about items i, ii - ix that fall under this GO? Finally, all these are overrun/superceded by the clause under the Unnexures [discussed in 1 above]. The issues pertaining to GO 111 must be brought out from the Annexures I to III to avoid any ambiguity or misuse or misinterpretation of GO 111 plus Hon'ble Supreme Court judgment dated 1-12-2000.
On 27 th March 2006 Vaartha daily newspaper carried out a report saying, "Golconda Hotels Group made available 'Golconda Resorts & Spa' to public - this is supported by Tourism Department, Tourism department became a destroyer of environment --, which is on the bund of Osman Sagar Lake (Gandipet cheruvu). It is quite surprising who has given them permission in an area covered by GO 111 and this activity in addition require under environmental act to go for public hearing and get clearance from Pollution Control Board - Is HUDA and Pollution Control Board not aware of this activity or they overlooked the illegal activity as the party has high political connections? There are several such activities taking place in the prohibited zone but HUDA and Pollution Control Board is just watching the violations of GO 111 [and the 1-12-2000 judgment of Hon'ble Supreme Court Order on this]. In the past Pollution Control Board rejected Golf-Course near Gandipet as well permission to several industries . Resorts come under category of Hotels that are prohibited by GO 111. Precautionary principle is applicable here as per the Hon'ble Supreme Court order of 1-12-2000. In the past, HUDA has given in writing and said orally to Hon'ble High Court and Pollution Control Board that they will see no such violations take place in the prohibited zone of GO 111.
(b) Musi River: Under item 5
(a) it states that "No building/development activity shall be allowed in the bed of water bodies like river, or nala, and in the Full Tank Level (FTL) of any lake, pond, cheruvu or kunta/shikam lands. Followed this under 5
(b-iii) it states that "The above water bodies and courses shall be maintained as recreational/Green buffer zone, and no building activity other than recreational use shall be carried out within - 9 meters from the boundaries of Canal, Vagu, etc. -
(item c) Unless and otherwise specified in the Master Plan/Zonal Development Plan, the space to be left in and around the Canal/Vagu (including the actual Canal/Vagu bed width and alignment) shall be minimum 15 m. This may be developed as Green Buffer/recreational and/or utilized for road of minimum 9 m width, wherever feasible";
(d) Under Annexure III
(ii), it states "Sky scraper zone - Along River Musi outside present MCH limits". With all these it is clear that builders could mutilate River Musi -- this is already happening with the tacit support from concerned authorities. At Attapur-bridge some body is filling Musi River with rubble and a bit further upstream some body put a board saying HUDA approved layout -- to identify such evil things you need a watchdog committees
Under Musi beautification the government is contemplating to spend around 900 cores and yet Revised Building Rules allow upstream of River Musi from MCH area to Himayat Sagar & Osman Sagar lakes for building activity along its banks and contaminate water of River Musi, they in turn contaminate the water treated in MCH area wasting 900 crores of public money. Alas! It is a national waste. It is proper to extend the clause instead upto MCH area on the upstream side it should extend up to the Himayat Sagar & Osman Sagar lakes . In fact Forum members in their submissions to MCH Commissioner on the Musi beautification after the JNTU workshop made similar suggestions and clearly brought out the need for such thing.
(c) Use of Buffer zone:
Item 5 (b) - It states that "The above water bodies and courses shall be maintained as recreational/Green buffer zone, and no building activity other than recreational use shall be carried out within [I, ii, iii, iv, c] ---": What is meant by recreational/green buffer zone? Is it similar to those of Food Courts/Jalavihar around Hussain Sagar, where in commercial activities are being carried out by constructing permanent structures in which alcohol is also sold [is it ethical to permit to sell alcohol in a recreational place where wife - husband comes with their children to have breathe of fresh air] , constructed projections into Hussain Sagar water, etc - which means, giving the prime land to influential people at throughway price to establish commercial activity in violation of pollution control board consent for establishment order and court orders and encourage unsocial activities! This shall be a green buffer zone only. The road, if any, shall be outside this buffer zone only and not within the buffer zone - similar to Necklace Road around Hussain Sagar Lake.
3) The other issues: With reference to item 3, 4.1, 4.2 & 4.3: builders rarely abide these. A team can go round and see the factual situation prevailing in and around twin cities - the concerned government departments are simple spectators of these illegal activities [Ex. How many of them have the clear and established approach road of minimum 9 m Black topped Road ]. For successful implementation of such, there shall be watchdog committees all round.
The item 7: "There are no plot size stipulations based on use or occupancy of the building. The setbacks and height stipulations given hereunder are applicable for all types of buildings". This is highly improper and malafide decision. This is against the basic zoning regulations. That is why Forum argued that building regulations must go with Master Plan/Zoning regulations. At present government is changing residential zones into commercial zones overnight causing hardships to public and at the cost of destruction of pleasant environment by cutting trees or filling the lakes, etc. This is unethical practice. The rules must follow the zoning regulations - based on use or occupancy of the building - [residential, commercial, etc.] otherwise it creates more problems in future to residents as well as to environment and contributing to global warming.
With reference to Greenery Clause: Item 7.1 [vi to viii, xi] & 9.9 - is highly biased by the shape of the plot. For example for a plot of 5m x 5m = 25 sq. m, the 1 m green belt on four sides means 16 sq. m; the same for a plot of 6m x 4m = 24 sq. m, 1 m green belt on four sides means 16 sq. m; the same for a plot of 7m x 3 m = 21 sq. m, 1 m green belt on four sides means 16 sq. m. Instead fixed width, by taking percent area this bias could be easily eliminated - in fact this was used in item 7.1 - viii & 9.9a. This is also true with setbacks. In the case of setbacks the minimum width required for fire service can be stipulated wherever it is applicable.
In the case of Table IV,
(i) Minimum road width should be 18 m; and
(ii) Minimum all-round open space on remaining sides should be in per cent area of the plot size by leaving minimum width required by fire services on all sides similar to that specified in Table VI to avoid bias based on plot shape and size. In the case of Table VI, separate residential building and use 30% and 20% while for the rest use 40% and 30%; above this group use 50% and 40%. Hospitals and residential complexes do not go on the same wavelength in terms of traffic/parking.
There is imbalance/fallacies in Table I and Table III by adhoc plot size limits selection and they vary from table to table and clause-to-clause and such fallacies gives raise the builder or owner of building violate the rules. Thus, it gives the impression that these rules are framed for benefiting the violators only. Let us take few examples under IIIB - less than 12.2 m road width.
Area of the Plot = Dimensions
Area Under Setbacks in %
Depth X Width
Depth X Width
200 sq. m. = 10m x 20m
800 sq. m. = 20m x 40m
1480 sq. m = 20m x 74m
1500 sq. m. = 20m x 75m
From the above results it is clear that for a simple decrease in area by 1.33% [from 1500 sq. m. to 1480 sq. m.] the percent area under set backs increase steeply [in the above example it is 16.7%, which is equivalent to 250.5 sq. m.]. This happened just because 1480 sq. m falls under 750 to 1500 sq. m group and 1500 sq. m. falls under 1500 to 2500 sq. m. group and by changing plot shape for 1500 sq. m. plot, the area under setbacks changes from 53.8% to 64.8%. That is, by changing width and depth [shape of the plot with respect to road facing] the percent area under set back also changed drastically. In addition to these, the front set back under road width from 12.2 m to 30 m and above in the case of 100 - 200m, etc. have no meaning. This is arising basically because of meaningless Table I.
Therefore most of the tables, particularly Table III must be re-worked out to give realistic and meaningful [with no scope for manipulation] plot size vs road width vs height vs setbacks. Not only the plot size but also the shape of the plot shall define the setbacks and thus this must be accounted in the revision. These revisions must go with land use. There shall be huge penalties & demolition of such violations.
Table II was not prepared by taking into account the practical problems [traffic & air pollution, parking, etc.] with different activities in respect of road width. These are over simplified to benefit vested interests only. The table shall present more realistic by taking into account the present experience in different localities by keeping into account the future congestions. The revision must go with land use.
Based on the plot shape in addition to plot size and local weather conditions must be taken into account while stipulating items 7.1 [iii to xvi] similar to item 8.
Item 5 (g) relates to Banjara Hills- Jubilee Hills area covered by Block 1 & 2, and part of Block No. 3 of ward no. 8, MCH area, the building restrictions imposed vide G.O. Ms. No. 601 MA dated 5-11-1988 read with G.O.Ms.No.423 MA. dated 31-7-1998 would be applicable. Against this is also included Annexure II (A-3). With this can also be mutilated by the government whenever they want. This is already under taken by the public - near by the Lotus pond, near Prashashan Nagar, etc by individuals, Road No. 36 in Jubilee Hills was changed from residential zone to commercial zone overnight, government has sold through auction around 23,500 sq. m. area at the check-post for commercial venture and special GO was issued for 6-month period for construction of Hotels. When the government is developing Outer Ring Road and radial roads, where is the need to tamper the existing GOs?
Appeal: From the above brief discussion - though a bit harsh in the presentation -- it is very clear that the "Hyderabad Revised Building Rules 2006" was issued in a hurry to better serve the vested interests/violators of law. The rules must be for public and at the same time safeguard the environment but not to provide shelter to violators of rules. The Forum For A Better Hyderabad, herewith appeal Dr. Y. S. Rajashekara Reddy Garu, the Hon'ble Chief Minister of Andhra Pradesh that in the light of above brief discussion and by keeping in view the government's proposals such as Greater Hyderabad, Hyderabad Metropolitan Development Authority, etc.:
First, the government shall bring out the Master plan/zonal regulations by using HUDA as planning body rather than making HUDA another center for real estate mafia. This is very important in regulating traffic and solving parking & air pollution, water pollution problems, etc in future;
Government shall create watchdog committees with people of the locality with integrity for timely control of illegal construction activities;
The 'Hyderabad Revised Building Regulations - 2006" shall be re-worked out in light of the above presented brief discussion and that too after the Master plan/Zonal regulations are issued by the government - at present these are in draft form only. The revised rules shall include the clause "The government or any other Authority shall have no powers hereafter to relax any site from the provisions of these Building Stipulation either in part or in total" and also water bodies shall be free from government manipulations/exemption clauses. The government shall assign the task of revision of the rules to people with integrity and good understanding of the subject.
Dr. S. Jeevananda Reddy
Forum For A Better Hyderabad
- The Chief Secretary, GOAP
- The Principal Secretary, MAUD, GOAP
- The Principal Secretary, E. F. S. & T., GOAP
- The Commissioner, MCH
- The Vice-chairman, HUDA
- The Member Secretary, APPCB
|Capt. J. RAMA RAO VSM, FIE,
Indian Navy (Retd)
Tel: (040) 2332 1350
540, Road No. 12,
|Date: 25th December 2005
|Dr.Y.S. Rajasekhar Reddy
Hon'ble Chief Minister
Respected Chief Minister
Sub: Rule of Jungle in Concrete Jungle of Hyderabad
Master Plan 1980
This is to bring to the kind notice of
the Hon'ble Chief Minister,
Hyderabad Master Plan prepared in 1980 continues to be in force
even today with several Adhoc modifications, during the currency of
several unplanned and unauthorized developments have come into
existence on the ground. The important developments taken place since then-Liberalized
Economic policy, unmanageable Road Traffic problems, 2001 Census
have serious adverse impacts on quality of life of
Revised Draft Master Plan 2020
The draft proposals of Hyderabad Master
Plan were being
but the revised Master Plan did not see the light of the day.
regrettable that undue delay is taking place in finalization of
the revised "Master
Plan 2020 of Hyderabad Metropolitan Area",
the draft of which was discussed in
and notified in
The draft plan in respect of the area covered by
Corporation of Hyderabad is not notified even till to day.
Role of HUDA
From the above, one gets the impression that HUDA,
which is entrusted with the job of Urban Planning and Development,
is mainly concerned with more of development / commercial
activities, than the planning. As a result, the revision and
finalization of the Master Plan, which is of vital importance for
comprehensive, energy efficient and eco-friendly urban land-use,
is being neglected and taking the back seat.
Many of the
Environmental problems, Traffic congestion, Automobile pollution,
Flooding of Roads & Residential colonies etc, being experienced in
Hyderabad, are mainly attributable to lack of proper Land-Use
Plan and non-implementation of whatever the Land-Use plan exists.
As a result, the Urban Land is being simply
treated as a "Commodity" and not part of a larger
continuum, intimately linked to the surrounding air, water,
vegetation and life.
Once the Master Plan
is finalized and notified, the change of Land-Use should
not be permitted at least for a period of 5 years from the
date of notification of Master Plan. Any change of Land-Use,
with particular reference to Water Bodies, Parks, Playgrounds,
Lung-Spaces earmarked for Recreation and Conservation etc
should not be entertained at all as it is gong to adversely affect
the quality of life.
All proposals for
change of the Land- Use stipulated in the Master Plan, should have
wide and elaborate public consultation, as was followed
while finalizing the Master Plan. The Section 12 of AP Urban
Areas Development Act, 1975 and the relevant Rules need to be
modified, so as to prevent suvo-moto change of Land-Use by the
Rules, Violations & Relaxations
The State Government,
reportedly after holding discussions and deliberations at various
levels, issued G.O. No.423. M.A. dated 31 st July 1998, to
rationalize the FAR values and standards of Building requirements
for different types of Buildings, uses and occupancies in
Municipal Corporations and Urban Development Authority Areas.
Even these Rules, with
regard to FAR, Road Width, Height of Buildings etc, which are
very liberal and diluted when compared with the guidelines of The
National Building Code and the Standards being followed in
other Metros including that of Delhi. But they are being flouted
by the builders, apparently with the collusion of the official
machinery, which is entrusted with the task of carrying out
mandatory inspections at various stages of construction of the
building and issue "Fit for Occupation Certificate"
The State Government
also granted liberally relaxations and exemptions to the
provisions of the G.O.423 in spite of the stipulation that "The
Government or any other authority shall have no powers hereafter
to relax any site from the provisions of these Building
stipulation either in part or in full".
Simplified Building Rules
But regrettably, the State Government with out
streamlining and strengthening the regulatory system for ensuring
the "Rule of Law" by strict implementation of the Building
Rules, issued Memo dated 15-01-2005, notifying the draft
"Common Building Rules" in the name simplification of Building
Rules. This is nothing but further
diluting the existing Rules, which are very liberal and already
diluted as stated earlier.
Building Regularization Scheme (BRS)
The State Government issued G.O.Ms.No. No 419 M.A.
dated 30 th July 1998 with the view to facilitate the
individuals, who constructed the buildings unauthorizedly or in
deviation of the sanctioned plan up to 30-6-1998, to get them
regularized by paying the penal amount prescribed for the purpose.
This has sent the wrong signals that the illegal constructions
can get away easily by paying the penalty, which is considered
to be peanuts. Again there is a talk of declaring another BRS,
which encourages only the "Rule of
Jungle", converting Hyderabad into a Concrete Jungle making things
In the absence of
revised Master Plan for the last 10 to 15 years, during which
explosive growth of population and the haphazard and un controlled
growth of the City have taken place, resulting in today's
traffic and the allied problems Instead of opting for the
energy efficient and fast Rail based Public Transport system, we
have chosen the energy inefficient Road-Automobile traffic
system, with focus on personalized vehicle transport, which
has become a nightmare because of Traffic congestion, Noise and
vehicular Air pollution.The Hyderabad
City is being developed for Cars and not for People by
widening roads and building Flyovers. The Ratio of the areas utilized for "Parks" to "Parking Lots" may be the best single
indicator of the livability in Hyderabad City. "Building
more Roads and Flyovers to ease Urban Traffic is kind of like
trying to cure Obesity by loosening the Belt"
*Master Plan 2020 of
Hyderabad Metropolitan Area including MCH Area be
finalized and notified with out any further delay, to
replace the Master Plan
of 1980, which is currently in operation
*The change of Land-Use,
with particular reference to Water Bodies, Parks,
Playgrounds, Lung-Spaces earmarked for Recreation and
should not be entertained as it is gong to adversely affect
the quality of life.
* Any change of Land-Use
should not be permitted at least for a period of 5
years from the date of notification of Master Plan
* The Section 12 of
AP Urban Areas Development Act, 1975 and the relevant
Rules need to be modified, so as to prevent suvo-moto
change of Land-Use
by the Government
The draft "Common Building Rules" notified on
15-01-2005 in the name of
simplification of Building Rules, be scrapped in the light of
finalizing the Master Plan
* The Building Regularization Scheme be scrapped to
enforce the Rule of Law
* The officials and builders responsible for the illegal
constructions taken place so
far be identified and subjected to stringent and deterrent
* The Officials concerned be made accountable to ensure
enforcement of the Building
Rules in force without any deviation
* The State government should not grant any relaxations /
exemptions to the Rules
in force without extensive Public debate
Recommendations of the committee headed by Sri A. Raghotham
Traffic & Transportation Management in Hyderabad Metropolitan
light of recent the directive of Hon'ble AP High Court regarding
Illegal Buildings and the Demolitions ordered in Municipal
Corporation of Delhi, necessary steps may please be initiated to
prevent further construction of illegal buildings or in deviation
of the approved plans in accordance with the Rules in force
Capt.J.Rama Rao I.N. (Retd)
Copy to 1) The Chief Secretary
2) The Principal Secretary, MA&UD
3) The Commissioner, MCH
4) VC & MD, HUDA.
JRR / 2005
September 16, 2005
Mr. Jayesh Ranjan IAS,
Chairman & Managing Director,
Urban Development Authority ,
Palace, Secunderabad -500 003
Sub: New Construction Projects - Environmental Clearance
The Ministry of Environment and Forests,
Government of India, issued Amendment dated 7 th July 2004, to the
principal EIA Notification S.O.60 (E) dated 27 th January, 1994,
adding "New Construction Projects" as Item 31 to the Schedule I of
the EIA Notification, which lists the projects requiring
Environmental Clearance of MoEF, GOI as per the procedure laid down
As per this amendment, any construction
project, including new townships, industrial townships, settlement
colonies, commercial complexes, hospitals and office complexes for
1,000 (One Thousand) persons or more, discharging 50,000 liters of
sewage per day or with an investment of Rs.50 Crores or more is
required to get Environmental Clearance of MoEF after getting the
"No Objection Certificate" (NOC) from APPCB.
The new construction projects which were
undertaken without obtaining environmental clearance and where
construction work has not come up to plinth level, shall require
environmental clearance as per EIA Notification with effect from 7
th July 2004. Any project proponent intending to implement the
proposed project with reference to investment in phased manner or in
modules , will need to submit the details of the entire project
covering all phases or modules for appraisal to the MoEF.
News Paper reports it is gathered that the following new
construction projects are being undertaken around Hyderabad:
Housing Board taking up mega township project in Shamshabad under
private partnership to provide accommodation to a population of
with an estimated investment of Rs. 340 Crores
developing a lay-out in 160 acres with about 2 lakh square meters
area and about 36,000 square meters commercial area falling in
area in violation of the provisions of G.O. No 111 and the
directions in its Order dated 1 st December 2000.
MCH developing commercial complexes under "Save Musi Project" the
details of which are not made public
The HUDA, as a responsible planning and regulating
agency, should set an example for the public by strictly following
the statutory provisions in respect of the layouts and construction
projects. It is therefore requested that all the construction
projects in violation of the provisions EIA Notification and the
G.O.No. 111 be kept in abeyance, till the environmental clearances
of MoEF are obtained as stipulated in EIA Notification.
The Principal Secretary, Dept of Municipal
Administration & Urban Development by a copy of this letter is
requested to direct the authorities concerned in other urban areas
like Visakhapatnam, Vijayawada, Tirupati, Warangal etc to strictly
follow the provisions of the EIA Notification in respect of all new
Looking forward for an early response.
Ministry of Environment & Forests , GOI
Mr. S.P. Singh IAS
The Principal Secretary to Govt.
Department of Municipal Admin & Urban Development,
Govt. of AP Secretariat, Hyderabad -500 022.
3) Mr.S.K.Sinha IAS ,
Member Secretary, APPCB
4 ) Mr. Sanjay Jaju IAS ,
The Commissioner MCH,
Memorandum to CM Submitted on Cutting Trees, Road
Winding & Breaking of Rocks on 14-.09-2005
Honourable Chief Minister,
Government of Andhra Pradesh,
Respected Chief Minister,
Cutting of trees for road widening
Destruction of rocks.
Blanket instruction for demolition of unsafe old buildings.
Sharing the road widening plan
We request your kind attention to the following matters and seek
your urgent intervention.
We notice that, purportedly for the purpose of road widening, a
large number of trees have been cut / are being cut along
Somaguda-Rajbhavan road, Begumpet road along the Hyderabad Public
School, and elsewhere. With a little imagination by the concerned
authorities, many of the trees on the sides of a road could have
been saved , by using them as road dividers between the existing
roads and their extended widths , and the extended portions could be
used for two wheelers, autos,. cycles, slow-moving vehicles and
We would like the Corporation and other
concerned authorities to examine how far the felling of trees could
be minimized while widening roads and we are prepared to offer our
help in this regard. Felling of trees increases air pollution,
thereby affecting a citizen's right to life. Therefore, such
felling cannot be permitted unless absolutely necessary, and when
no other option is available. That is why it was made necessary to
take approval from the Horticulture department under the Tree and
Water Act before felling any tree, even in one's own compound. But,
proper approval was not taken as required under the Tree and Water
Act of the government. Further, the current rules of the government
require that three times the number of trees felled should be
planted to keep the green cover. The concerned authorities must
ensure this, strictly, and suitably inform the public their plan
for planting new saplings in replacement of the felled trees.
Destruction of rocks
Hyderabad is known for its rocks and it is one of its attractions.
For the purpose of road widening, such rocks are being thoughtlessly
destroyed. We refer in particular to the huge boulders in front of
the Greenland Guest house, a notified heritage building, which were
just destroyed, without heeding our request to at least try to shift
these to some other location inside the premises. It will be
violation of the heritage conservation rules to alter/destroy any
part of the Greenland Guest house, without prior approval of the
Heritage Conservation Committee. The A.P. High Court has already
given a clear ruling in this regard in reference to a case
concerning the road widening project around Charminar, a few years
Heritage Buildings and Heritage Precincts
Press reports from time to time state that the Municipal
Corporation of Hyderabad have instructed that all old buildings,
which are considered unsafe, should be pulled down without delay and
without hesitation. While we appreciate the anxiety and the urgency
felt by the Corporation to prevent any risk of loss or injury to
life and property, by any unsafe, old building falling down as a
result of natural reasons, such order should exclude, not merely
the notified heritage buildings, but also buildings likely to have
heritage value, as the identification of heritage buildings and
heritage precincts is an ongoing process and the law provides for
additions to and deletions from the list of notified heritage
buildings and precincts. The concerned municipal authorities should,
before demolishing an old building considered "unsafe.", must
consider whether such a building is likely to have any heritage
value and/or whether the demolition of such a building is likely to
diminish or destroy the value and beauty of the Precinct inside
which it may be located. They can have made a list of old "unsafe"
buildings within a time-bound programme, and arrange a quick
inspection of such buildings by the Heritage Conservation
Committee, or a team of persons approved by the latter, who can
take an on-the-spot view whether the concerned building(s) can be
demolished without detriment to the value and beauty of the
relative Precinct, or because the building(s) is / are devoid of
any heritage value. If, on the contrary, this body finds the need
for conserving a building, and yet the building is considered unsafe
for occupation, it should be immediately evacuated, with a proper
warning regarding its un-safety to the neighbours or passers-by.
We are confident that it is practicable to take such a measure.
Steps should also be taken for the restoration of such buildings.
Finally, as citizens / body of citizens concerned with civic
problems and environment conservation, we request that the plan for
road widening and the construction of flyovers, be informed to the
public. Such sharing will improve the quality of the plan and help
its implementation.. It would be interesting to know whether any
study of traffic movement and traffic growth was made with a medium-
to- long term perspective, before undertaking the current road
widening plan and the construction of flyovers. Only a few years
back, some roads were widened, which now seem to require further
widening, which suggest that proper planning was not made at that
time. The mistake should not recur.
request your personal intervention.
REPRESENTATION TO THE HON'BLE CHIEF MINISTER ON GREATER HYDERABAD
Sri. Y.S.Rajasekhara Reddy
Honorable Chief Minister
Government of Andhra Pradesh
The Forum for A Better Hyderabad would like to state its
reservations regarding the proposed creation of Greater
Hyderabad by merging 12 municipalities and eight-gram
panchayats with the current MCH area.
In our view, the reported decision of the Government to
merge these local bodies is fraught with several risks
even while it might appear to create a more functionally
unified administrative territory. In this connexion,
you may recall that SPEQL had earlier raised several
concerns regarding both local governance and urban
development and management in 1998 in a letter to the
Principal Secretary to Government, Dept. of Municipal
Administration. & Urban Development, when the previous
government mooted the same idea. Certain definite
recommendations were also made in this letter to
overcome the problems of growing Hyderabad, without
creating a mega city. For ready reference, we re-state
these observations and recommendations.
The proposal to form Greater Hyderabad by
including contiguous areas in MCH goes against the basic
principle of democracy for decentralisation and
delegation of powers.
The basic objective of the proposal, as
stated in sub-section (1) of Section 3 of Hyderabad
Municipal Corporation Act, 1955, to secure "efficiency
and economy" in the Municipal Administration, is not
likely to be achieved, because of inherent
administrative and organisational inefficiencies and
inadequacies of a mega organisational set up.
The services delivery systems of present MCH,
spread over an area of 172 sq.km. with a population of
30.44 lakhs (1991), are unresponsive to the basic needs
of the citizens. There is no accountability for the
delivery of basic services at various levels of MCH. The
implementation and enforcement of various rules and
regulations are extremely poor to say the least.
The enlarged corporation spread over an area of
about 600 sq.km. With a population of about 40 lakhs
(1991), judging from the ground realities is going to be
unwieldy and unmanageable, making the things worse
adding to the problems of the citizens.
The contiguous, areas proposed to be included
in MCH, are without basic civic amenities and are
totally neglected inspite of decadal population growth
of 155% during 1981-91. The situation in these areas is
not likely to improve very much even after inclusion in
MCH, going by the fact that many areas even in present
MCH remain ignored and neglected.
The public perception of development activities
of MCH is that they are mainly confined to certain
privileged areas such as Banjara Hills, Jubilee Hills,
Panjagutta, Begumpet, Somajiguda, and others, at the
cost and neglect of less privileged areas.
local governance, involving local community, is key to
sustainable cities. Most of the services offered to
urban citizens are of local nature and can only be
provided efficiently if they are handled locally.
Decentralisation is believed to reduce the cost of
operations, and delays, significantly. The bottom-up
problem solving rather than top-down decision making by
fully involving stakeholders is possible only in compact
and manageable cities.
"The question marks hang in the polluted air over mega
cities like, Rio, Sao Paulo, Jakarta, Mexico City,
Cairo, Delhi and Beijing. In many of these cities
well-to-do citizens and corporate bodies are moving out,
driven away by high costs, crime, and a deteriorating
quality of life. We strongly oppose the proposal to
make Hyderabad a Mega City to join the galaxy of Mega
Cities mentioned above.
"We agree with the argument that, in the light of the
HI-TECH City, International Airport and other growth
oriented activities the time has come to look at
Hyderabad and the surrounding Municipalities, as one
entity and plan for the development of Land, Water,
Sewage, Road Network, Urban Transportation and other
resources, in an integrated fashion. This can be
achieved by constitution of "Committee for Metropolitan
Planning" (MPC) for Hyderabad Metropolitan Area (HMA)
comprising MCH, 9 Municipalities and other contiguous
rural/urban areas in accordance with Art 243 ZE of The
Constitution of India, without resorting to the merger
of the areas.
"The Hyderabad Metropolitan Planning Committee (HMPC)
can function as Planning and Regulatory Body, while the
Municipalities and Gram panchayats in "Metropolitan
Area" can function as institutions of self-government,
within the framework of Development Plans prepared by
Metropolitan Planning Committee (MPC), and for the
performance of functions and the implementation of
schemes as may be entrusted to them. (11th &
12th Schedules of The Constitution of India).
"The schemes of common interest between various bodies
of HMA, namely the development operation and maintenance
of infrastructural services such as Water, Sewage, Road
Network, Transportation, and others may be entrusted to
"Hyderabad Metropolitan Development Authority" (HMDA).
This Authority wills co-ordinate the activities of
common interest for integrated development and
environmental conservation of HMA. Thus the functions of
the present "Hyderabad Urban Development Authority" (HUDA)
will be shared by "HMPC" and "HMDA".
developing the infrastructure facilities of the
peripheral areas, in par with that MCH, the
Municipalities and Panchayats in Hyderabad Metropolitan
Area may be regrouped into 3 or more Municipalities as
considered feasible at appropriate time."
Our position on these matters is substantially the same
as that of SPEQL. Additionally, we wish to highlight the
following issues in the present context.
The trend towards concentrating administrative,
planning and development resources on the city of
Hyderabad over the last several years without a matching
effort at regional planning and development, has created
a serious imbalance in both the city and the region. The
creation of Greater Hyderabad is another step in the
same direction. These imbalances have already resulted
in massive in-migration, severe stress on the city's
infrastructure, growth of unauthorized construction by
all income groups, congestion and rising pollution
levels in the city. These issues need to be addressed
before such a major decision as to merge the
municipalities is taken.
The creation of Greater Hyderabad is also a step
towards greater centralization of resources and power.
This is against the spirit of the 74th
amendment of the Constitution which seeks to promote
local participation in planning and development. That
local democracy where the local people actively
participate in decision-making assumes a viable size of
the local body is self evident. The project for Greater
Hyderabad is silent on what, if any at all, democratic
structures are contemplated within the 'mega city'
proposed amalgamation will result in serious disparities
in political power in local governance. The fact that
Hyderabad unlike any other city in the state is also the
state capital, implies that the state government has
tremendous influence over urban governance and
development here. The most powerful actors in the
Municipal Corporation of Hyderabad are not the
corporators but the bureaucrats and the ex-officio
members.While this is an unhealthy trend even for the
MCH, extending it to the 12 municipalities will only
mean that more territory is directly subjected to
centralized state power. The creation of Greater
Hyderabad will only exacerbate this undemocratic
centralization and specific local interests may be
missed for redressal.
We are given to understand that the creation of
Greater Hyderabad will make it possible to claim the
mega city status which in the current national and
international policymaking environment will enable the
government to access certain types of funding for
infrastructure. This seems to be the main argument of
the government. But, the need for funds should not
direct policymaking. Mega systems are known to suffer
from mega crises as well. And to mitigate some special
problems of mega cities that have unfortunately emerged
due to lack of proper planning at the appropriate time,
special funding is provided. Only to attract some
special funds available to a mega city, we should not
create the phenomenon of a mega city with its attendant
problems. Mega city should be avoided on the principle
that prevention is better than cure.
We hope the government will reconsider the decision in
light of the above arguments and pursue a policymaking
path that will truly aim at creating a livable city and
region for all economic and social groups. In this
connection, we cannot help pointing out that the
government has taken the decision to create a mega city
of Hyderabad without prior consultation with the
municipalities, the political parties, not to speak of
the NGOs concerned with urban planning. This is very
arbitrary and undemocratic.
FORUM FOR A BETTER HYDERABAD.
CC To : -
Chief Secretary Govt.of Andhra Pradesh.
S.P Singh, IAS,
Principal Secretary to Government, Dept. MA&UD, Govt.of
Sri Jayesh Ranjan, IAS,
Vice Chairman, Hyderabad Urban Development Authority.
Sri Sanjay Jaju, IAS,
Commissioner, Municipal Corporation of Hyderabad.
The Forum for A Better Hyderabad
has addressed a communication to the Hon'ble Chief Minister of
Andhra Pradesh on the proposed creation of Greater Hyderabad and
sent the copies thereof to the concerned Government
departments of the state government, the local MPs and MLAs,
different political parties, the Chairman of MCH, officials running
the 12 municipalities and the gram panchayats sought to be
merged into Greater Hyderabad. The Forum has expressed its serious
reservations regarding the substance of the proposal as also the
undemocratic process of arriving at that decision without any
consultation. On the substance of the proposal, the Forum has
trend towards concentrating administrative, planning and
development resources on the city of Hyderabad over the last
several years without a matching effort at regional planning and
development has created a serious imbalance in both the city and
the region. The creation of Greater Hyderabad is another step in
the same direction. These imbalances have already resulted in
massive in-migration, severe stress on the city's infrastructure,
and growth of unauthorized construction by all income groups,
congestion and rising pollution levels in the city. These issues
need to be addressed before such a major decision as to merge the
municipalities is taken.
creation of Greater Hyderabad is also a step towards greater
centralization of resources and power. This is against the spirit
of the 74th amendment of the Constitution, which seeks
to promote local participation in planning and development. That
local democracy where the local people actively participate in
decision-making assumes a viable size of the local body is
self-evident. The project for Greater Hyderabad is silent on what,
if any at all, democratic structures are contemplated within the
'mega city' governance.
proposed amalgamation will result in serious disparities in
political power in local governance. The fact that Hyderabad
unlike any other city in the state is also the state capital
implies that the state government has tremendous influence over
urban governance and development here. As the situation prevails
today, effective power in the Municipal Corporation of Hyderabad
is not exercised by the elected corporators, but by the government
officials and the ex-officio members. While this is an unhealthy
trend even for the MCH, extending it to the 12 municipalities will
only mean that more territory is directly subjected to centralized
state power. The creation of Greater Hyderabad will only
exacerbate this undemocratic centralization and specific local
interests may be missed for redressal.
Decentralized local governance, involving local community, is key
to sustainable cities. Most of the services offered to urban
citizens are of local nature and can only be provided efficiently
if they are handled locally. Decentralisation is believed to
reduce the cost of operations, and delays, significantly. The
bottom-up problem solving rather than top-down decision making by
fully involving stakeholders is possible only in compact and
main argument of the government seems to be that the creation of
Greater Hyderabad will enable the government to access certain
types of funding for infrastructure in the current national and
international policymaking environment, by claiming the mega city
status. But, the need for funds should not direct policymaking.
Mega systems are known to suffer from mega crises as well. And to
mitigate some special problems of mega cities that have
unfortunately emerged due to lack of proper planning at the
appropriate time, special funding is provided. Only to attract
some special funds available to a mega city, we should not create
the phenomenon of a mega city with its attendant problems
basic objective of the proposal, as stated in sub-section (1) of
Section 3 of Hyderabad Municipal Corporation Act, 1955, to secure
"efficiency and economy" in the Municipal Administration, is not
likely to be achieved, because of inherent administrative and
organizational inefficiencies and inadequacies of a mega
organizational set up.
services delivery systems of present MCH, spread over an area of
172 sq.km. With a population of 30.44 lakhs (1991), are
unresponsive to the basic needs of the citizens. There is no
accountability for the delivery of basic services at various
levels of MCH. The implementation and enforcement of various rules
and regulations are extremely poor to say the least.
enlarged corporation spread over an area of about 600 sq.km. With
a population of about 40 lakhs (1991), judging from the ground
realities, is going to be unwieldy and unmanageable, making the
things worse adding to the problems of the citizens.
contiguous, areas proposed to be included in MCH, are without
basic civic amenities and are totally neglected inspite of decadal
population growth of 155% during 1981-91. The situation in these
areas is not likely to improve very much even after inclusion in
MCH, going by the fact that many areas even in present MCH remain
ignored and neglected.
public perception of development activities of MCH is that they
are mainly confined to certain privileged areas such as Banjara
Hills, Jubilee Hills, Panjagutta, Begumpet, Somajiguda, and
others, at the cost and neglect of less privileged areas.
The question marks hang in the polluted
air over mega cities like, Rio, Sao Paulo, Jakarta, Mexico City,
Cairo, Delhi and Beijing. In many of these cities well-to-do
citizens and corporate bodies are moving out, driven away by high
costs, crime, and a deteriorating quality of life. The Forum
strongly opposes the proposal to make Hyderabad a Mega City to join
the galaxy of Mega Cities mentioned above.
Latest international thinking recommends
an upper limit of two million population in a city and favours the
creation of independent cities which can be clubbed together for
planning. For example, we do not have greater Mumbai bu Navi
Mumbai, Kalyan, etc.
agrees that, in the light of the HI-TECH City, International Airport
and other growth oriented activities the time has come to look at
Hyderabad and the surrounding Municipalities, as one entity and plan
for the development of Land, Water, Sewage, Road Network, Urban
Transportation and other resources, in an integrated fashion. This
can be achieved by constitution of "Committee for Metropolitan
Planning" (MPC) for Hyderabad Metropolitan Area (HMA) comprising MCH,
9 Municipalities and other contiguous rural/urban areas in
accordance with Art 243 ZE of The Constitution of India, without
resorting to the merger of the
Hyderabad Metropolitan Planning Committee (HMPC) can function as
Planning and Regulatory Body, while the Municipalities and Gram
panchayats in "Metropolitan Area" can function as institutions of
self-government, within the framework of Development Plans prepared
by Metropolitan Planning Committee (MPC), and for the performance of
functions and the implementation of schemes as may be entrusted to
them. (11th & 12th Schedules of The
Constitution of India).
schemes of common interest between various bodies of HMA, namely the
development operation and maintenance of infrastructural services
such as Water, Sewage, Road Network, Transportation, and others may
be entrusted to "Hyderabad Metropolitan Development Authority" (HMDA).
This Authority wills co-ordinate the activities of common interest
for integrated development and environmental conservation of HMA.
Thus the functions of the present "Hyderabad Urban Development
Authority" (HUDA) will be shared by "HMPC" and "HMDA".
developing the infrastructure facilities of the peripheral areas, in
par with that MCH, the Municipalities and Panchayats in Hyderabad
Metropolitan Area may be regrouped into 3 or more Municipalities as
considered feasible at appropriate time.
has expressed its disappointment over the arbitrary and undemocratic
manner in which the government has taken the decision to create a
mega city of Hyderabad without prior consultation with the
Corporation, the municipalities, the political parties, not to speak
of the NGOs concerned with urban planning. The Forum has
appealed to the government to reconsider the decision in light of
the above arguments and pursue a policymaking path in a widely
consultative manner that will truly aim at creating a livable city
and region for all economic and social groups.
NOTE TO HON'BLE MINISTER FOR MUNICIPAL ADMINISTRATION AND
URBAN DEVELOPMENT FROM THE FORUM FOR A BETTER HYDERABAD
The Forum for Better Hyderabad was formed a few years ago
in response to the urban developmental policies of the
previous government. While welcoming the new emphasis on
the efficient delivery of city services, we differed with
the policies of the then government in several respects.
Among the issues taken up by the FBH, the first was the
protest at the proposal to put shops and buildings around
Hussainsagar Lake, a priceless asset of the city, dating
back to Qutb Shahi times. This project was aptly described
by Capt Rama Rao as "a real estate project in the guise of
a tourism project" The previous government decided to set
up a Buddha Purnima Development Authority, thereby
by-passing HUDA, which had been set up in order to take
care of the planned development of the entire city and its
hinterland, as described in the AP Urban Areas Development
We opposed the conversion of the Secunderabad Parade
Grounds into a stadium of national proportions. This led
to the shifting of the stadium to Gachhi Bowli, where the
National and Asian Games were held. We were unhappy at the
creation of the Cyberabad Development Authority, since
Cyberabad clearly forms part of the Metropol itan Area
defined in the 1975 Act, and deviating from the integrated
approach would lead to undesirable consequences. We are
glad to note that these decisions of the previous
government are being reviewed or have actually been
reversed by the present government
The Forum for A Better Hyderabad welcomes the new thrust
given by the present Congress Government to Andhra
Pradesh's development policy. The emphasis has shifted
from an urban-oriented approach to rural development, from
industry to agriculture, with a stress on the needs of
farmers, the problems of unemployment and the needs of
The new government has however inherited from its
predecessor Telugu Desam government an urban development
policy giving primacy to the city of Hyderabad in the
state's development This policy was not debated, so far as
we are aware, in the state legislature, nor by the
educated public and the civil society. It was thus imposed
on the city of Hyderabad without full consultation.
Wherever possible, we have suggested alternative policies
and presented them in representations. We issued public
statements and initiated a debate in order to alert the
civil society to the consequences of the policies being
Our approach has always been constructive, and not
destructive. We continue to stand for the values for which
we have stood during the last few years of our existence.
I.Adverse Consequences of land Use Changes and
Relaxation of Rules.
In recent years, the change of land use from residential
to commercial in the major streets of Hyderabad has
increased greatly. The Hyderabad Central shopping mall
located at Panjagutta has been constructed apparently
without any adequate parking facilities. There have been
several complaints about this in the newspapers. This is
however only a tip of the iceberg. Seven or eight shopping
malls, including some with Imax theatres and the like,
appear to be under construction on Road No 1, Banjara
Hills. As it is, this road is already subjected to
terrific traffic jams. It is not clear what steps are
being taken to provide parking on them, and to handle the
additional traffic generated by these shopping malls.
We regret to point out that several of the Government
Orders reprinted in the HUDA Development Control
Regulations [containing Land use, Zoning, Layout, and
Building Regulations] recently published by HUDA (as
amended and updated up to October 2003] contain Government
Orders which are unduly permissive. The application of
these orders is leading to serious consequences in regard
to traffic movement, circulation of air, provision of
parking, and add to the burden of water supply,
electricity and other services. Some of these Orders are
 Declaration of major roads as Commercial and
levying of Impact Fees-delegation of Powers for according
Commercial Institutional Building permission along and
abutting certain stretches of roads in Twin Cities
Notification- Confirmed- Orders Issued [GO Ms No 508 MA dt 10-11-02]
 Municipal Corporation/Municipalities and areas
covered by Urban Development Authorities - Road Widening
and demolition of affected properties - Delegation of
Powers for according certain relaxations of Building
Regulations and Zoning Regulations to the Local
Authorities [G9 Ms No 15 MA dt 15 January 1998 36 MA dt 31
Tourism Projects - Tourism Policy of Government
of AP -Incentives for promoting the Tourism Projects and
Enable Services in the State Automatic conversion or
exemption trom Zoning Regulations and exemption trom
payment of conversion charges.
These permissive orders of the government, as already
stated, have put the entire urban system in jeopardy. Even
now, the city faces massive traffic jams. Foreign agencies
arranging conferences are routinely warned to locate the
visitors in the same hotel where the conference is held,
as people moving trom other parts of the city will not
reach the venue on time.
We urge the Government, even at this late stage, to take
the public into confidence, as to the additional burden
being placed on the city's traffic and transport system by
these shopping malls, and the steps being taken to tackle
them. Are any MMTS stations being located in Banjara Hills
to handle the additional traffic, and if not why has this
alternative not been considered?
II.Regulation of Building Constructions
In the middle of May 1999 a building known as Madhavi
Enclave in Motinagar, off Erragadda, in the Kukkatpally
Municipality limits collapsed while under construction,
The decomposed bodies of a welder and an accountant, who
had been missing since Sunday 16th were recovered from the
site on 19th May. Instead of the permitted four floors
with 29 flats, the builder had allegedly constructed six
floors with 40 flats, besides a penthouse.
Although it was not the first of its kind, the collapse
sent shock-waves through the public and triggered off a
debate on the entire process of giving building
permissions, the responsibility of the state authorities
for the dangerous effects of these house collapses, and
the utter negligence of the MCH and the HUDA. The serious
consequences to the flat owners received adverse notice
not only trom environmentalists like ourselves, but trom
Sri P Janardhan Reddy, MLA and leader of the CLP who urged
the IDP Chief Ministerto take stringent action against the
builder, demanded the suspension of the MCH officials who
sanctioned the construction, and said that "an impression
had gained ground among people after introduction of the
Building Regularisation Scheme that the Government would
approve any illegal construction on payment of the
stipulated amount. This attitude had resulted in mushroom
growth of penthouses and other unauthorised constructions
which were a perennial source of danger." He further held
that "Government must dispel the public notion that
illegal constructions would be approved, Permission for
construction of multi-storied building should be given
only after a spot inspection of the safety guidelines.
Finally, no deviation must be allowed from the approved
plans." [The Hindu, 20 May 1999]
Immediately after this incident, on 17th May 1999, the
then Government appointed a High-level Committee to probe
the building collapse. It was chaired by Sri Raghavan,
Director General, National Academy of Construction, and
included the then Commissioner of MCH, Dr. P.K. Mohanty,
the Commissioner of Municipal Adminsitration and the
Director of Town and Country Planning. On June 25 the
Kukkatpally Municipality demolished portions of the
apartment complex in Motinagar, constructed in violation
of building rules." [The Hindu, 16 June 1999.]
In less than a fortnight, the High Power Committee
submitted its report. Its recommendations included: 1]
minimum plot size of 1000 sq metres for Multi-storeyed
apartments, and 500 sq metres for group housing to be
maintained [Plots of less than 800 and 400 sq metres posed
a grave threat to occupants, they said.]: 2] construction
of buildings under the supervision of a panel comprising
the structural engineer, architect and builder. 3]
Compulsory insurance of buildings to provide compensation
to occupants in the event of a mishap, 4] appointment of a
special Expert Committee to review the present laws on
building construction, and bring in radical changes to
prevent unauthorized construction.
What was the response of the previous government to the
report of the committee of experts appointed in May 17 and
which submitted its report by June 1 the same year? After
a delay of one and a half years, a Government Order, M5 No
541 MA dt 17-11-2000, was issued, in which it accepted
some of the recommendations in regard to buildings of 10
meters height and above. It demanded statements from the
owner as to whether he was constructing himself or giving
it to a builder, with details of the construction firm.
Soil tests, structural designs, building plans,
undertakings on stamped papers and insurance policies were
required. Stringent conditions were laid down, to be
followed before an occupancy certificate was issued. The
builder, site engineer, structural engineer and architect
were to be jointly and severally responsible for
structural stability during the building construction, and
water sewerage connection and power connections would not
be given without production of occupancy certificate.
Local authorities were directed to blacklist the builder
and his technical advisers in case any of the above
provisions were not followed.
These provisions appear to be stringent. The actual
experience has however been that complaints from neighbors
get ignored, the interests of the flat-owners are
frequently violated, and rules are bypassed with
impunity. The most common violation appears to be the
illegal conversion of single family dwellings into
apartment houses., Flats are sold surreptitiously or
openly, and Occupancy certificates are not obtained in
many cases. The individual builder/owner often obtains an
Ad-interim Stay Order and proceeds merrily with the
construction, since the MCH lawyers make no effort to get
the stay vacated. Usually MCH does not prevent the
occupation of flats even in single-family dwellings, let
alone in apartment houses where the number of apartments
exceeds the sanctioned number, as in the Madhavi
III.Routine Violation of Rules: Failure to
obtain Occupancy Certificates
On June 5 1999, an article in The Indian Express reported
that "almost every moneyed entrepreneur" had "turned into
a builder". They lack the basic knowledge of building
construction and "manipulated things" either at the MCH or
the HUDA, thus "playing havoc with prospective
buyers. " We agree with this assessment, and could
not have put the position more clearly ourselves.
There is a long list of clearances to be got by a builder
before occupancy is permitted, but buildings are routinely
occupied without an Occupancy Certificate. This means that
all rules and regulations, including safety requirements,
setbacks, open spaces, number of floors, heights, water
supply and fire restrictions, can be broken with impunity.
Ail these factors reduce circulation space, add to sound
pollution, violate privacy, and enhance the heat island
effect. The illegal increase in the number of flats and
shops leads to an added burden on the city's water supply,
electricity, and other services. The builder, sells the
flats to the occupants, and takes away his unearned
IV.Illegal Conversion of Single Family Dwellings
into Apartment Houses
One of the commonest and most serious irregularities is
the obliteration of the distinction drawn between the
building permission given to a single-family structure,
and that for an apartment house. If a building has three
stories or more, it requires a lift, and can be considered
an apartment house. In practice, however, we find that
single-family dwellings, which are permitted frequently,
become apartment houses.
This conversion is often done in spite of violating land
use in the area. It is very difficult for the public to
know in which area a multi-storied building is permitted,
and where it is not permitted. This is because
1] The land use and building regulations have been
changing frequently, and new Government Orders are often
issued overnight. These are sometimes not available even
to the legal profession let alone to a private citizen.
2] Notice Boards are not placed "in front of a
building indicating the land uses and FAR, the number of
floors permitted, the setbacks and the like - so that
neither the neighbors, nor future buyers, nor the
passers-by are aware as to what kind of building it is.
They would have to undertake difficult and tortuous
investigations in order to fmd out the facts of the case.
3] The 'Streets' and 'Lanes' branching off main'
Roads' or' Avenues' are often not numbered, even in such
high-profile areas as Banjara Hills. The land Uses and
FAR's for the main roads can thus be illegally extended to
the streets for want of a clear definition of the
The party often obtains an Ad Interim Injunction Order in
a subordinate court, without specifying the purpose for
which it is needed. The builder then carries on his
illegal building construction with little or no effort on
the part of the municipal authorities to get the stay
vacated. Any action the Municipal body may try to take at
a later date [such as issuing show cause notices to the
architect for removal from the list of architects, asking
the TRANSCO and HMWSSB not to supply water, or placing an
advertisement in the newspapers saying that the building
is illegal] can prove effective. The builders have ways of
getting around these irregularities. For example they may
treat the flat-owner as a Power of Attorney holder, or
show the flats as being on long lease, while taking the
payment for them. Not only the builder but also even the
apartment owners thus become parties to the
irregularities. The latter are obviously anxious to
receive early delivery of his apartment on which they have
invested a good deal of money.
This attitude of permissiveness was encouraged by the
Building Regularisation Scheme, which, according to
newspaper reports, expired on 31 December 2004. The FBH
has come out strongly against its renewal.
V.Building Regularization Scheme
The Building Regularization Scheme introduced by the
previous government in GO MS no 419 MA and UD dated
30-6-1998 was challenged by the Forum for A Better
Hyderabad in Writ Petition No 250111/98. Justices Bilal
Nazki and E. Dharma Rao of the High Court summarizing the
arguments put forth in the Public Interest Litigation,
referred to the qualifications of the petitioners. It was
pointed out that the petitioners had brought to the notice
of the government, even before the impugned order was
issued, that the order would have deleterious consequences
such as the increasing Heat Island Effect, the impact on
water and power, absence of lung space, traffic
congestion, growth of slums, accumulation of urban wastes,
overflowing sewerage, air pollution, water pollution, non
availability of parking places and depletion of ground
water table, etc. In another government order the state
authorities had regularized all previous illegal building
constructions. The very argument that this was a 'one-time
concession' made to the violators of building regulations
was clearly violated by going into details of the decision
that further irregularities would be regularized.
The Writ petition was decided as follows: "The Additional
Advocate General has not been able to show us any power
under any law, viz., HMC Act, AP UAD Act, AP Town Planning
Act, whereby the Government has the power to regularize
the illegal constructions..." The Judgment goes on to say
that the power of the Government to give directions to the
Corporations under any Act does not include the right to
"give instructions which are inconsistent with the Act or
the rules made there under. Therefore a Government can'
issue directions in furtherance of the objective that no
construction is made in the city without permission of the
Municipal. Authorities but it cannot subvert the Act
itself and then take refuge under Section 679 E by saying
that the Government has the power to issue directions ".
The Judgment accepted that the petitioners, who are "respected citizens have raised very important contentions
with regard to the environment and ecology of the city of
Hyderabad in this Writ petition. They have also approached
the Hon'ble Chief Minister twice in the past".
Since the petition was decided on grounds that the
Government had sought to "subvert" the Act, the questions
of ecology and environment of the state were not examined
by the High Court. However, the Judgment concluded as
follows: "We expect that the Government shall take steps
to get examined the apprehensions expressed by the
petitioners, through experts and take remedial measures if
The previous government responded to the incisive and
critical comments of the Hon'ble Judges not by challenging
the judgment, but by issuing an Ordinance and Act, giving
the mselves the power to regularize illegal constructions
under the AP UAD Act and Rules. Thus that government
showed its unwillingness to alter its policy of permitting
illegal building construction. It is true that it appeared
to be willing to take steps to prevent further collapse of
buildings. However, the recommendations of the expert
committee sought to link the danger to future buildings,
with the question of illegal buildings in general. It is
this, which formed the subject matter of our writ petition
before the High Court of Andhra Pradesh.
According to newspaper reports, the BRS proposed to be
revived in another form, by permitting 20 percent of
deviations in the construction of buildings. A statement
of this kind can be expected to encourage deviations from
building plans and continue the permissive atmosphere,
which has prevailed during the past few years.
We request the Government to drop the BRS totally, and to
set its face against the renewal of the scheme in any
shape or form.
VI. Alternative Approaches to Traffic Management Road
Widening and Flyovers versus Rapid Transit:
The continued stress laid by the previous
government on road widening on the one hand and flyovers
on the other have come in for adverse comment during our
discussions at the Forum for A Better Hyderabad. The
utility of widening of roads depends entirely on the use
made of the widened space. If it is used partly, at least,
for parking of vehicles, for pedestrian zed footpaths, and
for bicycle paths, it may have a salutary effect, in the
long run. [This is the model put forth by the former Mayor
of Bogota, Colombia, Enrique Penalosa, who spoke in
Hyderabad to officials a few weeks ago.
Unfortunately, there is little evidence of this. The
widened roads are often allowed to deteriorate with
pushcarts, vendors and the like, taking over the extra
space provided. Footpaths in Hyderabad are generally too
narrow and too high. Tree guards, electric poles, water
hydrants, etc frequently occupy them. Pedestrians are
often forced to walk on the road itself, and they often
cross roads at the risk of their lives, because the
pedestrian right of way at zebra crossings [in the cases
where they do exist], are not effectively enforced by the
The entire strategy of rapid transit embodied in the MMTS,
which is intended to take the place of bus and other
vehicular traffic, is defeated by the multiplication of
road-widening schemes and Flyovers. Flyovers do not add to
the total carriageway, but only lead to faster traffic
movement, provided they are located at road intersections.
Too often, they are located along the length of a road,
such as the Begumpet main road. The harassment caused to
the public by the 'Telugu Talli' flyover near the
Secretariat over the years too well known be repeated
We strongly urge that the Government take up a policy of
encouraging rapid transit through making the MMTS more
effective, and give up the idea of any further
Road-widening and/or Flyovers in the city of Hyderabad.
SIMPLIFIED BUILDING REGULATIONS
Dr. S. Jeevananda Reddy
Forum presented comments/suggestions on "Simplified building rules
applicable to all Urban Areas" on 18th March 2005 to Principal
Secretary, GOAP, Municipal Administration and Urban Development
Department. Some of
the sal ient comments/suggestions are
Though in the past also we had good rules, the main problem
was the lack of a proper implementing & supervising
agency. Because of this, illegal construction activity
flourished. In such circumstances, to execute the new
simplified rules most effectively the document should also
include the system that will ensure foolproof implementation
of these rules without any ambiguity or without any
provisions for exemptions. In this connection, the
Govt. should form "Watchdog Committees" with concerned
citizens who can bring to the notice of the concerned
authorities, violations if any, in their respective areas.
The new simplified building regulations should clearly state that
residential zones and bio- conservation zones are
The Master Plan indicating land Use with regard to
Residential/Commercial, Industrial, Institutional, Transport,
Water Bodies, Conservation, Recreational, Natural
Buildings-Monuments-precincts, etc. needs to be finalized at
the earliest for the entire Urban Development Authority
area. The Zoning Regulations and Building. Regulations with
have to be read and implemented in accordance with the land
Use specified in the Master Plan. Building regulations issued
in isolation without land Use Plan will only make things
- As per para 15 of G.O. Ms No. 423 M.A. dated 31st July 1998, "The government or any other Authority shall
have no powers hereafter to relax any site from the
provisions of these Building Stipulation either in part or in
total". The same may be included in simplified Building Rules
Also, for all violations make the concerned official(s)
responsible and action should be taken against them as per law
along with appropriate action including demolition of
violations and action on violators as per law.
In addition to these general observations some specific
suggestions were also made on the draft notification. Some
of these are given, below:
[a] Item 3 last sentence should read as: Restrictions contained in the respective existing rules/bylaws/
regulations/other stipulations as well as existing and
prospective orders of Courts of law would continue to be applied
in the respective areas. [Note: In this connection, the
government should list such issues for public awareness as well
as implementing agencies clarity, for example (i)
the case of Himayat Sagar and Osman Sagar Lakes, the two
drinking water sources for twin cities the government issued
Ms No. 111 MA dated 8-3-1996, which was later upheld by
the Hon'ble Supreme Court (1-122000) and brought in the
"precautionary principle" and (ii) land mark judgment of
the Hon'ble A.P. High Courtt dated 15-6-2001 with reference to
W.P. No. 26378 of
2000 with reference to Hussain Sagar
Lake]. Add Provisions of
the AP Water, land and Tree Act
(no. 10 of 2002) and rules made there off
as per G.O.
Ms No. 239 PR & RD (RD IV) dated 25th June 2002.
[b] Item 15 - Add "Wherever special GOs were issued priorto these simplified
building regulations by the government with respect to certain
water bodies, etc like G.O.
Ms 111 MA of 8-3-1996 with
reference to Himayat Sagar & Osman Sagar Lakes, they are covered
under the respective GOs/court orders, etc.". [c] Item 15b -
change as "The above water bodies and courses / nalas, etc shall
be maintained as such and any building activity/commercial
activity/ring road for
recreational use shall be carried
outside the green buffer zone of (i) 30meters from
FTL of Lakes of area 10 ha and above; (ii) 20 meters from
the FTl of Lakes less than 10 ha/Kuntas/shikamlands; (iii) 10
the boundaries of Nalas, Canal, Vagu, etc.
Unless and otherwise stated, the area and the FTL of a Lake/kunta
shall be reckoned as measured or given in the Survey of India
topographical maps. The green belt must include medium size tree
crops, particularly indigenous plants such as neem, kanaga,
Amendment: Saving or Selling the Future?
Capt. J. Rama Rao
First humanity must learn to acknowledge that a system of natural
ecological infrastructure exists everywhere, that it functions
with or without our presence, and that when we interfere with
its functions, the resulting effects are cataclysmic despite our
atempts to reconstruct, duplicate or mend it. Therefore, it is
in our best longterm interests to keep as much of this natural
infrastructure as healthy and as intact as possible. Second, and
perhaps the most important lesson to be learnt is that we did
not fully realize, the powerful influence that sensible
municipal land use planning has on the quality of our natural
environment. As a result the land is simply regarded as a
commodity and not part of larger continuum, intimately linked to
the surrounding air, water, vegetation and life, inflicting
In terms of Andhra Pradesh Urban Areas (Development) Act 1975,
Hyderabad Urban Development Authority (HUDA) was constituted in
1975, to ensure planned, orderly, balanced and sustainable
development of the notified Urban Area of Hyderabad, leading to
improvement of physical and social environment and consequently
quality oflife. The Master Plan for 1865 sq.kms, covering
Hyderabad and its surrounding areas was prepared by HUDA and
notified in the year 1980, the plan period of which was up to
1991. But it is presently in force and will continue to be so,
till the revised Master Plan is brought into force. The draft
master Plan-2011 was prepared in 1994 and was put for
public debate, and nothing heard after that. Again Draft Master
Plan-2020 is under preparation for the last one year and the
present position is not known.
As per the Act, the Master Plan shall define various zones into
which the development area may be divided for the purposes of
development and indicate the maner in which the land in each
zone is proposed to be used. The development plan for each of
the zones is also to be prepared containing land use plan for
the development of the zones. The land uses proposed in the
zones are Residential, Industrial, Commercial, Institutional
(Schools, Hospitals, and Public Buildings & Utilities etc),
Transport (Roads etc), Recreation (Parks, Playgrounds etc),
Reserved Forests, Water bodies, Conservation etc areas. The
hillocks, valleys, 18keshores and river banks are normally
earmarked as Recreation Zones, prohibiting development activity
involving any material change in the land use. Therefore the
commercial recreation activities such as Amusement Parks and
others requiring structures should not be permitted in notified
recreation areas such as Parks, Playgrounds, Water-fronts etc.
It is gathered that many developments that actually took place since
1975, include many deviations to the notified Master Plan and
Zonal Development Plans. Some of the deviations were carried out
by modifications to the plans as per Section 12 of the Act 1975
and others were by way of unauthorized constructions. In the
entire HUDA area, there have been about 300 cases of conversion
of Green Belts and other areas covering about 3400 hectares of
land from 1976 to 1994. The matter for concern is that the
changes in Green Belts have been taking place in a scattered
manner, with pockets of residential colonies appearing all over
the green belt areas.
A total of 132 orders, for the change of land use were issued
during the years 1994 and 1995, when compared to about 300 cases
between 1976 and 1994 January. Some of the changes authorized
during 1994 and 1995, pertain to plot sizes varying from 105
Sq.yds. to 2000 Sq.yds. in crowded residential areas converting
residential areas to commercial use. This type of piece-meal and
isolated changes are likely to cause considerable inconvenience
and hardship to the residents in the areas concerned, having
serious adverse impacts on their quality of life. The other
glaring aspect is that a number of recreational areas in some of
the localities have been converted into Residential and
In addition to above, large areas of water bodies, drains and
public places have been encroached by way of unauthorized
constructions. The State Govt. is also resorting to allotment of
large chunks of Govt. land, covered under reserved forests,
water fronts etc to various business groups, individuals and
organizations, camouflaged by fancy names such as Botanical
Garden, Night Safari, IMAX Theater etc in the name of attracting
investments and promotion of tourism, unilaterally modifying the
land use notified in Zonal Development Plans. As a result the
Master Plan and Zonal Development Plans of Hyderabad have become
superficial as they are frequently modified to suit individual
requirements and irrational Govt. decisions, with utter
disregard to sustainable development and long term adverse
environmental impacts. Most of the disaster causalities in India
are reported to be a consequence of shoddy planning and non
implementation of plans. The Honorable High Court in a recent
judgment recorded their dissatisfaction over the way in which
Master Plan and Zonal Development Plans are being modified,
keeping the citizens and voluntary organizations in the dark.
By virtue of Article 243 ZE & ZF of the Constitution of India, it
is only a Metropolitan Planning Committee, which shall be
entitled to prepare a draft development plan for the
Metropolitan area as a whole or modify, revise or alter any
existing master plan. Therefore the relevance of provisions of
Urban Areas Act 1975, relating to preparation, revision and
modification of Master Plan and Zonal Development Plans, and
constitution of special area development authorities such as
Buddha Poornima Project Authority, Cyberabad Development
Authority etc under the guise of the need for special planning
control will have to be reviewed in the light of Art 243 ZE & ZF.
|Earthquakes, Skyscrapers and Deathtraps
Capt. J. Rama Rao
The deaths reported in earthquakes occurring in California
and Japan do not normally exceed two digit figures, whereas the
death toll in Latur and Bhuj earthquakes is in 5 digits. It is
attributable to ignoring the grim messages of reported seismic
activities in identified areas, lack of adequate safety norms
for building constructions, and if any, their poor or lack of
The spatial policies for development of urban areas and proper
implementation of these policies, particularly in respect of
land use, are more important for sustainable urban growth and
development, than the skyscrapers. The high-rise buildings are
comparatively more expensive, because of special structural and
safety requirements to be complied with, making them out of
reach for many middle class families. They require more
maintenance efforts apart from being energy intensive, creating
extra strain on civic services. They are also likely to cause
many environmental problems such as air and noise pollution due
to increase in population densities and allied activities and
traffic in the limited area. The provision of fire fighting
arrangements and other facilities for skyscrapers may prove to
be very expensive.
On the other hand, if low rise and compact form of development
is adopted for urban residential areas, the highest permissible
gross residential density of 550 persons per hectare can be
achieved without going in for high-rise residential complexes
with the associated problems. The need to commute to the city
centre can be avoided or minimized by developing well planned
work centers, with offices, shopping areas, schools, hospitals
etc, on the outskirts, thus avoiding overcrowding of city
centers. The information technology, communication network and
fast public transport system will go a long way in decongesting
city centers. By well-balanced and integrated development of all
towns and cities and by bringing down urban-rural disparities,
the creation of mega urban agglomerations and the need for
high-rise complexes just to accommodate more people, can be
avoided. Therefore one need not view MSBs as the only solution
to provide accommodation for growing population. Also in the
light of technological developments of modern times, we need not
repeat the mistakes of the developed countries, by aping
Manhattans and Petronas Towers.
The Multistoried Building Regulations 1981 of Hyderabad was
enacted to enforce, structura1 safety, firefighting, and other
requirements for buildings more than 15m in height or having
more than four floors. At the same time Multi Storeyed Buildings
(MSBs) were prohibited in some of the congested areas and a few
traditional quarters of the city. The MSBs are permitted up to a
maximum of 8 storeys, as the normal maximum height allowed is 25
mtrs. There are however cases of violations, relaxations and
exemptions of regulations, leading to construction of a number
of MSBs more than 8 storeys, the tallest being 16 storeyed in
Bashirbagh Junction. The department of fire services is of the
opinion that more than 50% of high-rise buildings in twin cities
are "death traps", as builders did not bother to follow norms,
regarding safety, prescribed in various rules.
As if this was not enough, the G.O. Ms.No.423 MA dated 31-7-1998
was issued, in the name of rationalization of FAR, Procedures,
Standards of building requirements, etc, removing the height
restriction for MSBs, thus opening the flood gates for high-rise
The earlier restriction on high-rise buildings, in Banjara and
Jubilee Hill areas of Hyderabad and the sea front of
Visakhapatnam, which have been identified as earthquake prone
areas, was also removed.
To cap it all, the G.O. No.419 dated 3007-1998, which is popularly
known as 420 G.O., was issued to get all unauthorized
constructions, in violation of various rules, and regularized.
This infamous G.O. circumvents the very provision of prohibiting
the Govt. or any other authority from granting relaxations,
contained in G.O.No.419 issued one day later. This is nothing
but a back-door entry and hoodwinking of the public, sending
wrong signals to encourage noncompliance of rules, by making it
a very lucrative, high profit and low risk business. Who cares
for the death traps being created? The Politician, Bureaucrat
and Builder nexus think that they will not be trapped either by
ACB/ vigilance or the Death Traps being created by them for the
Shamshabad AirportSome Problems and an Alternative Proposal
Prof. M. V. Nayudu
In a letter
dated 3rd September 2002, Prof. M.V. Nayudu, member of the
Forum, addressed the special Chief Secretary to Govt. of Andhra
Pradesh, Roads and Buildings as follows:
We learn that the International Airport coming up close to Shamshabad about 1
KM to its south, encompasses about 5000 acres to its south,
south west and south eat, and is also hardly about 5 KM from
Himayatsagar - a heritage drinking water source together with
Osmansagar to the twin cities. This is totally against the well
intentioned G.O.No. 111 of 8/3/1996 to protect the 2 lakes from
industrial and domestic pollution.
From the HUDA notification of 14/8/02 that appeared in Deccan Chronicle of
21/8/02, it is clear that a large number of developers and
builders have already laid residential and other plots all round
the proposed International Airport and as close as 1/2 - 1 KM
from Himayatsagar. Apparently this activity is prohibited and
violators may "face consequences of law".
While the G.O. No. 111 prohibits all residential colonies, layouts and red and
orange category industies within 10 KM radius, upstream and down
stream, from full tank level of Himayatsagar and Osmansagar, and
inspite of the Supreme Court Judgement ofDec 1, 2000 the Govt.
allow in the polluting industries to function within the
prohibited zone, disregarding the "Precautionary principle" of
Further, the Govt. and its various ageneies have so far failed to prevent
land grabbers and encroachers from their unsocial activities as
exemplified by various illegal constructions in the MCH and HUDA
are'as, and the constructions of complexes near the "Protected" Durgam Cheruvu, and letting domestic sewage into it from the two
large colonies on its either sides. TIlls is inspite of High
Court Order of July 2001, and protest leters to RR District
Thus, it is a foregone conclusion that the 2 lakes will get polluted in 5-10
years like Hussainsagar, Mir Alam Tank, Saroornagar and
Kattedahn Tanks and many others in MCH and HUDA areas, if
the Airport is built in the prohibited site.
The Location of the International Air Port is _lose to Shamshabad, about 4 KM
from Himayatsagar, and extending to South West, South and
SouthEast of the town and to the lake.
Two major drinking water sources: Heritage lakes.
Situated in drought prone R.R. District fed by 2 major rivers during the
erratic rainy season; together with smaller streams, form the
Many parts of R R have ground water depleted to 80%, some 40%.
Water samples from periphery of Himayatsagar rich in some algae,
indicators of pollution.
Buffaloes and washing common in some places of the 2 lakes.
12 stone crushers operate within 100 Mts. to 1 KM of Himayat Sagar
starting from its dam along road leading to Shamshabad.
Kotwalguda area Against R. R Dist. Collector's order of
Rain water flow obstructions by some big cultivators on some streams.
Some tanks partly destroyed.
The following problems arise due to the above situation.
International Airport will lead to some effuents towards
Himayat sagar despite treatment systems due to efficiency
problems and negligence.
NRSA maps show lineaments and fractures that indicate ground water flow
towards the 2 lakes.
Thus contaminated surface and ground waters reach the 2 lakes
rapidly - pollution.
Many plots are laid out close to the 2 lakes, particularly Himayatsagar.
- Residential colonies will even more rapidly pollute the lakes. Result:
Similar to Hussainsagar, Mir Alam Tank, Saroornagar & Kattedahn Tanks, etc.
MCH, HUDA and municipalities around have not prevented illegal
constructions and enoroachments. Goings on in Durgam Cheruvu
now inspite of High Court order of July 2001 is a classic
The following solutions and alternative plans are put forth.
Shift the airport location to further south of Shamahabad by 15 - 20 KM
to beyond the catchment area of the 2 lakes.
Ban and enforce with accountability all constructions in the catchment
area of the 2 lakes.
Ban further growth of the existing villages and towns in the catchment
area to avoid increased domestic pollution.
The huge complexes coming up now in he vicinity of the 2 lakes should
be made to have their own adequate treatment systems to avoid
polluting the 2 lakes.
No more new constructions should be allowed in the area.
New constructions can be along the 6 main roads leading out of the
city on other sides, taking pollution containing measures for
each unit in a planned way; also protecting water bodies near
- Shift all Rod & Orange category industries to safe areas identified by
NRSA and NGRI and Ground Water Dept. Thus the "Precautionary
Principle" emphasised by the Supreme Court Judgement of Dec.
1,2000 and followed World over will be impklemented.
Permit Green industries like Hard Ware Park in the acquired area near
Shamshabad, releasing no pollutants.
A Lake Development Authority Cell should monitor the catchment areas
of the 2 lakes, destroy all illegal constructions within. 3
days, and severely punish the violators by 2 lakh rme, and
imprisonment for 2 years.
performance of the employees of the cell/authority should also
be punishable similarly to ensure law and water availability.
Drinking water is a fundamental right.
The location of the Airport at Shamshabad and land acquition inspite
of G.O. Ill, the Supreme Court Case in Surana Oil Co., and its
judgment on Dee, 1, 2000 as also the present efforts to continue
the Red & Orange category industries within 10 KM belt indicates
scant regard for good laws and court judgments at various levels