REPORT
OF THE
ADVISORY COMMITTEE
ON THE
‘DRAFT REVISED MASTER PLAN -
2015’
OF THE
BANGALORE DEVELOPMENT
AUTHORITY
NOVEMBER 2005
RECOMMENDATIONS OF THE ADVISORY
COMMITTEE ON THE REVISED MASTER PLAN 2015 OF THE BANGALORE DEVELOPMENT
AUTHORITY
53. The BDA needs to adopt a new approach in
certain respects :
54.
HOUSING : All slums
irrespective of legal status should be marked in the Master Plan, and listed in
the Planning District Reports. This has more than symbolic significance. As an
addendum to the Revised Master Plan a separate study on the housing needs of
the urban poor in Bangalore needs to be prepared, and a programme of housing
implemented during the period of the
Plan.
55.
There is need to provide for low income housing within easy
distance from work, and ensure a basic set of services and sanitation in such
colonies. Development control and sub-division regulations should be on the
basis of detailed plans for such areas. Areas for service personnel
(washerwomen, servants, local sanitation workers, etc.) should be shown in layout plans – up to 5 or
10% of the population.
56.
The housing board and
slum improvement board should take up public housing programmes on such lands
specifically for the low income tenants. In the first place there should be
list of such lands, which should consist of all lands which are not required by
the village community. Details of such land should be made public.
57.
LANDS HELD BY
GOVERNMENT : Government needs to articulate a policy with regard to land under
the Revenue Department. There should be a policy of making public lands
available for priority housing for the weaker sections. The first claim to such
land should be to the BDA and to agencies such as the Housing Board and the
Slum Improvement Board for the specific purpose of public housing for the
poorer families.
58.
INTEGRATION OF
VILLAGES WITH THE URBAN FABRIC : BDA should develop a model plan for the
villages which are likely to get submerged in the urban growth so that the
villagers share the benefit of urban standards of housing and infrastructure.
59.
URBAN AMENITIES : A
time frame of six months should be determined for deciding on the urban
amenities required to be provided in each Planning District, and land for
locating them should also be identified.
60.
FOLLOW UP PLANNING : As
immediate follow up there is need for three levels of detailed planning: that
of the BDA, that of the Service/Sectoral Agencies, and that of the Planning
Districts/Wards. Ward level planning should be a fully participatory exercise
involving the local residents. State Government and BDA should set up Working
Groups for each of these levels of planning with a time limit of 3 months to
draw up their respective courses of action. Financial planning should come in
at this stage
61.
The areas to be
entrusted to the respective Working Groups are :
i.
Strengthening and
restructuring of the Bangalore Development Authority for implementation of the
Revised Master Plan 2015, especially its Town Planning Division, and capacity
for implementation of Public-Private Partnerships
ii.
Heritage conservation
schemes for sites identified in the Plan, and inclusion of any others, and
issues of urban design
iii.
Area improvement schemes,
development of shadow areas, slums; housing schemes such as public housing and
rental housing
iv.
Transport and
utilities schemes
v.
Village integration
and development plan for the 200 meter area beyond the perimeter of the
existing village
vi.
Planning for lands
designated for Public and semi public land use, parks and open spaces, large
infrastructure and large transportation structures, and other dedicated land
uses marked in the Revised Master Plan 2015
vii.
City sub-centres
including their location, amenities and facilities to be provided, access,
public-private partnerships, and major activities for each sub-centre
viii.
Criteria for declaration
of Transformation Zones, Commercial Axis, and Mutation Corridor, and
finalization of the areas to be declared under each
62. Government should
consider setting up a high level committee for the implementation of the
Revised Master Plan 2015 of the BDA. The Committee should be headed by the
Chief Secretary.
63. The Committee is of the view that its Report is a
part of the wider debate relating to the Master Plan and future of the City.
The Committee would like its Report to be made available to the public, and
hopes that the State Government will comply with this suggestion.
CHAPTER 1
: INTRODUCTION
1.1 The extent
of Bangalore Metropolitan Area notified in 1984 is now recalculated at 1306 sq.
kms. from the earlier 1279 sq. kms. With
the formation of the Bangalore Mysore Infrastructure Corridor Project Planning
Area, 65 sq. kms. went out of the jurisdiction of the Bangalore Development
Authority, though, of course, in
practical terms this area continues to be part of Bangalore in very many ways,
not the least because of the BMICP Road (proposed in this Report to be the Proposed Peripheral Ring Road for
this stretch) which passes through this area, and all the developments which
interlock it with the Local Planning Area of the Bangalore Development Authority.
1.2 The
Local Planning Area falls into two broad categories of urbanized and
non-urbanized areas (lands). The area which is not urbanized is mostly
classified in land revenue records as agricultural. It cannot be used for non-agricultural – or, urban –
use unless it is first brought under the conurbation area, and then converted
to non-agricultural use. A Master Plan determines the extent of urbanization,
and what is not brought under urbanization continues to remain agricultural
land, which is intended for cultivation, and liable to pay land revenue to the
Government. The agricultural area needs to be carefully determined for a variety of reasons, such as the
implausibility of providing infrastructure and municipal services which an
urban area requires, to avoid loss of cultivable land, to prevent purely
speculative holding of land, to prevent loss to farmers if land is alienated
before authentic demand is built up, and for environmental support to the urban
area by preserving greenery, water resources and life forms found in nature,
preservation of features of nature whose value is being discovered once again
as essential for protection against vagaries of nature, and so on. The Bangalore
Metropolitan Area is large enough for accommodating for the foreseeable future
period both the needs of the growth of the city and the essential ‘Green Zone’
around the conurbation which has been even in the past a feature of planning
for Bangalore. The available land however, needs to be carefully husbanded. Thus
determination of the area to be urbanized in the period of a Master Plan is one
of the most important objectives of the Master Plan or Revised Master Plan.
1.3 The
Advisory Committee was set up by the Government of Karnataka to study the responses received from the public to the Draft
Revised Master Plan 2015 of the BDA (the Draft or Draft RMP 2015). The
intention of appointing the Committee is obviously to assist the BDA and the State Government to take
decisions on the changes if any to be incorporated in the Draft Revised Master
Plan 2015 before its finalization. On the Committee’s part, it was felt that
our task after study of the responses is to funnel the diversity of views
received from the stakeholders into focal areas on which the Committee would
then furnish its own opinions, keeping in view the objectives of preparing the
Revised Master Plan 2015 as laid down in the Karnataka Town and Country Planning
Act 1961 and the need for speedy implementation of the Plan in the best
interests of the quality of life of the citizens of Bangalore, and ensure that
the growth of the city is achieved in an orderly fashion.
1.4 The
responses of the public were required to be filed by 20th of
September 2005. The Committee had before it about 4000 pages of material
received from responding individuals and groups. The Committee is of the view that its Report is a part of the wider
debate relating to the Master Plan and future of the City. The Committee would
like its Report to be made available to the public, and hopes that the State
Government will comply with this suggestion.
1.5 The task
of the Committee was only to advise on public responses placed before it.
However, the range and extent as well as the volume of responses was very wide.
Individual requests needed to be viewed in the context of the planning concept
or planning proposal which lay at the back of the problem felt by the
responders. The Committee has therefore had to deal with the issues in a broad
manner but hastens to clarify that the Report is not to be construed as a full
review of the Draft Revised Master Plan 2015 of the BDA. A full review of the
draft would require a wider mandate, and much more time and resources.
1.6 It
will be observed from this Report that there are not many instances where the
individual requests relating to particular lands have been dealt with. The
resolution of most of the individual problems requires verification of facts of
the case from the records. In some cases a hearing may also be called for. Most
of the requests arise out of changed zoning of the lands involved. Some cases
involve legal issues because the land involved has received approval from
authorities including the Government, and in some cases the land allotted by or
purchased from the BDA. In the
course of its Report the Committee has attempted to make its recommendation as
to the general principles which can form the basis for deciding the individual
cases. These cases require not a
Committee of this kind, but a designated authority within the BDA and a process
of verification of the facts which can then lead to a decision. It is now for the BDA to take up the
individual cases for specific decisions, for which the response forms or
letters/applications already filed with the BDA during the prescribed period of
60 days to respond to the Draft RMP 2015, should be the basis.
1.7 Despite
the wide range of responses received, in the Committee’s observation the
process of public information and response has still left several areas and
sections of public inadequately
touched. The most notable of these is the relatively muted representations from
the ‘shadow areas’, which constitute along with the traffic and transport
problems, the most important of issues affecting the quality of life of a major
part of the residents of the city. From the affected villages to which the
urbanization is now proposed to be extended also the Committee did not come
across many responses.
1.8 The
provisions of the KTCP Act 1961 relating to preparation of Master Plans has to
be kept in focus.
“12. Contents of Master Plan.- (1) The Master Plan shall consist of a series of
maps and documents indicating the manner in which the development and
improvement of the entire planning area within the jurisdiction of the Planning
Authority are to be carried out and regulated, such plan shall include
proposals for the following, namely.-
a)
zoning of land use
for residential, commercial, industrial, agricultural, recreational,
educational and other purposes together with Zoning Regulations;
b)
a complete street
pattern, indicating major and minor roads, national highways, and state
highways, and traffic circulation pattern, for meeting immediate and future
requirements with proposals for improvements;
c)
areas reserved for
parks, playgrounds, and other recreational uses, public open spaces, public
buildings and institutions and area reserved for such other purposes as may be
expedient for new civic developments;
d)
areas earmarked for
future development and expansion;
e)
reservation of land
for the purposes of Central Government, the State Government, Planning
Authority or public utility undertaking or any other authority established by
Law, and the designation of lands being subject to acquisition for public
purposes or as specified in Master Plan or securing the use of the landing in
the manner provided by or under this Act;
f)
declaring certain
areas, as areas of special control and development in such areas being subject
to such regulations as may be made in regard to building line, heights of the
building, floor area ratio, architectural features and such other particulars
as may be prescribed;
g)
stages by which the
plan is to be carried out.
Explanation.-(i) “Building Line” means the line up
to which the plinth of a building adjoining a street may lawfully extend and
includes the lines prescribed, if any, in scheme;
(ii) “Floor Area Ratio” means the quotient of the
ratio of the combined gross floor area of all the floors, excepting areas
specifically, exempted under the regulations, to the total area of the plot.
(2) The following particulars shall be published an
sent to the State Government through the Director along with the master plan,
namely.-
(i) a report of the surveys carried out by the
Planning Authority before the preparation of such plan;
(ii) report explaining the provisions of the Master
Plan
(iii) regulations in respect of each land use
zone to enforce the provisions of such plan and explaining the manner in which
necessary permission for developing any land can be obtained from the Planning
Authority;
(iv) a report of the stages by which it is
proposed to meet the obligations imposed on the Planning Authority by such
plan.
(3) Master Plan shall indicate “Heritage Buildings”
and “Heritage Precincts” and shall include the regulations made therein for
conservation of the same.”
1.9 The ‘Master Plan’ under the Act regulates land
use, zoning, and development control. The street pattern is specifically to be
provided in the Master Plan, as also land for public purposes. It is evident
that in the growth and management of a city, these only part requirements,
however important in themselves. The Draft Revised Master Plan 2015 disappoints
people who took the ‘Master Plan’ to be a comprehensive all-inclusive plan covering
all aspects of the problems facing the city. It is seen that people expect that
at least those services which are within the purview of public authorities to
provide, should be covered in the Master Plan. Even if the law does not say so,
it is well within the means of the State Government to instruct the agencies
under its purview to provide their respective plans to the BDA. In particular, the issues of transport and
traffic, water supply and sanitation, housing, commercial and industrial
development etc, as well as measures for the decongestion of the city have been
inadequately touched, which indicates a certain lack of coordination between
the different agencies. This needs to be remedied even now by preparing separate
sectoral plans relating to water supply and sewerage, transport, power supply,
municipal services, etc. For these services the Master Plan is the starting point,
because it lays out for the concerned agencies the scope of the work ahead of them.
1.10 In
the ten years since CDP 1995, Bangalore has witnessed massive changes in its
features, growing into a hub of the IT industry in particular, with attendant
growth in population, vehicles, buildings, and economic activity. It has been
one of the most popular destinations for investors. Correspondingly, the poor state
of city’s infra-structure has drawn much attention, and in some quarters doubts
have been expressed whether the city can indeed cope with its status as a
growing metropolis. There have in fact been significant investments in the
city’s infrastructure for roads, public transport, water supply, and municipal
services but it is evident that much more needs to be done to achieve a quality
of life in the city for all sections of its population commensurate with its
ambitions to be a world city. Parts of the city have undergone transformation
which had not been foreseen, thanks to pulls for space for activities not
originally planned in the largely residential, ‘pensioners’ paradise’ kind of an urban settlement that Bangalore
at one time was. Nature of non-residential activities have changed with rise
and fall of some old, public-sector led industries and neglect and degeneration
of early industrial areas, while there is some movement towards newer IT-led
establishments and revitalization of some manufacturing sectors. Extensions
have changed their character beyond recognition, and there are powerful
contrary pulls regarding the use of prime areas of the city. The changes are
too numerous to detail in this brief report.
1.11 The
decade ahead relating to the revised Master Plan is therefore of crucial importance, some would say the most
important period in the life of the city which may make it or mar it for all of
future. The Revised Master Plan 2015 therefore has a role and a responsibility
to ensure that even while Bangalore grows into a Metropolis, the quality of
life in the city which has apparently taken a knock in recent years, is
retrieved and improved, across all sections of its residents. Those
engaged in framing and implementing the Revised Master Plan must learn from the
recent history of Bangalore’s growth, the successes and failures of its
institutions entrusted with various aspects of urban management and their
efforts in this direction, the national and global experience of cities growing
in a tearing hurry, and the pitfalls of
ignoring important social, ecological, and sustainability issues, and apply
these lessons in the planning and regulation of the city’s growth in the
immediate years ahead.
1.12 Along
with technical innovations, the Draft RMP 2015 brings about significant changes
in the approach to planning for the city. Advances in technology such as GIS
have been adopted to good effect and the quality of the document has been
widely appreciated. Apart from better maps and other basic data which are
provided in far greater detail than in the previous CDPs, there are important changes in the planning and zoning concepts, and
proposed regulations. To a degree this is the result of a particular and possibly
more analytical understanding of the trend and direction, and the dynamics and
the complexity of urban growth, its planning needs, and its regulation keeping
in view the future of the city. Consequently, there is an inevitable degree of
effort - if not difficulty - in making the transition from the old Zoning
Regulations to the new, which must be addressed. There are, of course, many
views which disagree with the proposals contained in the Draft, and these are
the issues this Report is mainly concerned with.
1.13 The
process of making a Master Plan : There has been suggestion that the process
was not participatory enough, that there should have been a more ‘bottom up’
approach. Discussion of the Draft with the public is, as many have accepted, a
step forward compared to earlier practice. There is vocal demand for involving
the residents as groups and neighbours in land use changes. It is advisable to involve the residents in
the decisions affecting them such as declaring a Transformation Zone or a
Commercial Axis or a Mutation Corridor, before such a decision is taken,
sharing with them the considerations which have led to the proposal. There is
also need for greater transparency and public consultation in any changes in
land from the use as per zoning regulations, especially if the powers under S.
14A are exercised. Apart from this, we will be suggesting a further process of
plan-making at the Ward level, where participation of the public and elected
representatives will again be recommended.
There have been suggestions relating to the Metropolitan
Planning Committee, on which it is appropriate that the State Government take
decision in accordance with the provisions contained in the Constitution
through the 74th Amendment.
1.14 The Revised Master Plan 2015 should conform to
the provisions of S. 12 of the KTCP Act, 1961. The Draft RMP 2015 is presented
in five volumes, and it is to be emphasized that all these are considered only to
be drafts. By definition therefore, they are likely to undergo changes before
finalization. The volumes are:
Volume 1 – Master Plan Report – 2015 : Vision Document
Volume 2 – Existing Land Use Maps
Volume 3 – Proposed Land Use Maps
Volume 4 – Land Use Zonal Regulations
Volume 5 – Planning Districts Report
1.15 On
perusal, the Vision Document and the Land Use Zonal Regulations in particular
will require to be subjected to corrections and tight editing, as they contain
many errors, tentative data, and inconsistencies. The Vision Report in
particular should avoid repetitive coverage of the same issues which has
sometimes led to inconsistent treatment.
The Vision Document is intended to contain the
basic assumptions, approaches, and understanding of the issues facing Bangalore
city. The Vision Document contains many suggestions and hints on what
needs attention. While these are
important areas for action, the suggestions are left undeveloped. The details
of the proposals need to be filled in, and to facilitate follow-up, model plans
should be developed to illustrate what is being proposed. The law, however, requires
‘a report explaining the provisions of the Master Plan’. This calls for a
chapter each on some of the important aspects of the Master Plan from an
implementation perspective. As an instance,
while considerable work has been done to identify roads to be built and
traffic, transport, and commuter facilities
to be provided, a comprehensive treatment which will show the total picture of
the proposals relating to roads and road based transport - street pattern,
traffic circulation pattern, new roads and roads to be improved taking into
account the requirements of different parts of the city, access to the new
airport, facilities for private bus operators, KSRTC and BMTC and their
interconnection, multi-modal transport, intra-city and mofussil / long distances
bus services, etc., - is missing. Similarly the major provisions relating to
residential development, development of industry and commerce – both
traditional and modern, high-tech including the IT industry, the Green Zone and
other protected lands and water bodies, integration of the villages into the
urban fabric, the problems of slums and the shadow areas, are among those
pertinent issues of the city and the Master Plan needs to treat them individually
in some detail in such a fashion as to give the entirety of the problems and
their solutions which are provided in the Master Plan, each on in a separate
chapter.
In our view these are covered in the requirements
of the ‘report explaining the provisions of the Master Plan’, and should be
part of the Revised Master Plan 2015. Support documents with maps should be
generated for each sector (transport, water supply, sewerage, drainage, power)
along with phasing and cost estimates. This should have the approval of the
sectoral departments and made part of the Master Plan for BDA 2015. In
particular the map for the integrated protection of lakes, valleys, and water
bodies is a crucial map requiring statutory acceptance, and should also have a
programme for the protection and rehabilitation of the water bodies.
1.16 Change
in Planning Area : The 1306 sq. kms. includes 65 sq kms of BMICPA area. An
Outline Development Plan for the BMICPA area has already been prepared. BMICPA
area contains in addition to the 65 sq. kms. which were earlier part of the
CDP, the length of the expressway area stretching all the way to Mysore. This
is a significant development in extending the advantages of the
Metropolitan Bangalore to its
hinterland along the corridor to Mysore. It is necessary to discuss in the
Revised Master Plan the dovetailing of the BMICPA area with the Revised Master Plan
2005 of the BDA because there is an umbilical relation between the two Planning
Areas which can be exploited for the benefit of city and the Southern Karnataka
region.
1.17 Developments
in the Bangalore Metropolitan Region and the Bangalore International Airport
Planning Area : The observation that the Master Plan should comply with s. 81-C
requiring it to be submitted through the BMRDA is valid and should be done even
at this stage. Legally, the Master Plan for BMA has to sit within the BMRDA
Plan. A chapter can still be added identifying the impact of the Bangalore
Metropolitan Region and developments therein such as the new Bangalore
International Airport, on the Bangalore Metropolitan Area. The new
International Airport, though located outside the BDA limits, will still be the
airport for the city. As with the BMICPA, its impact will be felt both within
and outside the BDA limits, and the salience of this development to the city requires
discussion in the Revised Master Plan 2015.
1.18 Planning
Districts : The LPA is divided in 47 Planning Districts, which fall into three
concentric area groupings – core, developed around core, and extension in
outskirts – also described as the 1st, 2nd and 3rd
Ring areas.
Concern has expressed that the CMCs and Panchayat
jurisdictions should not cut across Planning District boundaries, or vice
versa. Though the Planning District is not an administrative unit, the local
government jurisdictions are important, and there appears to be no valid reason
why the wards of the CMCs/TMC, and
Panchayat jurisdictions are not followed in the Planning Districts to avoid
fragmented responsibility. Such convergence would enable detailed plans through
wards and where a focused public participation is possible.
1.19 The
legends in the Existing Land Use Maps and Master Plan and Proposed Land Use
Maps should be the same to facilitate comparisons on changes between 2005 and
2015. The KTCP Act and the BDA Act have
prescribed the range of broad land
uses. The legend of the maps could be reformatted accordingly, with variations
only in sub- categories. The same should apply to each of the Planning District
maps.
CHAPTER 2
: PROJECTED POPULATION GROWTH AND OUTWARD GROWTH OF THE CITY – MEETING LAND
NEEDS FOR DIFFERENT SECTORS IN 2015
2.1 According
to Existing Land Use Survey 2003 carried out in the course of the preparation
of the Draft, the urbanization of the city reached by the year 2003 was 565 sq.
kms., which is the same as the geographical extent which had been projected for
urbanization by the year 2011 in CDP 95, which was 564.6 sq. kms. However there
are major differences between the two: area under Residential, projected at
243.69 sq. kms. for 2011, was only 143 sq. km. in 2003. There was an extent of 180 sq. km. of
developed vacant land in the urbanized area which had not been foreseen. This
is particularly striking, because it is as much as 31.9% of the total urbanized
area in 2003. There are sharp shortfalls in area under Parks and Open Spaces in
existing land use 2003 as compared with the allocated CDP 95 - 2.8% against
8.7%. The area under Transport and Communication also fell short at 13.9% as
compared with the allocated CDP 95 of 20.7%. Thus there are far fewer parks and
open spaces, and far less area under
roads and transport facilities than had been planned. These are important
shortfalls in the achievement of CDP 1995, and have serious impact on transport
in particular, and quality of life in general.
2.2 It
is projected that by 2015 the population of the Bangalore Metropolitan
Area will reach 8.848 million, and the Draft attempts to
propose the required increase in urbanization in order to meet the increase in
population. The area to be urbanized depends on the density assumed. Between
2001 and 2015 the projected evolution of densities is as follows:
-
BCC: from 191 to 236 persons
/ ha
-
Conurbation area: from 100 persona
/ ha to 110 persons / ha
Against this, to take only the new extensions in
the 3rd Ring, the actual average existing net density in these Planning Districts is worked out at around 195 persons per ha. For comparison, in
the six localities of Indira Nagar, Koramangala, Jayanagar, Banashankari,
Vijayanagar, Rajajinagar – taken as a group because of their predominance of
good lay-outs – the average of net densities works out to 457 persons per ha. For
a megacity 100 pph overall would be on the low side. In Delhi, it was assessed
that 170-180 pph overall would be the maximum possible for planned development.
2.3 From
the assessment of population growth, a proposal to increase land under
Residential use from 143 sq. kms. in 2003 to 280 sq. kms. in 2015 has been
made. However in arriving at the size of urbanization by 2015, it appears an assumed
rate of ‘urban sprawl’, and a proposal to extend the urbanization to the area
inside the PPRR, have also played a part. The result is that the area proposed
is far larger than what the city requires by 2015. To treat the ‘urban sprawl’ of
4.54%, which is much higher than the rate of growth of population even while
there is a vast area of ‘vacant developed’ land is to contradict the stated objective
of the Master Plan which is to contain the outward growth of the city in the
interests of better provision and management of urban infrastructure, and
protection of the agricultural zone. The Vision Document states that the
‘expansive mode of development uses a lot of space, is costly to equip and
encourages the use of individual transport…’ It also speaks of incoherence in
the management of urban extension with ‘neither planning nor even a larger
framework’, and absence of control on development. Thus the Master Plan speaks
on the one hand of the need to densify
the already urbanized part, and simultaneously assumes an outward growth. In
both urbanized parts and area to be urbanized hereafter a net density of levels
far below the actual existing levels is assumed, to justify the outward
expansion of the city. To accommodate this assumed inexorable ‘sprawl’ of the
urban Bangalore, the Green Zone of CDP 95 is breached, and even the Proposed Peripheral
Ring Road which is otherwise treated as the outer limit, is crossed at certain
points.
2.4 The
Vision Document states that ‘existing urbanized areas within which urban
renewal and transformation of old zones must be encouraged to limit urbanization
costs and to improve the cost-effectiveness of infrastructures (transport,
potable water, etc.)’ and that ‘future extensions are to be organized and planned
while ensuring the coherence of their development with respect to evolving
needs and available infrastructure and with a real involvement of the private
sector.’ These are sound ideas which if implemented will help reduce the urban
sprawl.
2.5 For
the BDA, an overall density of between 140 to 150 pph should be aimed at for
2015. This would enable a more compact growth at the periphery and more land for greenery now (in the
interstices between the corridors) but more
compact growth beyond 2015. This would also address the planned
objectives of eco-management plans, primarily:
a) High density – Low rise (overall)
b) Compact services delivery
c) Multi-modal intra city transport
2.6 THE PHENOMENON OF VACANT DEVELOPED LAND : Given the existence of 18,000 hectares of ‘vacant developed’ land – defined as ‘essentially land that is fully or partially serviced but unbuilt/non-habitated as per Existing Land Use Survey 2003 carried out by SCE’- the attempt should be bring these areas under construction, rather than further add to this category of land. There is little discussion in the Draft of the causes and contributing factors to the amazing amount of ‘vacant undeveloped’ land which exceeds the actual built residential area of the city as it exists (143 sq. kms.). The phenomenon of vacant developed land in the city, even exceeding the existing residential built up area, is apparently the consequence of a number of factors which can be surmised as speculative holding of land, unsuitability of location of some the lay-outs, inadequate opportunities