Safdarjang Airport Area Development

The area of about 500 hectares near Safdarjang Tomb has rare redevelopment potential due to its location (between Lutyen's Delhi and diplomatic enclave, roughly in the middle of the ridge-river triangle in which came up Delhi's historic cities as well as recent 'south Delhi'), high carrying capacity (with lower density, better infrastructure - inclusive of metro corridor, higher ground water table and more green area than other parts of the city) and no exceptional constraints (not being part of ridge or riverbed). 

Instead of District Park proposed in the Master Plan since 1962, the site has exclusive uses that can be shifted. Airport / flying club [1] were to shift to International airport as per Plan. Golf course / polo ground [2] and Gymkhana [3] activities have better sites at, respectively, Golf Club near Oberoi hotel, Oberoi farm polo ground beyond Airport and facilities at IHC.  Santushti / Sanskriti [4] should anyway have come up on planned shopping / school sites.

Recent proposals by Civil Aviation Ministry and a section of civil society appear to lack of clarity about the Master Plan and its processes and seem constrained by a site-level perspective of opportunities and constraints. In the context of the law about and positions in the proposals mooted for the site, the following 'suggestion' has been sent to earmark it in Delhi Master Plan 2021 for world-class development seeking riverbed / ridge / green belt / ground water notified area sites. Consistent also with nearly 2000 responses filed by citizens from all classes by due process of law in respect of change of land use in environmentally precarious areas, etc, this is posted here to facilitate broader participation in discussion about a rare potential site in the city. 

Suggestion to earmark Safdarjang site for "World-class Development" in MPD-2021

Delhi Master Plan is the statutory framework for development of Delhi, most accurately described as a document of citizens' entitlements in benefits of balanced equitable and sustainable development, entitlements that flow with weight of law from Delhi Development Act and land policy. The Plan can be modified for flexibility, but only by due process of law that guarantees to all accountability and safeguards against arbitrary downsizing of entitlements. There is no doubt there have been gross Plan implementation failures and recent expose of corruption at Plan minding levels in DDA and elsewhere point to reasons for these. It is imperative these reasons are dealt with and unconsidered Plan modifications checked to restore lawful planned development in widest public interest. It is from this perspective that a suggestion is made here not from personal opinion but merely from a planner's accountant-like job of "budgeting" all reasonable positions for Safdarjang Airport site in the context of recent reports / meetings and, more significantly, the Plan and its processes. 

THE LAW |  THE POSITIONS  |  ASSESSMENT  | SUGGESTION 

THE LAW ABOUT USE OF SAFDARJUNG SITE

According to the Master Plan Safdarjang Airport / Flying Club had to shift to International Airport. Use of the site, earmarked since 1962 for recreational use [District Park], has been in contravention of the Plan. Any proposal for the site other than District Park is a Plan modification requiring due process. Moreover, the Plan restricts change of recreational use except in "extraordinary circumstances". Since the site is not ridge / riverbed or green belt, an alternative use is at least open to consideration, but this, too, is required to be holistically made as per monitoring and review provisions set out in the Plan.

The site is in D-Zone, which is residential-institutional in character. The following are unjustifiable:

• industrial / commercial work centres (since modifications that make major alterations to the character of the Plan are not permissible under the Act)

• institutional use (since this is already over-developed in the Zone)

• commercial use (as facility) beyond convenient/local shopping (in view of three non-hierarchy centres in the vicinity -- Sarojini Nagar, Lakshmi Bai Nagar and INA -- as well as NDMC's recent budget allocations for modernising markets in its jurisdiction)

Even if the site seems attractive for any of these, a more holistic assessment will find them unviable. The shelf of landuse options for the zone, within which land use decisions for the site must be confined, thus reduces by elimination to recreational (current), public/semi-public and residential:

• A case for conversion of part of the site to residential use can be made out in context of backlog on population targets for D-Zone (6.3 lakh population was recommended by 1981, but only 4.9 was attained, and 7 lakh was proposed by 2001 as part of the densification strategy and given comparatively high level of services) and the rather high citywide population target for DMP 2021.

• Public-semi/public use is justifiable from Zonal perspective (in order to blur the edge, so to speak, with the Safdarjung Tomb precinct) as well as on account of suitability of the site (in terms of central location and now also planned Metro access) for city level Public / semi-Public use.

THE POSITIONS ON SAFDARJUNG SITE

MoUD/DDA: MPD-2021 vision presentation at Vigyan Bhawan on 15.10.99 spoke (under "Planning Options for the Next Millennium" at no.3 of 3 and at recommendation 7 of 37) of higher density / optimum use of unutilised / underutilised land parcels, mentioning Safdarjung Airport among others.

Ministry of Civil Aviation: As per reports of 13.07.03 and 13.10.03, in December 2002 MoCA formed a committee to suggest use for the site in line with a decision to use land adjacent to all airports and as PM has proposed two world-class convention centres in India, it has offered the land for one.

CII and ITPO: According to news reports of 13.07.03 and 13.10.03 Airports Authority of India received references from CII and ITPO in 2002 for leasing out the airport as an exhibition center.

Activists (on the dais at IHC Agenda meetings of 21.07.03 and 10.11.03)

• Ms Alpana Kishore (activist, area resident) seems worried about risk to open space and heritage. In the meeting of 10.11.03 she made a power-point presentation about Airport/Club with ideas for adaptive reuse in form of "airport/museum/leisure hub with bio-diversity park", etc.

• Mr Kamal Meattle (activist, entrepreneur, area resident) seems to have a businesslike concern about loss of greens for short-sighted real estate gains as well as about non-transparent processes against which he suggested at both meetings recourse to PIL.

• Mr Ravi Agarwal (activist, environmentalist, of NGOs Toxic Links / Shrishti) seems persuaded "greens do not figure in urban planning" and Master Plan and its processes are best ignored, "Delhi has less than 10 per cent of green cover, whereas a healthy city should have about 30 per cent" and development on Safdarjung Airport "will mean the loss of a huge green area".

• Mr Arun Rewal (practicing architect) made at both meetings a case, with reference to cities abroad, for conserving/reusing the Airport, etc. He is quoted (as planner) saying in the news report of 11.11.03 that a convention hall "would entail a change of land use for which the due process has to be followed". The same, of course, applies to Airport/Flying Club as well.

Other positions / s.11A Public Notices for land use change with similar existing/proposed use

• Over 1700 objections filed in response to Public Notice of 15.09.02 for change of land use in green belt -- applicable in principle also because of comparable heritage significance of Sultangarhi Tomb site and MoCA responsibilities in areas in vicinity of International Airport

• Responses to Public Notice of 16.12.02 for change of land use in riverbed for Metro property development -- applicable in principle also because of Metro corridor parameters.

ASSESSMENT OF POSITIONS

Concern about redevelopment: The Master Plan land use of Safdarjang Airport site is District Park. Except perhaps Mr Agarwal, none of the foregoing seems to be advocating this. As such there seems a consensus on re-development / Plan modification and, on this count, conflict in positions is illusory.

Concern about use intensity: MoCA's convention center proposal and activists' proposal of adaptive re-use of Airport are identical in land use terms. Both require only part site (1300 acres in all, according to Mr Rewal) for exclusive semi-public use unlikely to be high intensity in net terms. Inter-se concerns about use intensity appear misplaced and, on this count also, conflict in positions is illusory.

Concern about greens: The Master Plan provides strong legal protection to environmental resources in the city. Conversely, protection of greens in disregard of the Plan can be difficult as the Plan also provides legal protection to competing uses. The case for "preserving" a District Park after misusing it for 40 years is very weak at level of the site. At level of the zone or city it falls apart, as this District Park that never was is prime land that even environmentalists may do well to use to save the ridge and riverbed from development that the city chooses to have but has no other space for. The conflict in positions on this count is really between those speaking for the Safdarjung Airport site and those speaking, through due process of Public Notices, for the ridge and riverbed, both notified by CGWA. It is not illusory, but it is negotiable. None of the parties proposing redevelopment in Safdarjang Airport should have any problem reworking their proposals to factor saving the riverbed and ridge, especially since a lot of world-class development is likely to be low intensity in net terms, and environmental concerns can readily be resolved through site design and/or holistic approaches (including, say, carbon credits -- suggested by Mr Meattle -- on lines of TDR rather than at neighbourhood level).

Concern about re-densification: This seems implicit in the activists' concerns, although their own suggestions are not strictly preservationist, and as a point of clarification it is reiterated that D-Zone has a re-densification backlog and carrying-capacity surplus compared to the rest of the city. Those opposing development on Safdarjung Airport site must equally pursue viable alternatives for zonal re-densification, without which their activism would amount to an attempt to preserve inequitably superior islands for themselves at the cost of stress and squalor, besides environmental loss, elsewhere.

SUGGESTION

Safdarjang Airport is rare potential site and there is no cause for its sub-optimal use. In view of all the above, I suggest that, as per permissible boundaries for Plan modifications, land use of a part of the site be retained as (non-exclusive) recreational and the rest be changed to exclusive world-class residential and public/semi-public use that otherwise seeks locations the city can't afford to lose. The following (totaling 90 Ha / 225 acres), for instance, could right away be relocated to Safdarjang Airport (unless abandoned / shifted out of Delhi):

• Commonwealth Games village proposed / just starting illegally on the riverbed (20 Ha)

• Metro IT project proposed / just starting illegally at Shastri Park / riverbed (15 Ha)

• Sutangarhi scheme for international heritage center and mega housing illegally started / stopped by the court / sporadically re-started off and on since then in J-zone Green Belt (56 Ha)

It would also be possible to explore design options to optimize convention facilities, etc, in relation to these. Heliport, etc, could be developed as facility within all this. DMRC could raise quite a bit of its property development revenue target here. MoCA would find such a land use package more optimal. Environmentalists and architects could work out conflict resolution options, etc. Above all, a lawful and synergistic approach would make for conflict-free, efficient and meaningful participation and restore confidence in holistic planned development and democratic processes of participation therein.

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posted 25.12.2003   |    post ideas to redevelopment@yahoogroups.com

Recent proposals, etc

2003.06.16: In an interview in Times of India DDA Commissioner Planning spoke of better commercial use of areas like Safdarjung airport, etc.

2003.07.13: The Hindu reported Safdarjung airport may end up as a shopping mall, in view of Civil Aviations Ministry's plans pursuant to 'references' from CII and ITPO.

2003.07.21: At an IHC Agenda meeting on Future of Safdarjung airport a section of the civil society made a counter proposal for retaining the Flying Club, etc, which Planners present pointed out was also a Plan modification, etc.

2003.07.22: Clarifications made from the audience at the IHC Agenda meeting about the Master Plan and its processes, sent in a letter to MoCA.

2003.10.14: Letter to MoCA with reference to Times of India report about its proposal for world-class convention centre at Safdarjung airport site.

2003.10.20: Letter to MoCA with reference to Times of India report about proposed malls Vasant Kunj / Mahipalpur area near International Airport in the context of suggestion to seek relocation of such proposals to Safdarjung site

2003.11.06: Letter to MoCA, MoUD, DDA, etc, about another IHC Agenda meeting on Future of Safdarjung Airport to request clarification of official positions, etc, before the meeting on 10.11.2003.

2003.11.11: Express Newsline report on IHC Agenda meeting with no reference to remarks made again from the audience about the Master Plan and its processes, inclusive of engagements by citizens outside the IHC Agenda.

2003.11.15: Letter to DDA to make a 'suggestion' for the area

Accounts of the IHC Agenda meeting of 21.07.2003 about Future of Safdarjung Airport

Letter dated 22.07.2003 to Minister of state for Civil Aviation

Sub:     Request for clarifications about Civil Aviation Ministry's plans for Safdarjang Airport

Ref:      "Future of Safdarjang Airport" - discussion at IHC on 21.07.03

Dear Sir,

I am writing to you to make and to seek certain clarifications apropos what transpired at the discussion under reference that you were meant to but unfortunately could not attend.

The impression that all, other than DDA representative, on the dais conveyed is that Civil Aviation Ministry is working on, with international consultants and on suggestion of CII/ITPO, a proposal for commercial utilization of the site, being resisted by others in favour of continuation of Flying Club, etc.

Please permit me, as a planner, to point out the following:

1.       According to the 1962 Master Plan Safdarjang Airport and Flying Club had to shift to the International Airport. The site to be vacated was earmarked for recreational use then and again in the revised Plan approved in 1990 (District Park). Any other use of the site, including Flying Club and the Ministry’s office is, in effect, in contravention of Delhi Master Plan.

2.       The Plan restricts conversion of recreational use except in "extraordinary circumstances". Since the site is not part of ridge, riverbed or green belt, its conversion - to "regularise" existing use or allow a new one - is certainly open to consideration. But such consideration has to be holistically made as per due process set out in the Plan and Delhi Development Act and is the exclusive jurisdiction of DDA and beyond jurisdiction for any other agency to make at public expense.

3.       I had outlined yesterday how, within limits of flexibility permissible under law, the shelf of land use options for the site reduces to recreational, public/semi-public and residential use. Even if the site seems attractive for any other use, a more holistic assessment will find the same unviable or, at least, sub-optimal. The limits of flexibility, in any case, set the boundaries for all proposals and counter-proposals for the site, all of which can only be suggested to DDA for its consideration.

4.       I had also mentioned that the combination of land uses justifiable as bonafide Plan modification is the same as the one for a 56 hectare scheme comprising of mega-housing, international centre, archaeological park, etc, proposed in a comparable site in the vicinity of Sultangarhi Tomb that is, however, in water-constrained green-belt replete with historic water management structures on the ridge. The Ministry might be interested in seeking shifting of that scheme to Safdarjang Airport site, because unplanned development in that area had lately led to a minor breach in a 14^th century dam, as a result of which there was briefly serious risk of IGI airport getting flooded.

In view of the above, I request clarification of the following:

1.       In case the Ministry is processing in any way any proposal for "commercial utilization" of Safdarjang Airport site, basis for so doing despite provisions of Delhi Development Act and Master Plan that make land use decisions the exclusive mandate of DDA / MoUD.

2.       In case the Ministry is not processing any such proposal, action taken to counter the allegations being levelled about such proposal being considered (without jurisdiction), especially since you could not be present at yesterday's meeting to personally assure us about their falsehood.

3.       The Ministry's plans for vacating the Safdarjang Airport site so it can be restored to District Park as required by the Master Plan as well as details of misuse charges, if any, paid over the years.

4.       Action taken, if any, about the risk of flooding of IGI Airport on account of unplanned development in the southern ridge periphery demonstrated by the minor breach in the 14^th century Mahipalpur dam on the night of 10-11 July 2003.

I do look forward to hearing from you. Thanking you,

Yours sincerely

Gita Dewan Verma

B.Arch (SPA, gold medalist); M.Planning (SPA, gold medalist); PG Dip-Research (IHS-Rotterdam, top rank); Dip-Training (DoPT)

Formerly: Senior Fellow (HUDCO-HSMI), Visiting Faculty (SPA, TVB SHS), Consultant (DfID, IHSP, Nuffic, UNICEF, etc)

Currently: Independent planning researcher and writer and planning consultant to citizens' groups

Letter dated 14.10.2003 to Minister of state for Civil Aviation, copy to DDA Vice Chairman

Sub:      Request for clarifications about proposals for Safdarjang Airport

Ref:       News report - "Safdarjung airport in new avatar" (ToI, 12.10.03); my letter of 22.07.03 re IHC discussion of 21.07.03 on "Future of Safdarjang Airport" (enclosed) and Ministry's response thereto vide letter dated 28.07.03 No. MOS-I/C(CA)/2003/DO No Gen.975

Dear Sir,

As per the news report under reference, Civil Aviation ministry proposes in the 300-acre Safdarjang Airport site "India's first world-class convention centre". The report says "PM had proposed to build two world-class convention centres in India" and the Ministry "is offering the land to the PMO", the proposal "is in keeping with the government's decision to constructively use the vacant land adjacent to airports across the country" and the Ministry "expects the project to take off soon as there are no legal and procedural issues with dismantling Safdarjung airport".

As pointed out in my letter, there is a legal problem with this proposal, viz, it is not permitted by Delhi Master Plan and is beyond jurisdiction of Civil Aviation Ministry to make under Delhi Development Act.

Since the Ministry response to my letter said it was having the matter looked into and since the news report says it now expects the project to take off soon, I presume that the issues I had raised have been examined. I request a response to them and, specifically, clarification of how this proposal in contravention of Delhi Development Act and Delhi Master Plan was found legally tenable.

Thanking you,

Yours sincerely

Gita Dewan Verma

B.Arch (SPA, gold medalist); M.Planning (SPA, gold medalist); PG Dip-Research (IHS-Rotterdam, top rank); Dip-Training (DoPT)

Formerly: Senior Fellow (HUDCO-HSMI), Visiting Faculty (SPA, TVB SHS), Consultant (DfID, IHSP, Nuffic, UNICEF, etc)

Currently: Independent planning researcher and writer and planning consultant to citizens' groups

cc:        Vice Chairman, DDA (with request for clarification of DDA's view apropos legality of the proposal as well as on issues raised in the enclosed letter)

Letter dated 20.10.2003 to Minister of state for Civil Aviation

Sub:     Plans for Safdarjang Airport site and Mahipalpur area near IGI Airport

Ref:      My letters of 22.07.03 & 14.10.03; today's ToI report "Vasant Kunj to have two shopping malls"

Dear Sir,

As per the news report under reference multi-storied shopping malls, etc, are proposed north of Mahiplapur Hauz and Bund. As mentioned in my letter of 22.07.03, disruptions in the historic drainage pattern in this geo-morphologically complex area led to breach of Mahipalpur Bundh, with subsequent flooding risk to IGI Airport, in July 2003. Multi-storied structures here may also be in flight corridor.

Since Civil Aviation Ministry is represented on the Technical Committee to assist the high-level policy committee for guidelines for sanctioning layouts under Clause 3 of the Development Code of Delhi Master Plan, I would be grateful for clarifications apropos the following:

(1)     Basis for Civil Aviation Ministry's concurrence on proposal for schemes (incidentally in violation of Delhi Master Plan), including multi-storied malls, etc, north of Mahiplapur Hauz and Bundh

(2)     Basis for considering a world-class convention centre more apposite for the Safdarjang Airport site than, say, Sultangarhi scheme and other city-level and footloose projects (similar to ones CII / ITPO / NGOs have proposed to Civil Aviation Ministry) being proposed in excess of Master Plan provisions for Mahipalpur area with potential problems for IGI Airport.

Thanking you,

Yours sincerely

Gita Dewan Verma / Planner

B.Arch (SPA, gold medalist); M.Planning (SPA, gold medalist); PG Dip-Research (IHS-Rotterdam, top rank); Dip-Training (DoPT)

Formerly: Senior Fellow (HUDCO-HSMI), Visiting Faculty (SPA, TVB SHS), Consultant (DfID, IHSP, Nuffic, UNICEF, etc)

Currently: Independent planning researcher and writer and planning consultant to citizens' groups

Letter dated 06.11.2003 to Secretary, MoCA about IHC Agenda meeting of 10.12.2003

Sub:     "Future of Safdarjang Airport"

Ref:      My letters of 22.07.03, 14.10.03 and 20.10.03 to Minister of State for Civil Aviation (enclosed)

Dear Sir,

IHC “is hosting a presentation as part of its ongoing series Agenda Delhi on the Future of Safdarjung Airport on Monday, November 10th at 6:30 pm. "After the presentation there will be a discussion and suggestions/opinions from the audience. The discussants include Ravi Agarwal, environmentalist, Arun Rewal, urban planner, Kamal Meattle, entrepreneur & activist; and Alpana Kishore, activist."

At initiative of Mr Agarwal and Ms Kishore a meeting on the same subject in the same series was held on 21.07.03, which Minister of State was to but could not attend. On basis of information Ms Kishore had about CII/ITPO proposal for malls, they were advocating preserving Safdarjang Airport / Flying Club, meant since 1962 to have shifted out from the site earmarked for District Park in Delhi Master Plan. DDA Commissioner Planning represented the state and said MoCA has made no proposal and due process for Plan modification would entail Public Notice. Mr Meattle, on the dais as "old friend of IHC", advised all not to wait for Public Notice but make their point of view prevail through PIL.

Besides DDA Commissioner Planning, other Planners in the audience (including myself) represented the Planning profession. Mr Rewal, a practicing Architect (not practicing Planner) was the only one in the audience to support the [illegal] proposal mooted from the dais. The unanimous view of Planners was that the CII/ITPO and the "activist" proposals were both illegal. Technicalities about boundaries of permissible modifications and due process of law were spelled out for benefit of "activists" on the dais.

I do find a "re-do" of the "Agenda" meeting with a discussants' configuration that excludes the state and professional planners very worrying, especially in view of the following further developments:

(1)  An inquiry into professional malpractices by faculty (especially in Architecture departments) is underway in School of Planning and Architecture, where Mr Rewal teaches Architecture.

(2)  DDA has invited public suggestions/opinion via its website and unconnected exclusive processes for the same on Master Plan issues is inappropriate, to say the least.

(3)  I have received no response to the contents of my letters of 22.07.03 (about "Agenda" meeting of 21.07.03), 14.10.03 (about reported plans for "world-class convention centre") and 20.10.03 (about further developments affecting IGI Airport).

Besides DDA, which is custodian of Delhi Master Plan, MoCA, by virtue of its representation on Technical Committee under Clause 3(7) of Master Plan Development Code, is duty-bound to ensure development according to Plan and not abet or disregard development in contravention of it. Presence of DDA Commissioner at the IHC meeting of 21.07.03 and my subsequent letters, I believe, leave DDA and MoCA no excuse to not clarify their positions about existing and proposed misuse of prime land meant to be District Park. The state is any way duty-bound to ensure that a particular civil society "Agenda" is not privileged over other viewpoints of citizens / professionals. Accordingly, I request you to reply to the contents of my letters under reference before the meeting of 10.11.03.

Thanking you,

Yours sincerely

Gita Dewan Verma / Planner

B.Arch (SPA, gold medalist); M.Planning (SPA, gold medalist); PG Dip-Research (IHS-Rotterdam, top rank); Dip-Training (DoPT)

Formerly: Senior Fellow (HUDCO-HSMI), Visiting Faculty (SPA, TVB SHS), Consultant (DfID, IHSP, Nuffic, UNICEF, etc)

Currently: Independent planning researcher and writer and planning consultant to citizens' groups

cc:

Hon'ble Minister of state for Civil Aviation (for information, in continuation of letters under reference)

Secretary, MoUD (with request for clarification of MoUD’s position)

Vice Chairman, DDA (with request for clarification of DDA’s position, as sought previously)

President, Council of Architecture (in continuation of discussion about obfuscation of professions)

General President, Students Council, SPA (idem)

Letter dated 15.11.2003 to make 'suggestion' to DDA VC, copy to Secretary MoCA and Member Secretary CGWA

Mr Anil Baijal, Vice Chairman, DDA

Vikas Sadan, INA, New Delhi - 110023

Sub:     1300 acres at Safdarjung Airport: "suggestion" as extension to my responses to Public Notices of 15.09.02 and 16.12.03 for change of landuse from, respectively, green belt (J-Zone) and riverbed/green (O-Zone)

Dear Mr Baijal,

I wish to place on record a suggestion for Master Plan modification for Safdarjang Airport site. I am aware any attempt to "advise" a Plan modification outside due process underway for Plan revision is extra-Constitutional, especially so in the spirit of DDA Rules, 1958, that disqualify from membership of Authority or Advisory Council "licensed architect, draughtsman, engineer, plumber, surveyor or town planner" and anyone interested "directly or indirectly in any business of development of land" or "in any subsisting contract made with or done for the Authority" or professionally "retained or employed in connection with any cause or proceeding in which the Authority is interested or concerned". In view of this I have thus far confined my work apropos the Master Plan within the ambit of its implementation and due processes. I now wish to suggest a Plan modification on two grounds, only as extension to my responses to s.11A Public Notices under reference.

My grounds for making a ‘suggestion’ are:

1.   One, proposals are being mooted for Safdarjang Airport site and these appear to me to reflect a degree of bias and I perceive a need to restore a level playing field for public opinion.

2.    Two, I have written four times (between the IHC Agenda meetings of 21.07.03 and 10.11.03) to seek clarification of the official position and this clarification has not been made.

My reasons for extending my response to Public Notices under reference include the following:

1.   I have sought but not received clarifications about announcements, etc, in disregard of Public Notice of 15.09.02 (for international heritage center, mega-housing, etc, in J-Zone green belt).

2.   In the latest development in disregard of Public Notice of 16.12.02, DMRC is developing a 15 Ha IT project in riverbed after DDA Chairman persuaded CWC to reconsider its view. This is even as:

(a)     s11A process for this has not started, as Notice of 16.12.02 did not mention this proposed use

(b)     DMRC's mandate does not include IT promotion

(c)     CWC is not empowered to permit illegal development on riverbed

(d)     CGWA notification precludes use of drinking water reserve for construction, train wash, etc

(e)     DDA is duty-bound to take action against Plan violations and cannot take up their cause.

3.   Development for Commonwealth Games is also reportedly proposed on riverbed. My response to Public Notice of 16.12.02 and subsequent letters apropos riverbed apply to this as well.

My suggestion is that Safdarjang Airport site be earmarked in MPD-2021 for ‘world-class development’ seeking sites in riverbed / ridge / green belt / CGWA notified areas and is spelt out in the Annexure. I request all ideas for Plan modification for (a) Safdarjang Airport, and (b) riverbed / ridge / green belt / CGWA notified areas be assessed in comparison with this.

Needless to add, I think riverbed projects just starting need to be stopped, as they are illegal.

Yours sincerely

Gita Dewan Verma / Planner

B.Arch (SPA, gold medalist); M.Planning (SPA, gold medalist); PG Dip-Research (IHS-Rotterdam, top rank); Dip-Training (DoPT)

Formerly: Senior Fellow (HUDCO-HSMI), Visiting Faculty (SPA, TVB SHS), Consultant (DfID, IHSP, Nuffic, UNICEF, etc)

Currently: Independent planning researcher and writer and planning consultant to citizens' groups

cc: [in continuation of previous correspondence about SJA and/or J-Zone/O-Zone developments]

• Secretary, MoCA, Rajiv Gandhi Bhawan, Safdarjang Airport, New Delhi - 110003

• Member Secretary, CGWA, A2 W3 Curzon Road Barracks, KG Marg, New Delhi - 110 001