Face2News/Ludhiana
Depending upon the past experience and as mentioned byChief Minister S. Bhagwant Singh Mann, the colonisers have been selling land coming under parks and roads as well as have duped innocent farmers/land-owners which have not been given complete payment of their land, thus the Policy should be such that there is no technical or legal glitch in it.
However, there are major loopholes in the Draft Policy, which may lead to litigations in future. Further, the Hon’ble NGT has already imposed a fine of Rs 2000 Crores on Punjab for failure in Solid Waste Management and our Rivers and other streams are being polluted due to discharging of untreated sewerage by ULBs, Villages as well as private colonisers. Thus to prevent further damage to Environment, the Policy should be ECO-FRIENDLY and CITIZEN FRIENDLY FIRST.
Meanwhile the Engineers body President Er. Kapil Arora, has sent the objections/Suggestions to the draft of “Punjab Affordable Housing Policy 2022.
First of all, the time limit of 15 days given to submit the Objections/Suggestions on draft by your office is very less as it should have been ONE MONTH. Further no email id has been provided in Public Notice at which Objections/Suggestions can be submitted by the Stakeholders.
It is pertinent to mention here that as held by the Hon’ble Supreme Court, the Email is a valid legal document for even sending summons, sending notices, exchanging of pleading documents etc. Thus, the suggestions sent through email to your office should be considered too. Further, with this policy, the cities like Ludhiana, Jalandhar, Amritsar etc. will continue to grow like Slum Areas. Therefore, just like Haryana & Delhi, some Sector type planning should be done and overlapped over Chajra Plan of relevant villages first, otherwise, there will be no proper space left for Colonies with plot area of more than 150 Sq yards.(SUBHEAD)
It is well known fact that the construction of STP by small developers has proved to be a major failure and resulting into damage to Environment, therefore after planning the locality on Chajra Plan, the Local Body should acquire land to develop Common STP for localities (by levying charges as per number of plots) and sewerage system of localities should be connected to it. Similarly, land for Secondary dumps (Solid Waste Management) should also be planned for a cleaner and healthier city. The layout plans of localities must be made available to the public on the website of the Local Development Authority. Further, the treated water should be collected and used for activities like Plantation and construction works. The effluent or treated water should not be allowed to be dumped into ground or any water stream.
The operation of common facilities like Street Lights, Water Pump operation should run using solar Power systems. It is a well known fact that a coloniser with a colony in 5 Acres of land cannot provide facilities like STP, Water works, solar power, maintenance of plantation etc. thus the Size of Colony should not be less than 15 Acres. Two or more colonisers/owners of land may pool together to develop such a colony otherwise, cities like Ludhiana will continue to develop as unplanned cities which has resulted into over-exploitation of natural resources as well as deterioration of Environment. Due to such unplanned development, local development authorities couldn't find adequate land for development of locality like Sarabha Nagar, BRS Nagar, Rajguru Nagar, Urban Estate Dugri, Sector 32, 33 & 39 etc. and Punjab Govt. had to make pooling policy with private land owner to develop one affordable housing project at Village Daad.
Further, to avoid malfunction of common areas in future like selling of land of roads, parks etc. by developers & owners, the ownership of non-saleable Area should be transferred in name of Local Development Authority immediately at the time of approval of layout plan of locality. Thus it is suggested that the draft of this policy should be prepared again and objection/suggestions should be asked again.
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Page No. |
Particulars of Draft Policy |
Objections/Suggestion |
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Page No. 1 |
REGARDING THIS POLICY WILL BE APPLICABLE TO |
NO OBJECTIONS/SUGGESTIONS |
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APPLICATION & APPROVAL PROCESS |
Regarding Point No. (v): The population density norms must be applicable to this policy too. Further one more Point must be added: The Project must be approved under Punjab RERA Act, 2016 |
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OWNERSHIP OF LAND OR DEVELOPMENT AGREEMENT – POWNER OF ATTORNEY IN SPECIFIED FORMAT |
Regarding Power of Attorney: As held by Hon’ble Supreme Court, the Power of Attorney is not a legal document, thus such document should not be accepted strictly. Regarding Point No. (vi): The ownership should be 100% of land as it is seen in the past that developers have failed to pay the pending amount to actual owners which results into litigations and innocent purchasers have to face the music too. Instead of any registered development agreement, land pooling agreement (just like Policy of Delhi) should be allowed to avoid any litigation. |
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Page No. 2 |
BASIC AMENITIES TO BE PROVIDED |
Regarding Point No. (x): The GPS Coordinates (Longitude-Latitude) of all corners of localities should be mentioned in the drawing to avoid any illegal development outside the locality. There should be adequate space for Secondary Dump for Solid Waste Management & STP as after unplanned development, land of Parks and Green belts is being used for such SWM by MCL & GLADA. Further, there should be proper space for Water Works as due to depleting Groundwater Table, Surface Water Supply is need of the hour and for proper supply, land for Overhead Service Reservoir (OHSR) should be planned at initial stage as due to unplanned development of Ludhiana, land of large number of Parks is going to be used for construction of OHSR. The suggestion regarding Common STP and Common dump may also be considered but the same must be constructed in time. Further, the treated water should be collected and used for activities like Plantation and construction works. The effluent or treated water should not be allowed to be dumped into ground or any waterbody.
Requirement of Site: We strongly object to the 5 Acres provision for Plotted/Plotted & Mixed Group Housing of land as it will create unplanned development in small pockets in Ludhiana and other districts. Just like Haibowal Kalan, Dhandran, Shimlapuri, Gill, Lohara, Jaspal Banger etc. only one Main Road will be available as approach road to large number of colonies due to which there remains major traffic issue which results into damage to Environment, loss of time and money as well as harassment for people at large. Thus, the size of Plotted/Plotted & Mixed Group Housing of land should not be less than 15 Acres and should be allowed at locations which are properly planned for future expansion in the districts. |
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Minimum Width of Access Road and Main Road: Depending upon increasing number of Cars, the minimum width of inner Road should not be less than 30’ as some space is also required to plant trees along roadsides for healthier Environment and to increase forest cover in the district. Thus, depending upon the number of houses, the minimum number of trees should also be mentioned in the policy to be grown and maintained by the developer. The Approach Road should not be less than 60’. |
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Apportionment of Plotted Area:
Regarding Minimum Area under Parks: The land under Park area should not be less than 10% as Punjab is already facing acute problem of very less forest cover and for proper playing area, the width of park should not be less than 100’ and as the colony size should be 15 Acres, the provision of One Park as 50% of total one park area should be deleted. |
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Regarding Maximum total Saleable Area: Keeping in view of present conditions of Environment, for a healthier environment, the maximum total Saleable Area should be 60% of Site Area. Further, to avoid selling of land of roads, parks etc. the non-saleable Area should be transferred in name of Local Development Authority immediately at the time of approval of layout plan of locality |
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Page No. 3 |
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Regarding Plot Sizes: The provision of size of plots (50 Sq yards, 64 Sq yards, 100 Sq yards, 125 Sq yards & 150 Sq yards) should be done proportionately. |
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Page No. 4 |
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INDEPENDENT FLOORS: Regarding Minimum Set Back: The minimum Setback should not be less than 12’ so as to provide proper car parking space (ECS). |
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Page No. 4 |
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Regarding Minimum Parking to be provided: The ECS for plot size upto 60 Sq meters should not be less than 0.75 ECS per dwelling unit |
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Overall, this policy is incomplete and should not be finalized without giving us the opportunity to be heard as well as reasonable justification. You are therefore requested to consider the objections/suggestion and redraft the policy considering the healthier & better environment of Punjab.
