3 Jan 2021
Bangalore Development Authority (BDA)
5th Main Road
Kumarapark West, Guttahalli
With a copy to: Town Planner Member, BDA
Subject: Response to BDA's Notification dated 02 November 2020 (Declaration of Intention of preparing Revised Master Plan 2031) involving: a) Request for meeting with Commissioner, BDA and Town Planner Member, BDA and Team; b) Suggestions for the Revised Master Plan 2031 for Bengaluru.
It is with great pleasure that Heritage Beku has been actively working with the Bangalore Development Authority since 2018. It is important to reiterate our objectives.
Heritage Beku is a citizens led initiative to maintain and preserve Bengaluru’s heritage. We endorse the UNESCO Chair for Heritage promulgates an all-encompassing approach to understanding heritage, where human and natural systems are considered as one integrated whole. Such an engendered approach integrates sustainable development, management of natural environments and resources, sustainable land use as well as agro-ecology. It is inevitable that Bengaluru embraces such an integrated approach to thinking about its futures. To achieve this means, as a hub for dedicated thought and action Heritage Beku’s purpose is to engender, foster and develop a dynamic, evolving framework to support decision making to sensitively shape change and continuity in the built and natural heritage of the City. Over the last three years, Heritage Beku has worked hard to channel a host of diverse voices of citizens, professionals, domain experts, representatives of the private sector as well as other not for profit organisations in the City, to give impetus to a meaningful cause, provide shape to a challenging process in order to usher positive impact on the ground. In the years ahead, Heritage Beku desires now to deepen its efforts as a partner to public institutions to sustain these motivations.
The BDA, entrusted with the responsibility of preparation of the Revised Master Plan 2031, published notice inviting public suggestions and comments in 2017. The Heritage Beku group was among several key organisations in the City that provided well thought through suggestions for finalisation of the RMP 2031. Heritage Beku submitted a document titled, ‘#HeritageBeku #RMP31 Inputs, dated 10 Jan 2018 , involving a comprehensive set of objectives for the RMP 2031 to consider for the Heritage sector. Following this there was a long period of silence from the BDA. In this context, we also wish to bring to your attention another correspondence with the BDA, in 2019, wherein Heritage Beku expressed key concerns on BDA’s silence on finalisation of the RMP 2031. However, in June 2020, the Government of Karnataka withdrew the BDA’s Draft RMP 2031 an issued an order for its re-making. This letter is a response to the BDA’s notification dated 02 November 2020, involving Declaration of Intention for once again, preparing Revised Master Plan 2031. This letter is in continuation with the report Heritage Beku submitted in January 2018, and must be read in conjunction. Heritage Beku’s 2018 comprehensive suggestions to the RMP and subsequent correspondence is available at https://www.heritagebeku.com
It is commendable that the BDA has initiated the process of soliciting public suggestions at the commencement of the preparation of revisions to RMP 2015. Advancing the public consultation process to the beginning establishes a solid ground for evolving a common set of objectives for the city’s spatial, economic, social and cultural futures. Here, below, Heritage Beku has put forth several key suggestions for the revision to RMP 2015. Some of these suggestions hold an immediate imperative, while others need to be systemically integrated in the various components of the RMP, i.e., the geo-spatial data base, the Existing Land Use map, Proposed Land Use Maps, Situation Analysis, the Vision Document, Sectoral Proposals, Zoning Regulations and Planning District Reports.
Process related immediate imperatives:
1. An early meeting: Heritage Beku requests Commissioner BDA for a dedicated meeting on the Heritage sector at the outset. We understand the Karnataka Town & Country Planning Act 1961 mandates public suggestions and comments on the Draft Master Plan. Going beyond this prescription, we are aware that a progressive BDA has solicited public suggestions now, at the start, and has in the past conducted a series of public workshops during the plan preparation process, in public interest. We urge the BDA to take a step further. Rather than engage with civil society for soliciting their suggestions at the far end of the planning process, Heritage Beku stresses that the BDA must call for an express meeting at the very beginning of the RMP preparation process. Such a meeting will advance the co-creation of common heritage goals for the City.
2. Drafting the Terms of Reference: We have learnt through news media that the BDA is in the process of drafting the Terms of Reference for the preparation of the RMP. Heritage Beku seeks to partner with the BDA in defining the Terms of Reference pertaining to the Heritage sector. A transparent process must be installed in selecting the consultants for the RMP preparation. To this end, Heritage Beku offers its expertise and involvement with the BDA as a citizen’s partner, in the selection of the best suited consultant for the execution of the Terms of Reference.
3. Institutional arrangements: Bengaluru’s built, cultural and natural heritage has been under threat for several years and requires permanent institutional solution. The Government of Karnataka has in the past taken initiatives to establish a Heritage Committee. However, the committee has not been operational. In the absence of this body, we urge the BDA to constitute a Panel of Advisors for the preparation of the RMP as well as monitoring its implementation and enforcement. A dedicated focus on the Heritage sector from such a panel would mean empaneling citizen leaders, heritage experts and representatives of business communities interested in heritage preservation. A dedicated elected official and a special team of government officers must be exclusively appointed for the collaborative preparation of the RMP.
4. Heritage Beku as BDA’s partner: Bengaluru, by virtue of being a City with more recent histories as compared to other cities in India, such as Delhi, Mumbai and Kolkata faces a unique challenge. A key issue that heritage preservation confronts in the city, is lack of a demand for it. Government organisations are often fighting more severe needs on a day to day basis, on issues associated with economic growth, providing access to education, health care services or poverty alleviation. Lure for modernity often steers the common inhabitant in the City away from values and opportunities that history can offer. The private sector sees no vantage from a heritage- economics point of view as there is no demand from the society or the State. A good city is one which provides access to basic services to all and promotes science and technology for the future while building on its histories and sustaining the diverse cultural and social values of its people and urban places. Alas, Bengaluru fails to be recognised as one, so far. In such a circumstance, the responsibility to re-instil good societal values vests not merely with the agencies of the State. The responsibility is infact a collective one, one that cannot be imposed from the outside. There needs to a value laden demand generated from within multiple institutions - the political agents, administrators, private sector and the civil society. The process of re-building an endemic spirit needs to be a continuous one, involving crafting of regulatory processes, running programmes, schemes, initiatives, and so on, at the city and local levels. While many of these efforts may seem to be outside of the ambit of the BDA’s RMP, it is only such a collective effort that will truly lead to the framing of locally suitable legislations, regulations in the RMP and enable their appropriate interpretation for implementation on the ground. It is here that Heritage Beku offers its position as a partner to the BDA in its endeavours for heritage conservation and preservation. Given its positive and constructive working relations with multiple public organisations, educational institutions (design and public policy), civil society groups, value driven business entities and citizen’s at large, we believe the BDA will most certainty value Heritage Beku’s contributions.
Suggestions specific to components of the RMP:
1. Regional as well as local growth dynamics: Bengaluru city is experiencing extraneous pressures of growth as well as from within its localities. For example, the national and State government’s proposals for the making of the Bengaluru Mumbai Economic Corridor Region (under the National Industrial Corridors Development Corporation) certainly bears an impact on growth, employment, mobility and spatial development within the city’s localities. A heritage conservation approach to urban planning requires that the BDA’s RMP maintains complete cognisance of the City’s urban places, including the essential values and qualities it has stood for through generations, while allowing these places to transform.
2. A two tier planning process: The Earlier RMP 2031 proposed a two tier planning process where the RMP serves as a macro level strategic plan followed by micro level local area plans. The BDA must retain this proposal and approach in order to safeguard the City’s heritage and essence. We believe the BDA will develop the two tiered planning framework now, keeping in mind the recent enactment of the BBMP Amendment Act 2020, which delineates municipal zones for ease of urban management, formalises the functions of the Ward Committees and Area Sabhas’ and extends the tenure of the Mayor. The RMP must include detailed proposals for the local area planning and urban design of heritage precincts, streets, open spaces, including public and private properties, to be initiated and implemented at the second tier of planning. These must be aligned with Ward level initiatives of the Bruhat Bengaluru Mahanagara Palike (BBMP).
3. Mapping and building a data base: The Earlier RMP included an extensive mapping of areas worthy of historic conservation. In an unprecedented move it also included a detailed geo-spatial data inventory and listing of heritage properties in the city. Request that this data base and list be reinstated.
4. Natural heritage: The UNESCO Chair for Heritage interprets built and cultural heritage as natural heritage. The two are inseparable. Within such a framework, theRMP must develop a region wide framework for preservation of ecologically sensitive areas on public and private lands, including forest lands, rocky outcrops, water shed networks, lakes-tanks and tree groves. Tree protection on private as well as public spaces including streets, parks and playgrounds must be made mandatory in the RMP. The RMP must also include future projects, schemes, proposals and recommend allocation of finances for restoration, rejuvenation of damaged natural eco-systems.
5. Public Transit: Heritage Beku welcomes the State government’s pursuit of the Transit Oriented Development Policy and its City-wide application, as it supports the overall premise of sustainable development by inducing a shift in ridership, from private transport to public transport. We recognise that the BDA will derive the normative directives from the National Urban Transport Policy 2006 (NUTP), which recommends allocation of Floor Area Ratios (FAR) as high as 4.0, in areas delineated as TOD Zones. While such a regulation may enhance intensity of development in proximity to public transit stations, there is one caveat. Through the two tier process, Heritage Beku requests the BDA to mandate a specific exercise to determine carrying capacity at the local levels, in order to prescribe the proposed FAR. In areas rich in historic, cultural, natural value the BDA must maintain a highly sensitive approach to proposing Zoning Regulations. Local level Heritage Precinct Projects must be delineated and proposed in the Proposed Land Use Maps of the RMP 2031. These proposals must be reflected in the Planning District Reports in order to align with initiatives the BBMP may undertake through Ward Committees and Area Sabhas.
6. Public transport network expansion: TOD Zone boundaries, as per the NUTP, are defined as 5 Km radii around transit stations. If we apply this normative 5 km radius around transit stations on a map of Bengaluru, we find that the entire city is infact not covered by access to public transit. The RMP must ensure that public transport networks are made available to all parts of the City. City-wide access to public transit forms part of a heritage approach as increased use of private transport and emissions enhances structural harm to both built and natural heritage. Air pollution weakens respiratory health of the people, on the one hand. On the other, unfiltered surface run-off from streets which enters the drains, water bodies and percolates into the watersheds exacerbates health hazards to the city’s inhabitants.
7. Planning mechanisms: The Earlier RMP 2031 has proposed the use of planning instruments such as Transferable Development Rights (TDR) as a means to preserve built and natural heritage. There are two possible constraints Heritage Beku wishes to highlight. One, that poor enforcement of building byelaws followed by condonation of violation from time to time dis-incentivises the success of TDR; and two, that TDR when applied to heritage buildings needs to be approved by the Heritage Committee. Heritage buildings in cities such as Mumbai have suffered from insensitive adaptations to the TDR policy, causing more harm to heritage value than good. Bengaluru must prevent such an undesirable outcome.
8. Land Use and Zoning Regulations must be ascribed from a place based approach rather than a technical approach. This means proposed land use, permissible FAR, building height restrictions must be ascribed based on the nature of the urban fabric. The prevailing practice of allocating FAR based on road width needs to be discarded, in order to recognise ‘places’ and their ‘inhabitants’ in the City. Particularly for areas in proximity to heritage sites all parameters of Zoning Regulations must be addressed after weighing pros and cons from multiple dimensions.
9. Preserving agro-ecosystems: The western-southern and south eastern arcs of the larger Bengaluru Metropolitan Region form a contiguous whole with the green belt reserved for agricultural land use within the Bengaluru Metropolitan Area. These are lands better equipped with ground water and must be reserved for agricultural purposes. On the other hand, the land in the northern arc is arid and is also unsuited for further urban expansion.
10. Contained development: Bengaluru City has already sprawled extensively and unsustainably. Considering that the peri-urban areas of Bengaluru are unsuited for further urban expansion, it is crucial in the interest of agrarian heritage that development remains concentrated in the core areas of the city, along transit corridors.
11. Financial arrangements: The RMP must propose that the urban local body, all planning authorities as well as lie departments must allocate appropriate finances in their annual plans in order to operationalise the heritage agenda of the City.
12. The Earlier RMP 2031 was exceptional in its approach to heritage. The sectoral proposals on heritage conservation duly paid cognisance to heritage as and natural and cultural values of a vibrant and socially diverse society in Bengaluru. Heritage Beku reiterates that all proposals of the Earlier Draft RMP 2031 must be retained.
13. Building knowledge and capacity among government, private sector and civil society through multiple action oriented initiatives are essential, in order to introduce a heritage based approach and cognisance to urban planning.
14. Implementation framework: Above all to make up for the time lost, a time bound effort is needed. Set clear milestones and deadlines in place. A realistic schedule must allow course correction on an annual basis. A collectively owned Revised Master Plan with clear actionable proposals means setting out responsibilities for all agencies, public and private, involved in plan implementation. To this end, the RMP must prepare a more detailed institutional framework than elaborated so far, to achieve greater clarity on accountabilities. Similarly, a more detailed Monitoring and Evaluation (M&E) framework must be elaborated (than the current framework in the Earlier Draft RMP 2031). This M&E framework must involve citizens and citizen’s groups to co-monitor plan implementation with the concerned planning authorities. The clear milestones must be tied in with the M&E framework.
Bengaluru has suffered without a plan. The City's uncertain futures and risks are only exaggerated if the various issues that plague our City, such as preservation of natural, built and cultural heritage, which is intrinsically linked with issues pertaining to infrastructure including water, traffic, garbage, environment etc. are inadequately attended to. A cohesive plan with multiple stakeholders, collaborative decisions involving citizens’ inputs and the will to bring the RMP into action with invested stakeholders across government, elected and unelected officials, civil society and citizens is urgently needed.
Heritage Beku looks forward to partnering with you to realise this much needed collaborative process.
Note: Heritage Beku’s comments and suggestions to the BDA, on the Earlier Draft RMP 2031 is available at the following link https://citizenmatters.in/wp-content/uploads/sites/14/2018/02/RMP-2031_heritage-suggestions.pdf
Team Heritage Beku