9th April 2015
The Municipal Commissioner, C/o The Chief Engineer, Development Plan, 5th floor, Municipal Head Office, Annexe building, Mahapalika Marg Fort, Mumbai 400001 Subject Suggestions/Objection to Draft Development Plan 2034 – noise pollution Dear Sir, We have the following objections/suggestions to the Draft Development Plan of 2034. The concerns expressed in this letter are limited to the aspect of noise pollution in the DP area. Noise pollution has been identified as a serious environmental and health hazard afflicting almost every citizen of Mumbai in one way or the other. The draft DP states: 16.1.2 They (Noise decibels) exceed the prescribed decibels at practically all over Mumbai in different area categories. The maximum noise levels are recorded in airport area. Besides the State Government strictly follows the norms of court by strictly keeping constant vigil and by attending noise nuisance complaints. Mumbai is among the first Indian cities to undertake a pilot noise mapping project for some of its new infrastructure projects and the first to construct noise barriers to protect people living close to high density traffic from the ill effects of noise pollution. The conclusions that noise in the area around the airport is highest is based on the noise mapping study conducted for the airport area. While the high noise levels surrounding the airport are indisputable, it is impossible to conclude that the highest noise level in Mumbai are around the airport, since there is no comprehensive noise mapping study of the whole city with which the airport noise levels may be directly compared although spot studies do indicate the high noise levels all over the city. Other areas with equally high noise levels from other sources require planning in a manner to protect the health and well being of residents from unhealthy levels of noise. This is particularly true since, during the festival season, apparently in spite of the efforts of the Government as stated in the draft DP, noise levels to which citizens are directly and unwillingly exposed regularly exceed the pain threshold of 120 dB. often even in the vicinity of hospitals including ICUs. At other time of years, varying sources of noise including from educational institutions and religious places violate noise pollution laws during the night and day periods and impromptu open air parties, weddings, political rallies, noise from hotels, bars and restaurants, construction, extra-loud horns on roads through sensitive areas etc violate prescribed decibel limits in all zones of the city. Section 16.2.1. of the draft DP states: 16.2.1 MEIP had strongly suggested adopting an environmental management strategy and action plan. Environment planning seeks to build environmental concerns in the process of land use planning. Since the present development plan of Mumbai operative fro the period 1981 – 2000 did not have explicit role for environmental planning the same can now be done and enforced in respect of major development projects. Challenge is in implementing this without causing high additional costs and avoiding delays. In the next development plan of Mumbai, the environmental considerations in respect of all kinds of development should be in built It is clear from the pilot studies on noise mapping already conducted by the BMC and the para above quoted from the draft DP that environmental concerns require to be built into land use planning. There is an urgent need to demarcate areas where recreational activities may safely take place and to build appropriate infrastructure to ensure that events generating high levels of noise pollution are appropriately zoned away from residential areas and Silence Zones such as hospitals. There is also an urgent need to ascertain effects on noise levels when changing Residential areas into Residential/Commercial areas and to change zoning only appropriately with the findings of the Noise Map. While demarcating any area as hawking zone, projected increase in noise levels need to be calculated and disclosed on the DP. Environmental noise is one of the most serious health hazards afflicting citizens of Mumbai, one of the loudest cities in the world. We request that the DP should not be finalized without a comprehensive noise mapping study of Mumbai which is built into the land use planning of Mumbai and which suggests measures to decrease the high noise levels of Mumbai. Thank you and with regards, Yours sincerely, Sumaira Abdulali Copy to: 1. The Municipal Commissioner MCGM Municipal Corporation of Greater Mumbai Municipal Head Office, Mahapalika Marg Mumbai-400 001. 2. Shri Yashodhar P. Phanse, Chairman Municipal Corporation of Greater Mumbai Municipal Head Office, Mahapalika Marg Mumbai-400 001
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