The Proposed Development Control Rules (DCR) for Pune - An Analysis

This analysis of the Proposed DCR is coming a bit late. The frenzy of voices for and against the DP and the DCR have died down. Nevertheless, as a loyalty gesture to my blog followers (:-), here is a quick Analysis of the DCR that I have presented in various fora:

The Proposed DCR are radically different from their predecessor and I am glad of that. In the government, very rarely do we see officers taking a radical approach and this is surely a good sign. The document itself is actually quite well organized, short and to the point, with many issues given clarity, instead of just leaving decisions to the discretion of the Municipal Commissioner. Personally, I liked the shortness and crispness of it.

Secondly, a very serious attempt has been made to simplify the FSI equations. This will make the life of architects better (who want to seriously practice & build good buildings), but this will also ensure that the right revenue dues are brought in by the Local municipal government. With complex FSI rules, I feel that the government was losing a large revenue, when architects and builders proclaimed to be building less, but were actually building more! The concept of Fungible FSI, has made its entry into Pune through these DCR! Only time will tell, how well this system is managed by the municipal officers of the Building Permission Department.

To a large extent, a very serious attempt is seen to avoid multiplicity of scrutiny by different departments of the government. For example, Height of a Building is governed by the DCR, the Airport Authority and the Fire Officer. The Proposed DCR has now linked the Height of the Building only to the Road Width adjacent to the plot. For example, how many floors to build is left open to market conditions prevailing at the time and the capacity of the Developer to invest in a high rise building. How this will impact the skyline of the city, has however, not been studied. Nevertheless, its a progressive move to promote vertical growth, which is far efficient & smart than horizontal growth.

Principally, the proposed DCR have inserted the mechanism of Accommodation Reservation. In this, the landowner, will be able to develop the Reservation. This will not only reduce the overall resistance to Reservation acquisition, but will also reduce the fiscal burden of developing Reservations on the PMC. A smart move indeed!

Lastly, the proposed DCR have incentivized Green Buildings! Yay! For a marginal additional FSI, green buildings are promoted. This is a good move towards making buildings that used less energy, less water and manage their wastes.

My appreciation, unfortunately, never comes by itself. It is always balanced by criticism, as I like to tell myself - that there needs to be a balance always! :-)

Some of the essential aspects that are necessary to understand how a city will grow, in terms of its population density, the regulation addressing Tenement Density is sorely missing from the DCR. This is a single most huge gap. Even today, we struggle, to estimate the population estimates and particularly fall way behind in aligning required civic amenities. This is largely because we don't know, or can't estimate, as to which urban policy (or part of it) will cause which neighborhood to grow its population density. At a time, when we are seriously contemplating a Public Transport Infrastructure like the Metro, not addressing the issue of Tenement Density, or indirectly, the Population Density, is a serious fault in the DCR.

The Cluster Development Policy, for some reason, has been further diluted and the minimum plot size requirement is reduced to nothing! As per my theoretical knowledge, Cluster Development policy is implemented, when amalgamation of plots needs to be incentivized so that congested and/or unplanned areas of a city will generate small parcels of land for fulfilling the civic amenity requirements. In the Cluster Development policy of the proposed DCR, this element is completely missing. It is just allowing and marginally incentivizing small plot amalgamation. There is a serious threat to the core city structure with this policy. With small plot amalgamation as the only strategy of the Cluster Development policy, the city will end up building elite housing inside the core area of the city (again, no tenement density regulation either to control size of housing), pushing out the current residents and finally further increasing (not relieving) the stress on the current civic amenities.

The 4.0 FSI and the Metro Influence Zone, both contentious issues, are retained by the DCR, which is of concern. I am personally against and wary of any kind of blanket rules across the city. Cities are complex interplay of small neighborhoods and each smaller part has its own unique characteristic - economic and socio-cultural. A blanket urban policy, such as a 4.0 FSI, along the Metro route, cutting across small parts of the city, seems like a policy that is not thought through. Planners in the government departments, cannot shirk away from micro planning analysis and studies, by such blanket rules. Such an approach, so far, has caused this kind of urban mess that we live in.

Some aspects of the DCR, like the requirements of Open Space, are in direct violation of the Supreme Court order which mandates that the mandatory Open Space should be free from all encumberances and as far as possible vegetated. The proposed DCR allows services like garbage treatment, Generator sets etc to be placed in the mandatory Open Space, which is not acceptable. I think, a mandatory 5-10% services area will ensure that services are placed. After all, the services of a building makes it liveable, even if we architects, refuse to acknowledge it! :-).

Another important aspect in Urban Design that the DCR has lost (and never had previously either), was a concept of constant front margins, particularly on specific streets. The front margins will vary as per the height of the building, creating a staggered street frontage. I had earlier spoken of a stepped margin, that is, reduce the width of the building as its height is increased, but keep the front margin constant to have a more structured street scape. Such and many more urban design features are simply lacking in all our DCRs. This is a serious lapse, since there are never any architects-urban designers involved in the process of formulating DCR!

While, the simplicity and crispness of the DCR is admirable, its potential problems are evident and its operationalization in the Building Permissions department of PMC is questionable.Whether new approaches can function with existing governance mechanism, is the question that I keep asking myself? Newer methods will also need newer methods of scrutiny, transparency and governance accountability, which is a task that PMC will need to take, if these and any versions of a progressive DCR are to be made successful and effective!