23rd Sept, 2011
To,
Shri Prithviraj Chavan
Hon’ble Chief Minister,
Maharashtra State,
Mantralaya, Mumbai 400 032.
Sub: Proposed Elevated Metro – II corridor – Charkop – Bandra Mankhurd.
Sir,
As you are aware the above Metro – II contemplates to construct 32 km. elevated Metro Rail from Charkop to Mankhurd via Bandra. There are seventeen Metro Stations en-route. The proposal also includes construction of 4000 m2 of commercial area above each Metro Station and the rails are to be laid on an elevated via – duct connecting these stations. For upkeep and maintenance of the rolling stock, it is proposed to construct two terminal Metro Yards with workshops and allied activities. Each station spreads over 180m X 30 m. area with height of 80’ to 100’ inclusive of the height of commercial area. The said commercial area of 43000 sq.ft. is on the existing road and is not approvable under the Development Control Regulations of Greater Mumbai 1991. The total construction of the elevated Metro Rail – II spreads over an area of approximately 10,00,000 m2, (1,07,64,000 sq.ft.) (Built-up area) which includes station area with commercial area of about 3,50,000 m2, (37,75,000 sq.ft.) viz – duct area 3,50,000 m2 (37,75,000 sq.ft.) and about 3,00,000m2 (32,30,000 sq.ft.) of Metro yards.
At the outset it is to be submitted that the elevated Metro Rail as proposed in the present scheme is totally non-practical and misconceived considering the existing ground realities in Mumbai in as much as that the elevated Metro is proposed to be constructed on narrow roads that are encroached over long stretches and which are very heavily congested even now. Truly, if the project is implemented in its present form, it will devastate the life of millions of citizens of the Western and Eastern Suburbs and permanent destruction of the locality of these suburbs through which
Metro – II will ply. The project is not in public interest at all and in fact it will adversely affect the lives and properties of millions of citizens of the city. It suffers from grave / serious technical / planning flaws together with legal infirmities that are high lighted hereunder.
<!--[if !supportLists]-->1. <!--[endif]--> The to be constructed Metro – II runs at the centre of the already heavily congested roads having comparatively narrow width of 90’ to 120’ inclusive of the footpaths and central dividers as also encroachments at several long stretches and these widths were prescribed considering the need of vehicular traffic at the material time and future increase of vehicular traffic and constructing Flyovers. It was never contemplated to use these roads to erect huge structures of fire ducts and stations of an elevated Metro Rail. In fact on account of easy availability of cars and the affordability of the public more and more vehicles are being added on these roads and that too much beyond estimated increase. Even at present these roads are being utilized beyond their capacity. Vehicles literally crawl on these roads at peak hours. At places and for long distances the road width is lesser than 90’ because of encroachments thereon. Only 9 k.m. runs on 120’ road and the remaining 23 k.m. ply on road 90’ or less width due to encroachments. Even the 120’ wide Link Road starting from JVPD Scheme upto Marve Road is heavily congested. All these stretches including 120’ Link road stated above experience traffic snarls even at present in the morning and evening peak hours; speed of travel of motor vehicles drops down to 8 km / 9 km per hour all along the Link Road. It is actually verified by car driving that it takes during the peak evening hours almost two hours to go from Bandra to Malad (West) along the road on which Metro – II is to be constructed. Motorists as well as commuters in buses travelling on these roads get exhausted and tired with fatigue, which speaks on their health and efficiency. Pedestrians especially ladies, children, elderly are unable to cross the road for long time and have to jostle with vehicular traffic at times leading serious fatal accidents, which are increasing day by day as shown by statistics of Traffic Department. Pedestrians are forced to walk on the carriage ways at many places either on account of missing footpaths or encroachment in these footpaths by hawkers autos and taxis parked to pick up passengers or drop them all along these roads for long stretches and telephone / electrical boxes.
It will be disastrous for the citizens of the Western and Eastern Suburbs if massive columns with their protective anti-crash devices all around are constructed for the elevated Metro Rail at the Centre of these permanently busy roads as they will take away two traffic lanes (one in each direction) from the existing carriageway. Taxis/Rickshaws, private and public buses, vehicles – all will suffer from the aggravated traffic congestion. The present average 8/9 k.m./hour speed of travel will reduce to half i.e. 4 to 4.5 per hour and the travel time will consequently double leading to exhaustion of the motorists, public transport drivers, buses, ambulances etc. The fuel consumption will be exorbitant - this will be national waste of scarce commodity. In such traffic scenario even Fire Engine and Ambulances will not be able to ply on these roads in response to “Fire Call” of citizens resulting in colossal damage / destruction of life and property of the public. The number of vehicles that ply on these roads is increasing day by day on account of rapid growth in population of these Suburbs and this will continue in the future.
It will be disastrous for the citizens of the Western and Eastern Suburbs if massive columns with their protective anti-crash devices all around are constructed for the elevated Metro Rail at the Centre of these permanently busy roads as they will take away two traffic lanes (one in each direction) from the existing carriageway. Taxis/Rickshaws, private and public buses, vehicles – all will suffer from the aggravated traffic congestion. The present average 8/9 k.m./hour speed of travel will reduce to half i.e. 4 to 4.5 per hour and the travel time will consequently double leading to exhaustion of the motorists, public transport drivers, buses, ambulances etc. The fuel consumption will be exorbitant - this will be national waste of scarce commodity. In such traffic scenario even Fire Engine and Ambulances will not be able to ply on these roads in response to “Fire Call” of citizens resulting in colossal damage / destruction of life and property of the public. The number of vehicles that ply on these roads is increasing day by day on account of rapid growth in population of these Suburbs and this will continue in the future.
Pedestrians safety is also of huge concern in this regard since statistics show that they form major component of road fatalities in Mumbai. Construction work on road forces pedestrian on to roads which leads to several accidents. What will be the fate of pedestrians if the road carriageway is reduced is for anyone to imagine. Are they to be treated as “forgotten citizens” and ignored and left to jostle with vehicular traffic and fend themselves ? Children and elderly citizens will suffer the most.
<!--[if !supportLists]-->2. <!--[endif]--> Somewhere in 2003 MMRDA had carried out survey and prepared MUIP Scheme to give some relief to vehicular traffic in the Western Suburbs. The objective of the study was to provide a signal free ride to motorists from Bandra to Dahisar. It was decided to construct several flyovers on these roads at the junctions of the important roads so that the flyovers can provide a signal free journey to reduce travel time and give consequents relief to the motorists and commuters in buses, taxis, etc. apart from saving fuel and protect their health. The efficacy of construction such flyovers is confirmed by the flyovers constructed along the Western Express Highway and Eastern Express Highway where the time of travel from Bandra to Borivali and Sion to Thane has reduced to half now because of these flyovers providing signal free drive. Also the Metro Rails, whenever proposed / constructed are provided underground and never on existing roads within the City Area. In Chennai the proposed Metro Rail to run though Urban area is to be constructed underground and it is proposed elevated only in the areas outside the City. Similarly in all Metro Cities in China like Bejing and Shanghai such Metro Rails ply underground and efficiently. Elevated Metro – II will forever eliminate the possibility of constructing flyovers to ease traffics in the Western Suburbs in the future. No relief will then be possible to be provided to the ever increasing vehicular traffic on the road below. This is very important aspect of Judicious planning for future traffic increase in the Western Suburbs has been ignored and overlooked by Elevated Metro – II proponents. This can be equated to a classic example of non-application of mind by the public authorities. This lack of foresight shall manifest in the future when it will be too late if the elevated Metro – II is constructed on these roads. The Commercial / Financial capital of India will be crippled devastatingly forever for the aforesaid reasons resulting in massive economic loss for the City.
<!--[if !supportLists]-->3. <!--[endif]-->Elevated Metro Rail at the centre of the existing roads was never planned and contemplated by both Mumbai Municipal Corporation and the State Government in the Urban Development Department at the time of preparing and then sanctioning the Development Plan of Greater Mumbai and the Regional Plan. The land use maps of these authorities does not provide for construction of elevated Metro Rail on the public roads shown on the maps. These roads and their widths were planned after detailed Survey evaluations of the traffic then existing and the anticipated future increase as rationally estimated. No city in the World has an elevated Metro Rail on 90’ to 120’ congested Road which are encroached and that too with commercial / shopping areas at stations at a height of 80’ to 100’ as proposed in Metro – II. It is surprising to note that Mumbai Municipal Corporation, which is the implementing authority of the Development Plan as also the owner of the roads is mutely observing this. It is high time the Government / MMRDA and Municipal Corporation realize the mess and devastation the elevated Metro – II with create in the areas along which the elevated Metro – II will ply. Mumbai Municipal Corporation which is the Local Planning Authority ought to have objected to use their roads to accommodate elevated Metro Rail as the same was never planned under both the Development Planning 1962 and 1991.
<!--[if !supportLists]-->4. <!--[endif]-->Another very glaring / serious flaw of the elevated Metro – II relates to Fire Safety and security of the citizens and the commuters of the Metro Rail. This is a very crucial aspect of any Metro Rail, which runs through City; more so because of spate of railway accidents, derailment’s and increasing terrorist attacks which have led to loss of life and property. It seems the project proponents have treated this issue in a “Cavalier” fashion all along. In emergency event the ambulance will not be able to reach hospital in time resulting in loss of life of the patient. In fact safety, fire and security aspects need to be addressed and analyzed in depth by experts in the field at the beginning itself before sanctioning the project.
All the Metro stations extend over the entire width of the road and come in dangerous / close proximity of 5’ to 10’ from the existing structures at many places blocking their light and ventilation as these stations have height varying from 80’ to 100’. Each station has commercial built up area of 4000 m2 at the top. Station being an “Assembly” Building where people gather, it is mandatorily required to provide an open to sky court yard of at least 20’.0” around every elevated Metro – II stations for movement of Fire Engine in case of fire. Metro Rail will ply at an elevated level and if fire occurs in via –duct at location between two stations, the evacuation of commuters will be a problem and for that matter evacuation of people from stations also. The existing buildings will be at a close proximity of only 5’ to 10’ from the Railway Station and will be exposed to fire risk if fire takes place in the station. Apart from the safety/security risk, the residents all along the Metro Rail will be exposed to loss of privacy and sleeplessness due to noise pollution created by Metro Rail passing every 5 minutes, activities of anti-social elements etc. Fire Safety and security aspect are completely and conveniently ignored / overlooked. It is mandatory that no compromise is tolerated at all while insisting upon compliance of Fire Safety norms and ensuring general safety and security of citizens. As we understand, the Chief Fire Officer who enforces the fire safety norms prescribed in Maharashtra Fire Prevention and Life Safety Measures Act 2006 has not yet granted any clearance to the elevated Metro – II. No where in the World Metro station is constructed in such close distance of 5’ to 10’ from Residential Buildings & other inhabited structures. Hence it is our say that the contentions above shall be kept in mind without fail while dealing with application for N.O.C. of C.F.O. when submitted by M.M.R.D.A. If any untoward incident of Fire takes place resulting in loss of life and property on account of any laxity in this regard, the concerned authorities and executors of the project shall be responsible and liable to face criminal action and consequences thereof as provided in Law.
Further, very heavy traffic will be generated at Metro Stations. Autos and Taxis will halt at all stations for pick up / alighting Metro Commuters resulting in frequent stoppage of traffic. Also there are no parking area available in the vicinity of practically at all the stations. There will be utter chaos at the Metro stations. In addition hawkers would surely add to the woes of the public. Also no provision of private car, Taxi, Auto and 2 wheeler parkings is available at most of the proposed Metro stations each having office commercial built-up area of 43000 sft. The mess that would be created at all the proposed Metro station will be unimaginable. The quality of the life of citizen of entire Western Suburbs will deteriorate / become pitiable.
<!--[if !supportLists]-->5. <!--[endif]--> Along the alignment, the Metro Rail Track is required to negotiate several curvatures en-route to change the travel direction. At all such curvatures the track runs across the existing occupied structures. This will necessitate acquisition of the property at a very heavy cost and then demolish these to accommodate the via – duct / track. This will also lead to mass displacement of the citizens causing injustice to them for no fault on their part. There are about eight to ten such curves where there will be massive displacement of people, which is obviously not desirable.
<!--[if !supportLists]-->6. <!--[endif]--> As stated hereinabove the construction of the elevated Metro – II would require construction of approximately 10,00,000 m2 (1,07,64,000 sq.ft) built-up area. Consisting of Metro Stations, Metro Yards, commercial areas, via-ducts etc., being one continuous structure. This will require obtaining prior (EC) Environmental Clearance from the Ministry of Environment & Forests, Government of India as per the Notification No.1533 E of 14-09-2006. The said prior (EC) has not been obtained by MMRDA as yet. Metro Yards have growth of Mangroves, which are classified as CRZ – I under the CRZ Notification No. S.O. 19(E) of 06-01-2011 issued by the Ministry of Environment, Government of India. No construction can be permitted in CRZ – I as per the said Notification. In fact MCZMA (Maharashtra Coastal Zone Management Authority) has refused to give clearance to the Metro Yards at Charkop and Mankhurd because of CRZ – I classification. In addition to this several important public amenities / open space are affected by Metro yards. As it is, the available open spaces are far below the norms and these open spaces Development Plan reservations of Recreation ground and play Grounds should not be reduced further. In fact such reservation need to be increased to take care of the increase in the population much beyond the estimated figure considered at the time of sanctioning the Development Plan 1991-2011.
In the present context we may refer to the proposal submitted by M.M.R.D.A. to the Urban Development Department wherein several lands are proposed to be reserved for various Metro Mono Rail Yards to be located on lands that are at present reserved for public amenities of Play Grounds, Recreation Grounds, Schools, Markets, Government Staff Quarters, Education Complexes, Markets etc. The proposal contemplates deletion of these public amenities to the exclusion of Recreation Grounds and Play Grounds to make room for the Metro Yards. Even the Recreation Grounds / Play Grounds which are to be retained have been shifted / relocated at places that are already encroached by buildings and hutment colonies or in No Development Zone. Hence these will remain on paper only.
It is also a fact that present population has already exceeded the estimated population considered by providing public amenities in the sanctioned Development Plan of 1991/2011. As a result the D.P. reservations of these amenities is already falling short of the requirements. In fact such amenities need to be increased to provide for the future growth in population and to be considered at the time of preparation of the Revised Development Plan for 2012 to 2032, which is under preparation.
Most importantly all Mangroves have been notified as “Forest” under Indian Forest Act 1927 under the orders of the Hon’ble High Court Mumbai in the W.P. (PIL) No.3246 of 2004. Being so the Forest (Conservation) Act 1980 shall apply to the lands of Metro Yard and Non-Forest activity is not permissible on it. Land on which Charkop and Makhurd Yards are proposed are covered with thick Mangrove Forests.
In the above circumstances, it is our say that if at all the Metro Rail is to be constructed, it can ply underground as is done / as is being done in the Metropolitan cities World over. This will not disturb / interfere with the existing road net work or any utility services and will also keep in reserve the scope of improving the same in future when traffic volume is sure to increase. It is observed that the traffic volume almost doubles in about 10 years. It is absolutely necessary that the present net-work of roads should be kept in tact for future needs and improvement by construction of flyovers. Due to the easy availability of cars and improvement in the quality of life, the vehicular traffic goes on increasing at a very fast rate, which cannot be ignored. In fact general public interest unanimously demands underground Metro Rail. It is not understood why the said demand is being rejected without even studying the feasibility thereof. We contend that an underground Metro would be far citizen friendly and more urban planning / environment complaint. This has led us to believe that underground Metro is rejected for an obvious reason that it will give lesser profit to the concessionaire. Surely this consideration should not be allowed to prevail over the larger interest of public safety security and other advantages / welfare of the citizens.
Lastly it is to state that the so-called benefits / advantages / merits of an elevated Metro Rail – II as proposed (though not admitted) are liable to be completely set side / overshadowed by the horrendous adverse effects and negative impact it will have on the traffic and environment of the City and the lives and properties of citizens including mass displacement of people and demolition of the existing residential buildings at curvatures as also the basic existing infrastructure of the City.
It is our sincere understanding that the authorities cannot and would not be immune and insensitive to the stated grave problems of the traffic congestion, safety and security of the citizens and commuters, noise and environmental pollution , inconvenience etc., and including massive population displacements that would be caused if the elevated Metro is constructed as proposed. The elevated Metro – II project is surely a brain child of bankrupt minds of the face of it. It is liable and hence required to be scraped to prevent devastation of the quality of life of its citizens.
To recapitulate our say in nut shell, the elevated Metro Rail – II from Charkop – Mankhurd via Bandra in the present form will be disastrous and against the larger public interest, especially citizens of the Western and Eastern Suburbs as it is fraught with countless flaws enlisted above and as it is proposed without proper application of mind on the part of planners who have completely ignored its adverse implications on the future need of traffic on the existing road network and the need of improvement in future to give relief to vehicular traffic which is going to surely increase in the same proportion of increase in the population of the Western Suburbs. No detailed traffic study has been carried out by experts in the field of Traffic Engineering. The present planners shall be held solely responsible for the sad state of traffic congestion that will occur if the elevated Metro – II is constructed over these roads - in addition to the danger caused to the public being exposed to fire, safety and security problems mentioned above.
Further to this, proximity of the Metro Rail to the existing buildings of all types of occupation of residential, commercial, educational, institutional etc., will be exposed to serious terrorist attacks that have increased presently. Surely the State Government would not like to be associated with such scheme which is fraught with technical / planning flaws as also exposing the citizens to countless problems and endless sufferings enumerated hereinbefore in addition to massive demolition of existing buildings and displacement of citizens as mentioned above.
Most importantly the entire Elevated Metro – II violates provisions of multiple legislations and regulations viz. (a) Maharashtra Region Town Planning Act, 1966 & D.C. Regulations framed thereunder (b) Environment (Protection) Act 1986 & rules framed thereunder (3) Mumbai Municipal Corporation Act 1888 (4) Constitution of India (5) Maharashtra Fire Prevention and Life Safety measures Act 2006 (6) The Air Prevention and Control of Pollution) Act 1981 (7) CRZ Notification dated 06-01-2011 (8) EIA Notification of 14-09-2006. It can be termed as classic example of a project which is misconceived, impractical, hazardous, against larger public interest and non-complaint of the provisions of the relevant laws and legislations.
Under these circumstances Underground Metro is the only option available which shall not only integrate other modes of transport and whatever investments made today by the government shall positively benefit the future generations.
It is therefore our humble request and seek your honour’s timely intervention in the matter of our grave concern stated above. It is sincerely hoped that our above submission will be considered and relief is given to the citizens.
Yours faithfully,
P.S. : What is stated apprehensively above of deliberated devastation of the city by MMRDA is already been demonstrated in the ongoing execution of Metro I (Versova-Ghatkopar) as well as Mono Rail project (Wadal-Chembur Route).
It is shocking that a small stretch of 11 km. of Metro I is under construction for last four years and is now curtailed to just 3 kms., making a mockery of public trust and exchequers money. There is no hope that remaining 8 km.s will see light of the day in present circumstances.
The Mono Rail project is comparatively much smaller in volume and complexities, has also elapsed all possible deadlines that too with massive over-runs in costs.
Even a simple project like skywalks had to be abandoned by MMRDA due to lack of planning and absence of foresight, resulting in destroying of sublime streets of the suburbs.
Yours Sincerely,
For Save our Suburbs
Sherley J Singh
(Convener Core Committee)
9821035469
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