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PETITION TO THE HONOURABLE MINISTER OF STATE FOR ENVIRONMENT & FORESTS

Shri Namo Narain Meena


Hon. Minister of State for Environment Ministry of Environment and Forests. Government of India Pariyavaran Bhavan CGO Complex, Lodhi Road New Delhi - 110003

PETITIONERS
Remaking Of Mumbai Foundation (ROMF)
along with

Citizens Forum for C Ward Development (CFCD) Old Buildings Landlords Welfare Association (OLWA) Federation of Associations of Maharashtra (FAM) & over 20,000 citizens of C &D Wards of Island City of Mumbai
for

REMOVAL/RELAXATION IN CRZ II PROVISIONS FROM AREA AFFECTED BY CRZ IN C & D WARDS OF GREATER MUMBAI

Respected Sir, The following is the back ground of the Petitioners 1) Remaking of Mumbai Federation (RoMF) Remaking of Mumbai Federation (ROMF) is a Federation of over 50 Chambers of Business, Associations, Institutions, NGOs, pertaining to Architects, developers, tenants, property owners, engineers etc. having lakhs of stake holders who have interest in developing Mumbais over 20,000 dilapidated buildings to save the lives of lakhs of people who are living under the shadow of death in these buildings while remaking Mumbai into a World Class City with matching infrastructure and all this on a self financing basis. The Federation has various dignitaries on their Managing Committees and on its Advisory Council. The objectives & other details of the Federation is as per Annexure A. 2) Citizens Forum for C Ward Development (CFCD) Citizens Forum for C Ward Development is a large group of eminent citizens of C ward who have come together to work constructively for the redevelopment of its ward and is represented by a managing committee and a mohalla committee consisting of representatives of each of the 129 mohallas. The details of the Managing Committee and the members are as per Annexure B. 3) Old Buildings Landlords Welfare Association (OLWA) OLWA, Old Buildings Landlords Welfare Association, is an Association formed for the cause of the landlords of dilapidated buildings in Mumbai, who are suffering from various laws imposed under the Bombay Rent Control Act. pg. 1

The association is working towards getting the correct value of the building in favour of the landlords while seeking their co operation, to enable the redevelopment of buildings. Committee are as per Annexure C. 4) Federation of Associations of Maharashtra (FAM) FEDERATION OF ASSOCIATIONS OF MAHARASHTRA is an apex body representing more than 750 associations/chambers of Trade, Transport and Small Scale Industries from all over Maharashtra. This year FAM is celebrating its Silver Jubilee Year. During these 25 years Federation has been able to gain the confidence and respect of the Trading community, since it has been trying to solve problems and genuine grievances of business community when they are in difficulties. The details of its Managing Committee and other details are shown in Annexure D. 5) Over 20,000 citizens of C & D Wards of Island City of Mumbai. These are people who are living in very old and dilapidated buildings in the C and D Municipal Wards of Mumbai. They came together and signed the petition on behalf of over 62,000 people staying in 1,110 dilapidated buildings in CRZ-II area of C & D Wards to be submitted to Ministry of Environment & Forest for removal / relaxing CRZ norms from C & D Wards. The signature drive was conducted under the umbrella of ROMF and CFCD during last one month and concluded in a massive public meeting of C, D & B ward citizens on 28th June, 2008 and well attended by dignitaries and leaders of Maharashtra State. advertisement are annexed herewith (Annexure E & F). The press cuttings of the Public Meetings invitation advertisement and thanks The details of its Managing

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The advertisement shows the supports of spiritual leader H.H. Sri Sri Ravishankerji and the states eminent political leaders like 1) Shri. Vilasrao Deshmukh, Chief Minister of Maharashtra 2) Shri. Sharad Pawar, Minister for Agricultural, Government of India 3) Shri. R. R. Patil, Deputy Chief Minister, Government of Maharashtra 4) Shri. Gopinath Munde, Vice President, BJP and other MLAs & ExMPs of the area of C, D & B Wards. DETAILS OF C & D WARDS AND HOW IT NEEDS REMOVAL /RELAXATION IN CRZ NORMS TO SAVE THE LIVES OF 62,000 CITIZENS Description of C & D Wards The C & D Wards of the Island City of Mumbai consist of some of the oldest areas of the city. These wards have been urbanized since the past 100 years. These wards accommodate a large population which is engaged in numerous economic activities. The area consists of mixed land use with commercial, residential and manufacturing activities being carried out in close quarters of each other. Buildings Almost ninety percent of the buildings in this ward are six decades to a century old and hence are in a very weak and in dilapidated condition. The C & D wards comprises of 22,000 cessed & noncessed dilapidated buildings housing nearly 2 lakh people. Many of these buildings are in a state of imminent collapse. These buildings have to be continuously given structural support to prevent them from falling. 90 percent of these buildings are constructed prior to 1940 and therefore much before the said CRZ Notification was issued, in 1991. Foundations of most buildings have settled, large cracks are visible and continuous water seepage. The condition of pg. 3

these buildings in the CRZ II area of C Ward is highly dangerous. Besides these buildings are very susceptible to earthquakes and natural disasters. Hence the redevelopment of these cessed buildings is imperative. Infrastructure The town planning in these wards is a century old and is crumbling and considerably strained with the additional load it has seen over the decades. The roads and lanes are very narrow creating perpetual traffic management problems. Since these areas house the oldest trading and commerce areas there is considerable flow during the day of business visitors which puts enormous strain on the movement of men and materials. The day time population in these wards is almost five times the night population; hence traffic & pedestrian movement is highly congested. Unhygienic Environment The sewage and garbage disposal systems in these wards have completely collapsed and only held together with temporary measures which have to be carried out frequently. During monsoons the sewage flow mixes with the rainfall and it creates conditions for the spread of many contagious and life threatening diseases. Mosquitoes, flies and disease bearing conditions lead to poor hygiene and illness. Thus considering the conditions of the C & D Wards as enumerated above there is a dire need to address the issue of creating new living and working conditions for the residents of the ward which ensures a better environment to live in.

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CRZ II AFFECTED AREA IN C & D WARDS Roughly 100 acres each are affected by CRZ II provisions in C & D Wards respectively. These 200 acres of C & D wards are in continuity and are located on after four stages of developments from Marine Drive sea coast. Four front levels are already developed by Netaji Subhash Road, various Gymkhanas & Buildings, Western Railway Line and the Queens Road respectively. The map & Google picture of C & D wards area with CRZ affected areas are annexed (Annexure G). REMAKING OF MUMBAI FEDERATIONS PROPOSAL TO THE

GOVERNMENT OF MAHARASHTRA In October 2005 Remaking of Mumbai Federation submitted a concept paper to the Government of Maharashtra suggesting the planned redevelopment of the 20,000 old dilapidated buildings in the island city of Mumbai. The people staying in these buildings live under the shadow of death. The ROMF proposal takes care on one hand of saving the lives of lakhs of people staying in over 20,000 unsafe buildings while on the other hand remaking Mumbai into a World Class City. The scheme is pivoted on redevelopment of the whole city on a self financing basis using land / FSI as leverage. The problems of Mumbai are due to awkward, haphazard and incremental growth rather than a integrated, planned and holistic planning process. Thus a scheme was suggested comprising of (a) Sectorial planning of whole city by a Jt. Venture Co., between Experts from public and various Government departments pertaining to Housing, Urban Development and Infrastructure on a PPP basis by forming a JV Co. i.e. CPMC - City Planning & Monitoring Co. (b) Development of each sector i.e. SSDS Sector by Sector Development on a self financing basis.

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GOVERNMENT OF MAHARASHTRAS URBAN RENEWAL SCHEME INVITES EXPRESSION OF INTEREST FOR PILOT PROJECT UNDER NEW HOUSING POLICY 2007 As per the New Housing Policy of Government of Maharashtra addressing cluster development on Joint Venture basis between tenants, landlords and developers the Government invited Expression of Interest for a Pilot Project for cluster development. The copy of EOI advertisement is as per Annexure H. REMAKING OF MUMBAI FEDERATIONS RESPONSE TO THE

GOVERNMENT OF MAHARASHTRAS EXPRESSION OF INTEREST BY SPECIAL PROJECT DEPARTMENT In response to the Government of Maharashtras EOI, ROMF submitted its plan for the cluster based development of the C Ward of Island City as per a Master Plan of Greater Mumbai. The proposal envisages demolition and reconstruction of 1,777 old and dilapidated buildings in C ward and rehabilitating around 1,00,000 tenants of residential, commercial and shopkeepers along with creation of matching infrastructure and ample open spaces to a standard of World Class City. The C Ward and adjacent D Wards comprises of 1,110 dilapidated buildings falling under CRZ II area and the proposal becomes unviable unless the CRZ norms are removed / relaxed in CRZ II area of C & D wards.

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CAUSES FOR NON-APPLICABILITY AS WELL AS FUTILITY OF CRZ II PROVISIONS TO C & D WARDS AND REASONING FOR REMOVAL OF CRZ II FROM C & D WARDS We, the inhabitants of C and D Wards of Bombay who are staying in the shadow of death in 1,110, most unsafe and dilapidated buildings of C & D Ward hereby make this petition to put forward the difficulties faced by us and appeal to the Ministry of Environment and Forest (MOEF) to consider the removal/ relaxation of CRZ II norms in the C and D Wards of Mumbai. 1. We are presently living in precarious old cess buildings, which are authorized structures of permanent nature, and most of which are more than 80 to 100 years old. 2. This area has been urbanized for more than a century. Between the HTL and the 200 meter line there is the a. Marine Drive Promenade b. 180 feet wide Netaji Subhaschandra Road c. Large cricket Maidans d. Four track arterial western railway line e. Maharishi Karve Road which is an arterial road f. After the 200 meter line is a parallel barrier strip of crematorium and burial ground of average 50-100 meter width. These features of urbanization have existed since more than a century in the current area and hence the area has been developed. The area is not covered with mangroves or does not display other features of coastal ecology which need preservation.

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3. This area does not have features of a coastline, like mangroves or sand dunes, which require protection. Thus the Ministry needs to apply the laws keeping the geographical context in mind and not as per a blanket policy of certain parameters from the High Tide Line. Most of the structures in this area are prior to 1991, i.e. before the enactment of the CRZ Act. 4. The residents of these buildings are paying cess to the government, and the same are authorized buildings and structures. C Ward is an area capable of development, which comes within the Municipal Corporation of Mumbai limits, having DP roads and reservations on all sides. 5. The areas of 'C' and 'D' ward have among the highest density in the world, and the inhabitants are living in miserable conditions, due to the outdated and crippled infrastructure and facilities. 6. Though our fundamental rights to life and right to shelter are guaranteed by the Constitution, we are unable to exercise the same in light of the existing regulations which force us to live in such debilitating conditions. There is an urgent and pressing need for providing adequate living space, safe and decent building structures, clean and decent surroundings, sufficient light, pure air and water, electricity, sanitation and other civic amenities like good roads, garbage disposal and treatment facilities, access to emergency response agencies etc. The Supreme Court has held that "The right to life would take within its sweep the Right to food, the Right to clothing, the Right to decent accommodation to live in. The annexed are the Supreme Court Judgments supporting right to life (see Annexure I).

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7. Your Ministry has time and again, in public interest, given considerable relaxation, by amending the principal notification of CRZ 1991 under section 3 of the Environment Protection Act, 1986 wherein rights and livelihood of fishermen and koliwadas were protected. However, the inhabitants of one of the oldest section of the city of Mumbai i.e 'C' and 'D' wards who are living here since more than a century have no protection for their homes and livelihood. The MoEF has been allowing the fresh developments and redevelopments on the sea-ward side on the principles of imaginary line. (see Annexure J). 8. We, the residents of the area belong to the middle class and cannot carry out the complete redevelopment of our buildings on our own. Under the current thinking of the Government of Maharashtra, it is mandated, that new units being built should be of a minimum of 300 sq.ft. In a number of cases our units consist of 100-150 sq.ft. While we cannot afford to redevelop the area, of our tenements with the current available FSI, redeveloping any additional area is out of question. 9. Hence we have to depend on outside developers to redevelop our buildings. The developers would redevelop our buildings, only if it is economically viable and would hence require an additional free sale component, to subsidize the complete reconstruction. 10. The Government of Maharashtra has realized that cluster

redevelopment is the only solution to the miserable condition of the inhabitants living in dilapidated cessed buildings and has vide its Expression of Interest dated Oct 11th, 2007 (see Annexure H) invited interested parties to submit their tenders for re-development of Mumbai city based on the cluster approach. The local town planning laws support redevelopment of buildings in the C and D Wards but this pg. 9

becomes unviable in the area of the Wards, which fall under CRZ II. The CRZ II provisions restrict the amount of FSI that can be permitted for new buildings (FSI of 2 or the amount already consumed) and also have height restrictions (buildings cannot be higher than 9.75 meters and 21 meters). Most of the buildings in the aforementioned area have already consumed an FSI of nearly 3. 11. The roads are narrow and winding, and there is perpetual heavy traffic flow in the area, as it houses some of the city's busiest commercial establishments. None of the buildings have a compound and there is hardly any open space or greenery in this entire area. Being one of the oldest areas in Bombay, this area now dons a decaying look. Consequently, it is essential in the interest of preserving the fabric and health of the people living in those areas and society as a whole, to relax the F.S.I norms for development of cessed and noncessed buildings in the C and D Wards of Mumbai city which predominantly falls within the CRZ II area. 12. If the Government were, on the other hand, to develop areas having no accessibility and having no actual scheme of planning, and redevelop them, into areas having taller structures, as opposed to wider structures, it would as a result relieve most of the land, by releasing locked spaces and creating open spaces. Such spaces can then be used for developing parks, sanctuaries or gardens, whereby a far greater purpose would be served. 13. The entire purpose of the CRZ Regulations is to maintain the ecological balance and attempt to preserve ecosystems. What the CRZ Regulations, does not take into account, though, is the fact that in the C and D wards of the Island City of Mumbai, there is already a gross

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destruction of the ecosystem, and most areas are completely devoid of greenery and open spaces. 14. Freezing the structure of cities, most of which have already become over-burdened and cluttered, would actually be more harmful than beneficial, for all environmental purposes, and for the purposes of planning. 15. The Governments Urban Renewal Scheme, would, in effect, become toothless, if the CRZ Norms are allowed to continue regardless of the ground reality. Presently, all areas coming within CRZ II would only be allowed to be re-developed, as long as they dont come within the seaward side, and as long as they are governed by height and distance restrictions. Since re-development, of the manner proposed, wherein emphasis is being laid on open spaces and better world class infrastructure, would require buildings having a height far greater than what is currently permitted, the CRZ would serve as a great impediment in the execution of an idea of such a magnitude. 16. The structures in the C and D wards lack basic infrastructure and amenities, like sanitation, garbage disposal, proper sewage, proper access to light and air; and access to and by emergency services like Fire Brigades, Ambulances etc. The scheme of re-development proposed by Remaking of Mumbai Federation, addresses all these issues, and deals with them, more holistically. The scheme as proposed also takes care of the environment, as it provides for green and open areas, sewage and garbage disposal and treatment which at present is lacking. 17. As of now, the scheme is for the redevelopment of the C Ward, having an area of 212 acres. Once the nature of the redevelopment is approved by the Government of Maharashtra, the whole of Mumbai pg. 11

would be developed, keeping the scheme in mind. In the large scheme of things, water bodies, parks and open spaces would be created. Also, by creating far greater infrastructure, the government could create a system of mass-transport, wherein the dependency on private vehicles, and fossil fuels would be greatly reduced. 18. Another thing that the Government has not been able to address, because of the CRZ regulations is the fact that there is a genuine crisis situation, wherein many of these structures are in a state of caving in, and sooner than later, if not addressed appropriately, the situation is going to go out of hand. There have been many incidents of inhabitants dying, due to the collapsing of buildings. The buildings have outlived their normal life and doing continuous repairs is costly and not a lasting solution. Repairs can only be cosmetic in nature and do not address cracks in load bearing walls and settled foundations. There are many buildings built by MHADA, which are in urgent requirement of re-construction. There have been many incidents where persons have died due to the collapse of such buildings. Though MHADA is making all efforts to re-locate people staying within such structures, and redevelop them, the entire process is a bit-by-bit process, where the entire exercise could take between ten and thirty years. 19. The MOEF has over the years considered relaxation for deserving cases as is borne out by the numerous amendments carried out from time to time. The relaxation given to fishermen and Koliwadas should be extended to the residents of C Ward who are also the original Mumbaikars, and who have been residing in this area for more than a century. 20. We again submit that in September 1997, the Chief Secretary of Maharashtra wrote to the Central Government's Ministry of

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Environment and Forest (MOEF) explaining the practical difficulties in implementing the CRZ II norms in a growing metropolis like Mumbai, especially since it had large slum population. He asked the MOEF, in view of Mumbais new slum rehabilitation scheme, to consider slums as authorized structures and therefore to consider slum redevelopment as the reconstruction of authorized structures. However, MOEF, in a letter issued in September 1998, did not approve either of these suggestions. The MOEF clearly stated that slums is not an authorized structure and that the existing norms meant those norms that existed prior before 1991. It said: " it is clarified that the phrase " Existing Authorised Buildings" means those of buildings of permanent nature that were existing before 19th Feb, 1991 and were constructed in accordance with building regulations and byelaws in vogue previous to 19.2.1991 and received necessary sanctions, including commencement certificate and occupation certificate from the

concerned local authority prior to 1991. Subsequently the Government of Maharashtra informed all concerned local authorities to adhere to this clarification. Considering our case, where thousands of authorized cessed buildings are in dilapidated conditions, we are the most eligible for relaxation of CRZ II norms for C and D ward. 21. The non-CRZ areas of the C and D wards have a higher permissible FSI and hence residents of old buildings have been finding it easier to go in for redevelopment. There is a new proposal of having a planned redevelopment of the whole ward as per a cluster approach which would enable provision of much needed infrastructure like wider roads, new and better sewage and water facilities and open spaces. Under this provision too there may be additional benefits which will not come to us since we fall in the CRZ II belt. Please find attached in (see Annexure H) the EOI of Government of Maharashtra. pg. 13

22. Most of the buildings in this ward are small and cramped. There is hardly any space between the buildings. Even the lanes and by-lanes in the area are cluttered and in case of emergency, the emergency response agencies are unable to access the area. This area has a mix of both residential and commercial tenements. Therefore, in public interest, the MOEF needs to relax the provisions of CRZ II in the C Ward area in respect of cessed structures at par with Non-CRZ cessed structures. ADVANTAGES BY REMOVAL / RELAXATION OF CRZ II FROM C & D WARDS 1. Saving the lives of 62,000 people If the CRZ II provisions are removed / relaxed the residents living in miserable living conditions will find themselves being able to live in well built and safe buildings in the redevelopment which will become possible. 2. Creation of Infrastructure and improving the Quality of Life New infrastructure will substantially improve the quality of life of the residents in the form of wider roads, drainage, sewage, water, gas and electricity can be provided. This will substantially improve the socioeconomic profile of the area. 3. Creation of Open Spaces & Amenities As per planning norms there should be an average of 4-5 acres of open spaces per thousand persons. As opposed to that the C&D wards have almost zero acres of open spaces. Relaxation in CRZ provisions will enable the creation of open spaces and play areas and other social infrastructure like schools, Hospitals, libraries etc. pg. 14

4. Financial viability The C & D wards have buildings which have currently consumed nearly 3-4 FSI and the average tenement size is 100 - 150 sft. The State Governments current thinking mandates a minimum size of 300 sft. In any new redevelopment. The CRZ II provisions which cap the FSI at 2 or the one currently consumed makes the redevelopment of the buildings and provision of new infrastructure completely financially unviable. CONSIDERING THE ABOVE during the month of June we have carried out a door to door signature campaign by reaching out to the residents of the C and D Wards. Teams of citizen volunteers collected a total of 20,102 signatures (summary in Annexure L). We herewith along with this petition are attaching photocopies of the collected signatures. These we are submitting as spiral bound books numbering 40. We have also submitted our objection to the CMZ notification and please find attached the copy of our letter as per Annexure K.

OUR PRAYER: In view of the above our Prayer to you is as under: Relax CRZ II norms for C ward and D wards of Island city of Mumbai for the pilot project under urban renewal scheme as invited under Expression of Interest offer by Special Project Department of the Government of Maharashtra in the following manner: (a) Unsafe buildings in CRZ II area under Urban renewal Scheme of Pilot Project should have the same entitlements of FSI norms for development as other cessed buildings in non-CRZ area. pg. 15

(b) That amalgamation of plots should be permitted: Since the entire area of the C ward & adjacent D ward would be developed as a pilot project, the entire area would be developed, as a whole, and the land-use pattern would be distributed among the entire areas of C & D ward under Pilot Project proposal. (c) That development of new roads on landward side and building activities as well the infrastructure should be permitted. (d) Height restriction has to be removed to accommodate vertical high rise buildings. We are hopeful that the government will look favourably at our submissions and listen to our petition in humanitarian interest and do the needful. We also look forward to meeting the officials of the MOEF in person and explaining our condition. Yours sincerely, For Remaking of Mumbai Federation

Lalit Gandhi Chairman

Girish Gokhale Vice President

Mayank Gandhi Secretary

For CFCD

For OLWA

For FAM

Vishwas Mhambrey President

Viren Ranjitsinh Kapadia President

Muhammadali Patel General Secretary pg. 16

ATTACHED AS UNDER: Annexure Annexure A - Details of ROMF Annexure B - Details of CFCD Annexure C - Details of OLWA Annexure D - Details of FAM Annexure E - Details of Meeting Advertisement Annexure F - Details of Thanks Advertisement Annexure G - Maps and pictures showing the area Annexure H - Government of Maharashtra, newspaper notice inviting Expression of Interest for Urban Renewal Scheme Annexure I - Supreme Court pronouncements supporting Right to Life Annexure J a. MoEF letter contents, Dt: March 1998. b. Bombay High Court observations on Imaginary lines Annexure K - ROMF response to CMZ Notification Annexure L - Summary of Signatures collected during Campaign

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Annexure A Introduction Remaking of Mumbai Federation was formed for the mission of saving the lives of lakhs of people living in old and dilapidated buildings, while learning from the global practices of redeveloped countries and cities like Singapore, Shanghai, Hong Kong and similar to create a World Class Mumbai. A concept line paper was submitted on October 2005, triggered by the collapse of buildings due to the 25th July 2005 floods, to the Chief Minister of Maharashtra for a cluster based approach on a Sector by Sector Development Scheme (SSDS) as per integrated and holistic planning by a City Planning and Monitoring Company (CPMC) based on a Public Private Partnership basis. The creation of the federation consisting of over 50 associations, institutes, NGOs and chambers of stakeholders was preceded by intense discussions and crystallization leading to the final proposal with C Ward development being applied as a Pilot Project for the government of Maharashtras Expression of Interest for Urban Renewal Scheme. Some of the eminent dignitaries who are part of the mission are mentioned on the left hand column.

The objectives of the Federation are A. To create a campaign that would enable Protection to lives of lakhs of people living in thousands of most old, unsafe and dilapidated cessed and non-cessed tenanted society buildings all around Greater Mumbai more particularly in South Mumbai by demolition and reconstruction of such buildings. Creation of Infrastructure Funds for putting in implementation the JNNURM norms for Urban Renewal at Mumbai by upgrading and augmenting the infrastructure facilities like road, bridges, drainage and water supply network to cope up with the enhanced load of population owing to increase of constructed area. Creation of Mass Housing Stock utilizing large unused land in the city. Formation of a Single Planning, Regulatory decision making body on a Public Private Partnership (PPP) basis i. e. a SPV on JV Corporate Co. between Government and Private Parties. Improvement in quality of life in the Megacity of Mumbai. Creation of job opportunities and growth. Bringing together all concerned under the umbrella of Remaking of Mumbai Federation. Protection of the rights and interest of the poor and middle class residents affected by the development activities. B. To campaign for the collective objectives of the housing sector by using study, research, advocacy with the authorities, mass mobilization and / or use of judicial intervention to achieve the goals. C. To form a corporate body with / or without partnership with other entities for achieving the goals.

D.

To enter into agreements with various entities, including the government for furtherance of the goals of the campaign.

E.

To act as consultants, advisors on all mattes related to the housing and infrastructure sectors at appropriate levels.

F.

To enroll members, receive membership fees and / or any other fees / charges, operate bank accounts, keep accounts, and appoint any employees or persons as may be required from time to time for the purpose of discharging the main objects of the Federation.

G.

To make available services of the Federation to other entities in the manner deemed fit by the Associations.

H.

As a result of fulfillment of all above objectives to articulate and put in to implementation a time bound action plan to remake Mumbai a world class city.

I.

To take up all such works for the purpose of improving life of residents of Mumbai.

ANNEXURE B

Brief Introduction of CFCD

A group of active citizens, who have been working for the benefit of society and our area for the past many years, saw a series of presentations of Remaking of Mumbai Federation for redeveloping CWard to a World Class City decided to form a Citizen Forum with an agenda to constructively work in partnership with the Federation for changing the lives of our families and children. The forum represents the tenants, landlords, shopkeepers, traders, laborers, workers, hawkers and artisans of C3 and C4 part of C Ward. The Forum Managing Committee consists of eminent people of the area from various fields and representing all sections of society.

The Street Committee consists of representatives from all the 129 streets of C3 and C4 who have been working in their locality for social and cultural causes and who have an excellent standing in their respective areas. Please find attached a list of the street representatives.

Annexure - B CFCD MEMBERS


No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Name Harshad Vakharia Narendra Thakur Georgi Saha Rakesh Jain Lalit Jain Siddhraj Lodha Pravin Dhoka Bal Govind Dubey Radhika Prasad Dubey N.N. Bhabhada Jitendra Jain Mohan Purohit Alpesh Soni Shivji Jhawar Nathulal Chaurasiya Manoj Shah Ketan Shah Amratlal Purohit Jasraj Rawal Jaisingh Sawant Kadar Shivani Hariom Chaurasiya Dinesh Kapadia Dilip Shah Nilesh Doshi Hitesh Shah Tushar Sampat Narendra Damodar Bhawsar Manubhai Pandya Sanjay Mehta Kapil Doshi C.A. Street Name Tambakanta Mumbadevi Compound Dhanji Street Dagina Bazar Zaveri Bazar Vithalwadi Vithalwadi - 2 Champa Galli Champa Galli Cross Lane Vithoba Lane Oval Wadi Shekhadi Lane Narnarayanwadi Old Hanuman 1st Cross Old Hanuman Lane Old Hanuman Lane Shamseth Street Mirza Street Sutar Chawl Kashinath Chawl Pinjara Street Mangaldas Road Kitchen Garden Lane Kantilal Sharma Marg Kantilal Sharma Marg - Lohar Chawl Shamaldas Gandhi Marg Vithaldas Road Pathakwadi New Hanuman Lane New Hanuman Lane - Kalbadevi Road Vasant wadi-O & Cavel X Lane No. 2 R Phone No. 93205 44027 93236 09141 / 93241 22004 93222 39895 2242 5691 98690 00288 93245 94095 98210 99645 98192 34417 98330 36054 98223 32581 98693 88892 98690 12913 98203 69626 98201 01698 93244 94198 98200 65595 / 2240 9153 98212 32902 98928 27107 / 98693 94190 98208 20564 93222 36554 92241 45374 98664 60004 93222 40383 98211 66458 98201 35054 98200 45306 98210 29201 98336 26854 98197 93739 93212 47533 98673 74160 / 2201 9650-R 22087504 98692 86655 98205 33467 98690 85545 93240 86435 98212 15772 98205 63910 98217 87889 98195 89248 98216 79699 98219 84717 98213 30010 98214 07650 98691 69798 2208 8289 99208 59109 / 6501 2470 - R 98195 84709 2209 4683 98200 17352 98691 20655 98920 70220 98673 05604 98206 63497

Premshankar Pandey Joshiwadi Sunil Amre Girdhari Purohit Rakesh Ashar Madan Sharma Narayan Chogle Gopal Das Mahavir Sharma C.M. Farid Aslam Shaikh Santosh Shinde Cyrus Irani Tanaj Kerawala Pankaj Parmar Nicholas Fernandes Hasumati Saraiya Alpesh Rathod Jayshree Patel Dr. Ramnik Bakshi Hirachand Jain Mehboob Khan Naresh Khorava Jude Gomes Picket Road / R.S. Sapre Picket Road Ext. Geeta Gruha L.T. Road Takwadi Jambhulwadi Bomanji Master road Dhobi Talao 1st Dhobi Talao 2nd Hamalwadi Bhiwandiwala Terrace Dr. C.H. Street Princess Street Dadi Santok Lane (Dhobi Talao) Sorabjee Santok Lane Trinity Street 4th Marine Street 3rd Marine Street 2nd Marine Street 1st Marine Street Anandilal Podar Marg BIT Chawl 1, Chandan Wadi

No. 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113

Name Rajesh Gamre Narendra Gohil Sunil Desai Sanjay Bhosle Ramesh Gohil Hemant Hodar Dr. Mangala Meghraj Mugdha Trilokekar Deepika Thapania Chandrakala Chaoudhary Hemant Maher Vyagnesh Motivaras Vinayak Sangodkar Pravin Khorawa Arun Hodar Milind Vaingankar Prakash Jain Kirit D. Shah Lalitaben Panchmatia Vishwas Mhambrey Subodh Madan Shyam Sapre Savio D'Souza Shirish Mhambrey Sampat Thakur Vishwas Surve Arvind Pitkar Advocate - Trupti Puranik Nilima Kashelkar Manoj Jain Hemant Shah Ashok Botre Subhash Kalugade Prakash Joshi Madhav Moghe Puran Dave Sharad Vichare Bindu Oza Kumar Mankar Shilpa Ganpatye Kanak Parmar Jyotsana Chandratre Arun Morsawala Prerana Sirohiya Lezarus Mendis Subhash Harlalka H.S. Nagi Dilip Karandekar Tulsi Purohit

Street Name BIT Chawl 2, Chandan Wadi BIT Chawl 3, Chandan Wadi BIT Chawl 4, Chandan Wadi BIT Chawl 5, Chandan Wadi BIT Chawl 6, Chandan Wadi Chandanwadi - Gavliwadi Chandanwadi - Rupa Lane Shrikant Palekar X Lane Shrikant Palekar 2nd Cross Lane Samata Compound Dadi Santook Lane (Chira Bazar) Borichi Chawl Mahadev Shankar Seth Lane Shrikant Palekar 1st Cross Lane Shrikant Palekar Main Lane Tadwadi (R.S. Navalkar Marg) Vijaywadi Gazdar Street Shankar Bari Lane Shankarseth Compound Baroj Lane Gangaram Khatriwadi / Waghlewadi Nawroji Street Bhai Jivanji Lane Denawadi Kamat Chawl Hemrajwadi Karelwadi Dhobiwadi Thakurdwar Road Jawahar Mansion Anandwadi (Jalamsingh Compound) Kapreshwar Marg Gorakshawadi Jagannath Chawl 1,2,3 Sitaram Podar Marg 1st Fanaswadi 2nd Fanaswadi Naviwadi Zaobawadi 1 Zaobawadi 2 Dhuswadi Chirabazar Main Road - Thakurdwar Chirabazar Main Road - Chira Bazar Chirabazar Main Road - Chandanwadi Dadi Seth Agiary Lane Dadi Seth Agiary Lane Dr. Viegas Street Dabholkarwadi

Phone No. 98331 59571 98212 56885 99872 63832 99696 44891 98926 22847 98673 81727 98211 35529 99690 83835 92247 00098 / 2207 0072 93228 76207 98690 41502 98208 79232 93228 76207 98196 57761 98692 88 279 98925 20616 98924 37243 98193 49975 98205 73073 98191 35437 99204 03790 / 2385 5741 - O 98197 29413 2206 1947 2205 9330 / 98205 05120 98213 05232 98213 91959 99870 83421 / 2209 4727 98693 38950 / 2205 6517 2209 5152 99693 01035 93210 58475 / 2205 8475 - R 98691 07201 92217 81898 98190 23520 98199 51046 98692 53813 98920 98423 93207 35599 98200 25612 98690 24925 98191 40110 2207 0880 / 93231 84776 98190 52869 2200 3009 98334 38947 93242 49288 / 2241 0349 98690 88489 93228 72225 98697 34562 98696 05515 93240 38707 98207 09133 98690 00233 98339 69971 98196 33980 98213 37906 93222 16131 98204 67410 98925 60294

Surendra Chaurasiya Cavel 1 Vijay Sarda Chandrakant Parmani Ramesh Purohit Shailesh Patel Ashish Dave Tamanna Vyas Uday Sampat Kishor Chudasama Mahendra Romani Cavel 2 Cavel 3 Cavel 4 Cavel 5 Cavel 6 Cavel 7 Cavel 7 Cavel 8 Cavel 9

No. 114 115 116 117 118 119 120 121 122 123 124 125 126 127

Name Manish Surve Deepak Rao Bharat Trivedi Shashikant Amre Mulsingh Purohit Rahul Vayda Chhaganraj Purohit Ashok Dave Mahesh Pancholi Ashwin Seth Bipin Shah Sabir Patanwala Ashok Sakharia Nirvan Goradia

Street Name Cavel 10 Dr. M.B. Velkar Street Chewool Wadi Sadguru Kadam Baba Lane Vanka Mohalla New Bhatia Mahajan Wadi Narottamwadi Badam Wadi Swadeshi Market Popatwadi Bhagwadi Bori Masjid Street (Shaikh Memon St.) Ganesh Wadi M.J. Mkt.

Phone No. 98921 42828 98336 77899 98212 88945 98926 37091 / 99694 06906 / 2209 6915 - O 98203 63439 98199 08142 2207 9386 93240 22059 3290 3136 98693 47408 / 2207 7892 - R 98210 50064 98190 61752 93245 45276 93244 58810

ANNEXURE C OLWA, Old Buildings Landlords Welfare Association, is an Association for the cause of the dilapidated buildings Landlords in Mumbai, who are suffering from various laws imposed under Bombay Rent Control Act. The association is working towards getting correct value of the building in favour of the landlords while seeking their co operation, to enable remaking of Mumbai possible. The cessed buildings have been categorized as below: a) Dangerously dilapidated buildings that have been repaired 30 to 40 years back and cannot be repaired any more. b) Buildings that were repaired more than 10 to 15 years back but would again need extensive repair in the next 3 to 5 years. c) Cessed buildings maintained by landlords till date but cannot be afforded to be maintained in future. Such buildings also come up for repairs in the next 3 to 5 years. Please find attached a list of the Managing Committee

OLD BUILDINGS LANDLORDS WELFARE ASSOCIATION (OLWA) Sr. No. 1 2 3 4 5 6 7 8 9 10 Designation President Secretary Treasurer Member Member Member Member Member Member Member

Name Shri Viren Ranjitsinh Kapadia Shri Krishna Devidas Sampat Shri Kirtikumar Jamnadas Ved Shri Atul Ranjitsinh Kapadia Shri Tushar Ranjitsinh Kapadia Shri Dhruv Atul Kapadia Smt. Ila Viren Kapadia Smt. Hemini Atul Kapadia Shri Jitu Viren Kapadia Miss Shivani V. Kapadia

ANNEXURE D

Brief Introduction of FAM

FEDERATION OF ASSOCIATIONS OF MAHARASHTRA is an apex body representing more than 750 associations/chambers of Trade, Transport and Small Scale Industries from all over Maharashtra. This year FAM is celebrating its Silver Jubilee Year. During these 25 years Federation has been able to gain confidence and respect of the Trading community, since it has been trying to solve problems and genuine grievances of business community when they are in difficulties. Since the formation of Federation, the business community of Maharashtra comprising of trade, transport and small-scale industries have looked upon this Federation as their own organization to which they could look for help whenever they are in difficulties.

Inception of FAM

In the year 1979 when the Government of Maharashtra came down heavily by way of draconian amendments to the Sales tax Act, the business community all over Maharashtra organized themselves and through terrific show of unity protested against the draconian amendments with the result that the Government of Maharashtra had to take back a legislation which was passed in both houses of the Maharashtra legislature and assented to by the President of India. At that time a huge convention of more than 1,25,000 traders was held at Bandra Reclamation ground in Mumbai on 25th May, 1979.

ANNEXURE - G

ANNEXURE - G
Appx. details of Buildings in CRZ area

C WARD & CRZ II


No. of Buildings Appx. Population 685 40, 000

No. of Tenements 8,678 Resi 6,684 (40,000) non- Resi- 1,994

D WARD & CRZ II


No. of Buildings Appx. Population 425 22, 000

Site

ANNEXURE - G

C & D WARD & CRZ II


No. of Buildings Appx. Population 1,110 62, 000

ANNEXURE - G

CRZ & Site boundary

Site

ANNEXURE - G

ANNEXURE - H

Annexure - I SUPREME COURT JUDGEMENTS SUPPORTING RIGHT TO LIFE Upholding the importance of the right to a decent environment and a reasonable accommodation, in Shantistar Builders v. Narayan Khimalal Totame (1990) 1 SCC 520: AIR 1990 SC 630 the Court held that, "The right to life would take within its sweep the right to food, the right to clothing, the right to decent environment and a reasonable accommodation to live in. The difference between the need of an animal and a human being for shelter has to be kept in view. For the animal it is the bare protection of the body, for a human being it has to be a suitable accommodation which would allow him to grow in every aspect - physical, mental and intellectual. The Constitution aims at ensuring fuller development of every child. That would be possible only if the child is in a proper home. It is not necessary that every citizen must be ensured of living in a well-built comfortable house but a reasonable home particularly for people in India can even be mud-built thatched house or a mud-built fireproof accommodation," Maintaining that right to shelter is a part of right to life under Article 21 of the constitution and getting the basic amenities and infrastructure is vital to lead an important life. In Ahmedabad Municipal Corporation, Appellant V. Nawab Khan Gulab Khan and Others, the Supreme Court observed that, "Article 19(1) (e) accords right to residence and settlement in any part of India as a fundamental right. Right to life has been assured as a basic human right under Article 21 of the Constitution of India. Article 25(1) of the Universal Declaration of Human Rights declares that everyone has the right to a standard of living adequate for the health and well-being of himself and his family; it includes food, clothing, housing, medical care and necessary social services. Article 11(1) of the International Covenant on Economic, pg. 1

Social and Cultural Rights lays down that State parties to the Covenant recognise that everyone has the right to standard of living for himself and his family including food, clothing, housing and to the continuous improvement of living conditions." The objective of all laws on environment should be to create harmony between the two since neither one can be sacrificed at the altar of the other. This view was also taken by this Court in Indian Council for Enviro-Legal Action v. Union of India (1093) 5 SCC 281, 296 where it was said: "while economic development should not be allowed to take place at the cost of ecology or by causing wide spread environment destruction and violation, at the same time the necessity to preserve ecology and environment should not hamper economic and other developments. Both development and environment must go hand in hand, in other words, there should not he development at the cost of environment and vice versa but there should be development while taking due care and ensuring the protection of environment". In Chameli Singh v. State of U. P [(1996) 25CC549 132] a Bench of three Judges of this Court had considered and held that the right ro shelter is a fundamental right available to every citizen and it was read into Article 21 of the Constitution of India as encompassing within its ambit, the righty to shelter to make the right to life more meaningful. In para 8 it has been held thus: (SCC pp. 555-56) "In any organised society, right to live as a human being is not ensured by meeting only the animal needs of man. It is secured only when he is assured of all facilities to develop himself and is freed from restrictions which inhibit his growth. All human rights are designed to achieve this object. Right to live guaranteed in any civilised society implies the right to food, water, decent environment, education, medical care and shelter. pg. 2

These are basic human rights known to any civilised society. All civil, political, social and cultural rights enshrined in the Universal Declaration of Human Rights and Convention or under the Constitution of India cannot be exercised without these basic human rights." Emphasizing further on the right to shelter, the Court in this case held that, "Shelter for human being, therefore, is not a mere protection of his life and limb. It is home where he has opportunities to grow physically, mentally, intellectually and spiritually. Right to Shelter, therefore, includes adequate living space, safe and decent structure, clean and decent surroundings, sufficient light, pure air and water, electricity, sanitation and other civic amenities like roads etc. so as to have easy access to his daily avocation. The right to shelter, therefore, does not mean a mere right to a roof over one's head but right to all the infrastructure necessary to enable them to live and develop as a human being. Right to Shelter when used as an essential requisite to the right to live should be deemed to have been guaranteed as a fundamental right. The ultimate object of making a man equipped with a right to dignity of person and equality of status is to enable him to develop himself into a cultured being. Want of decent residence, therefore, frustrates the very object of the constitutional animation of right to equality, economic justice, fundamental right to residence, dignity of person and right to live itself."

pg. 3

ANNEXURE J a. MoEF letter contents, Dt: March 1998 On 27th March, 1998 MOEF in a clarificatory communication to the Chief Secretary of Government of Maharashtra inter alia stated that in areas categories as CRZ II, construction of buildings can be permitted on the landward side of the imaginary line drawn along the existing authorised structures. On 8th September, 1998, this was followed by a further clarification by MOEF in regard to the manner in which imaginary line should be drawn. The clarification was in following terms: "Construction of new buildings/reconstruction/expansion of existing authorised structures shall not be permitted in the seaward side direction in the CRZ II area of Mumbai Municipal Corporation, unless the following conditions are satisfied: 1. The CRZ II area should be within the territorial jurisdiction of the Mumbai Municipal Corporation as it existed on 19-2-1991, i.e. the date of coming into effect of the Coastal Zone Notification, 1991. 2. This construction/protrusion towards the seaside should not go beyond the imaginary line drawn from the seaward side of the existing authorized structures on the adjoining plot. 3. The imaginary line will be parallel to the High Tide Line. 4. The building (s) to be constructed will be restricted to the single plot (plot boundary as on 19-2-1991) immediately abutting/adjoining the existing authorized structures between which the imaginary line is drawn.

5. The Imaginary line to be drawn should not cut across any river, creek, backwater, estuary, water body, sandy beach or mangroves. 6. In case of reconstruction, change in the existing use of the building shall not be permitted. Further any permissible extension of the plinth in seaward direction vis a vis the existing plinth limits will be governed by the stipulation mentioned in the above paragraphs." (Please refer the aforesaid to Bombay High Court Case- PIL Writ Petition No. 2163, decided on 1-4/ 10-4-2003) 2003 (5) Bom. C.R. 95 (OS) Before Thakker C.K., CJ & Dr. Chandrachud D.Y., J. b. High court Observations on Imaginary Line In the case of Breach Candy Residents Association & others VS Municipal Corporation of Greater Mumbai & others PIL No. 68 of 2006 decided on December 7, 2006, the Bombay High Court held, Regarding the alleged violation of CRZ 1991, it will be seen that there is a structure behind the plot in question and if a imaginary line is drawn, then the construction in question is inside the imaginary line and therefore, Prima facie it cannot be said that there is a violation of CRZ." (Coram: H.S. Bedi, C.J., & V.M. Kanade, J.). This was the case on a CRZ II plot which was situated on seaward side of Bhulabhai Desai Road and near junction of Bhulabhai Desai Road and Gamadia Road

& Citizens Forum for C Ward Development (CFCD)


ANNEXURE K To Secretary to Government of India Ministry of Environment & Forest Pariyavaran Bhavan New Delhi Re.: Raising objections for implementation of the Notification as regards CMZ (Coastal Management Zone) by Government of India. 3rd July 2008

Dear Sir, We would like to place on record the views of our Federation i. e. Remaking of Mumbai Federation (ROMF) and those of our co-petitioner as regards the draft Coastal Management Zone notification issued by the Ministry, dated 1st May,2008. Both organisations i. e. ROMF & CFCD hereby strongly register their objections to MOEF regarding implementation of CMZ by Government of India for the following reasons. We wish to give you a short background regarding ourselves. Remaking of Mumbai Federation was formed with the mission of saving the lives of hundreds of thousands of people staying in the shadow of death in nearly 20,000 old and dilapidated buildings in the island city of Mumbai while leveraging land in a self financing mode to create win-win solution for all stakeholders on its way to create a World Class city. Citizens forum for C Ward Development is a large group of eminent citizens of C ward who have come together to work constructively for the redevelopment of its ward and is represented by a managing committee and a mohalla committee consisting of representatives of each of the 129 mohallas. Government of Maharashtra in their new Housing Policy has encouraged reconstruction of dilapidated buildings through a cluster development approach on a Joint Venture basis between Tenants/Landlords/Developer & Government and accordingly they have also invited the Expression of Interest for development of a Pilot Project in Urban Renewal provisions as per the Government of Maharashtras Housing Policy. RoMF had accordingly submitted their proposal for the development of `C Ward which comprised of 212 acres of area and having 2202 buildings out of which 1777 are cessed, old and dilapidated buildings having nearly 40000 tenements and population of around 1,00,000 people. `D ward is an adjacent ward having further buildings and tenants. .. 2

& (CFCD)
.. 2 .. C and D municipal wards of the island city of Mumbai have been urbanized since over a century and the buildings are in dangerous conditions with settling of foundations and cracks. There have been building collapses and deaths before and thus fear of collapse and death is stalking the residents. In the C Ward (C3 and C4 parts) approximately 86 acres and in the D ward approximately 60 acres consisting of 1110 old and dangerous buildings and over 62000 residents falls within 500 meters of the High Tide Line defined by the Marine Drive Promenade. Hence these areas are governed by the CRZ II provision of the Coastal Regulation Zone Act (1991). The CRZ II restrictions make the redevelopment of these buildings completely unviable. Now the Ministry has introduced the CMZ notification for public discussion. We observe the following about the CMZ notification: 1. There is no mechanism of transparency, accountability and participation when drawing up the setback line. This has made CMZ notification ambiguous. The Setback line is not defined in the CMZ notification. The setback is a concept for which the scientific methodology is not clarified and instead only some basic parameters are listed. This line is supposed to be based on the concept of vulnerability including both natural and man-made hazards. However, only 4 parameters (elevation, geomorphology, sea level trends, and horizontal shoreline displacement) are listed for this. All the parameters of vulnerability only relate to natural hazards and nothing is actually mentioned about manmade hazards. The CMZ notification provides Integrated Coastal Zone Management Plan' as an authority to determine the vulnerability. However, the role and functions have not been defined. The ICZMP has no deadline for completion. All clear restrictions are now replaced by broad and obscure guidelines incomprehensible to common coastal and fisher people largest stakeholders and custodians of our coastal resources making it more difficult for them to intervene or play a role here. The concept of a setback line makes it difficult for us to understand as to whether the areas of the C Ward which are currently governed by the CRZ II provisions would still continue to be governed under the new CMZ notification or not. The CMZ II categorization mentions that The activities proposed on the seaward side of the setback line in the above boundaries shall be regulated to ensure that no further development takes place other than foreshore requiring activities and basic infrastructure. a. Additionally the notification says that The development on the landward side of the setback line shall be as per the local town and country planning rules as existed on the day of this notification. We feel this will be detrimental for the local authorities in carrying out any future changes in rules which would be necessary for meeting the changing requirements of the residents of the ward for the better quality of their life. Accordingly we feel that this point should be removed from the notification. .. 3

2.

3.

& (CFCD)
.. 3 .. b. While some criteria are mentioned to define the setback line and we feel that using the said criteria the setback line be established such that it does not impact the redevelopment of the old and dilapidated buildings we can still not be certain of the same since the detailed application of the criteria would be time consuming. c. Thus the concept of a setback line is confusing and vague and has the potential of being used discretionarily. The concepts being ambiguous and non-specific it is difficult for us to judge its impact on the C and D ward residents and make specific objections. 4. In the context of an urban area like C and D ward it has to be understood that the number of livelihoods and vocations followed by people is much more diverse than just fishing. Mumbai generates a vast chunk of the countrys GDP and most of it is in the services, business and manufacturing sectors. The future development and the infrastructural and housing and other real estate needs of the city are thus extremely important for the development of the city and in return of the country. Any law which restricts this would be detrimental to progress.

Hence while raising strong objections against implementation of the said CMZ Bill, we suggest that the Ministry should first undertake the exercise of establishing the setback lines and subsequently discussion can be engaged in to discuss the beneficial and detrimental aspects of the CMZ notification. You are requested to kindly call us and give an appointment for discussion on the above raised objections so that our both organisations representatives can discuss with you in detail as regards objections raised. Yours sincerely, For Remaking of Mumbai Federation Sd/Lalit Gandhi Chairman For Citizens Forum for C Ward Development Sd/Vishwas Mhambrey President

ANNEXURE - L

CRZ removal/relaxation Signatures Campaign June & July 2008


In C and D ward of Mumbai (summary)
S.No. Cluster No. Existing No.of Buildings No. of Buildings Covered No.of Signatures 7/9/2008 No. of Sheets

17 12 9 9 22 22 20 20 18 18 49 29 10 7 39 37 13 8 23 23 19 16 15 9 47 47 6 2 14 9 20 10 11 10 28 28 31 5 20 6 52 25 37 21 60 20 6 3 10 9 25 17 6 5 16 16 8 8 22 22 19 19 13 13 35 33 D Ward Public Meeting Signatures GRAND TOTAL TOTAL BOOKS- 40 Campaign conducted by

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34-39 40

1 2 3 4 5 6 7 8 12 13 14 15 16 55 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125

764 228 323 821 194 1021 116 528 723 529 621 232 948 19 241 274 135 284 71 215 321 264 207 40 204 113 39 1861 157 456 623 383 1943 5291 913

39 13 26 50 11 53 6 43 37 33 38 17 65 2 15 18 13 30 7 14 31 24 19 4 16 18 5 100 12 23 41 23 92 250 50

20,102

1238

RoMF

CFCD

FAM

OLWA

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