To,

Commissioner cum- Secretary

Delhi Development Authority
B Block
Vikas Sadan
New Delhi -110023
23.05.2016
SUB: SUGGESTIONS ON MPD 2021 MODIFICATIONS IN RESPONSE TO PUBLIC NOTICE
DATED 24. 04.2016
Dear Sir,
Thank you for giving us an opportunity to give our suggestions on the MPD 2021 modifications in
response to the public notice dated 24.04.2016.
The regulations and provisions of the MPD 2021 that will help operationalise the TOD Policy in Delhi
need to ensure that the intent of the Policy is not lost in the implementation process.

1. INTENT : Demarcating an influence zone for TOD

Reference:
As per UTTIPEC Policy draft:
The Influence Zone along MRTS corridors shall be demarcated as per the
following:
(i) A maximum up to 2000 m. wide belt on both sides of centre line of the
MRTS/ Major Public Transport
(ii) The Influence Zone further consists of three sub zones Intense Zone,
Standard Zone, and Transition Zone (see Figure 1). Demarcation of zones,
characteristics and norms are applicable as per Table 1 below.
Development Control Norms as per Section 2.1 2.5 apply to all three
sub-zones. Norms as per Section 2.6 High Density Mixed Income
Development shall not be applicable to the Transition Zone.

As per MPD 2021 (July Draft):

The scheme for Development / Redevelopment of Influence Zone shall be
prepared on the basis of the following:
(i) About 500 m. wide belt on both sides of centre line of the existing and
planned / approved MRTS Corridors will be designated as Influence Zone
which will be identified
in the respective Zonal Development Plans.
Issue:
MPD refers to 500 m linear corridor on either side of the MRTS,
however UTTIPEC policy document refers to 300m, 800m and
2000m radial distances from transit stations as the zones of
influence with varying intensities and norms for TOD
The UTTIPEC policy document suggests a graded system for
implementing TOD, which is in direct relation with the intensity /
proximity to the transit centre. Regulations dont cite the urban
design guidelines as bye laws in different zones for management of
the precincts in terms of parking facilities, movement networks etc
Recommendation:
TOD is oriented around MRT hubs for ease of access to the hubs and not
the transit corridor, therefore the effective influence zone where TOD is
applicable needs to be limited to a radial distance (500m) from the hub. It
should not be applicable to the continuous stretch on either side of the
transit corridor. Further, the UTTIPEC policy document suggests a graded
system for implementing TOD, which is in direct relation with the
intensity / proximity to the transit centre (300m, 800m & 2000m) with
varying pedestrian & parking management strategies for different zones.
This is an important principle of TOD which needs to be acknowledged in
the regulations.

2. Intent : Preparation of an influence zone plan as a pre-requisite to

TOD to ensure integrated development/ redevelopment
Reference:
As per Public notice for modifications in MPD 2021

Issue: Scaling down the integrated Plan to a minimum requirement of

1Ha to be prepared by DE cannot lead to an integrated development of
the entire TOD influence zone.
Recommendation:
Influence zone plan needs to be prepared in advance by the Authority for
the entire TOD influence zone to provide/regulate urban infrastructure and
to guide redevelopment. This shall be a prerequisite to entertaining any
DE proposals. A time bound program for publication of such plans shall be
committed to by the Authority.
In the absence of this procedure TOD development will attract legal
challenge.
The integrated influence zone plan shall lay down a 100m c/c pedestrian
movement & 250m c/c vehicular movement grid, and also mark areas

exempted from TOD under AAI or monument regulated zone regulations. It

shall be the responsibility of the Authority to make this information
available at the single window.
3. Intent : Increase in density in the TOD zone
Reference:

Issue:
Higher FAR does not ensure a higher density unless minimum density is
prescribed in the regulations / norms
Recommendation:
A. Apart from maximum & minimum FAR the regulations need to stipulate
a range of maximum & minimum densities to be achieved for
corresponding range of FAR as has been suggested in the TOD Policy
document:

B. The maximum permissible FAR of 400 is an absolute number reflecting

the available/ planned infrastructure provisions. This cannot be
exceeded. Therefore, the mandatory EWS component (15% of FAR)
shall be provided within the 400 FAR.

4. Intent: Ensuring high density mixed use development within

transit influence zones
Reference:

Issue:
The government and public land uses form a substantial part of the city
fabric and have an untapped potential for mixed use TOD and should not
be exempted from the minimum mixed-use norms. Not tapping this
potential will render TOD ineffective along many stretches of the transit
corridors.

Recommendation:
Govt., Transport & Public-Semi-Public land use shall not be exempted from
the minimal use clause if they are exploiting a higher FAR under TOD.
Certain specific uses which dont conform with mixed use might be
exempted up to a maximum land area of 0.5Ha. In case larger land
holdings are required for such specialised uses, such institutions should be
relocated to lands away from the TOD zone. This will maintain a continuity
of high density development close to the transit corridor as intended by
the policy.
5. Intent: To ensure affordability of housing close to transit corridors
and prevent gentrification
Reference:

Issue: Increasing the unit size cap to <93 sqm. reduces affordability for
lower & middle income groups.
Recommendation:
Dwelling Unit area shall be carpet area of the dwelling unit.
The area cap should ensure affordable unit sizes:
o Of the 30% mandatory residential mix 50% units should be
<60sqm carpet area and remaining 50% can be <93sqm
carpet area.

6. Intent: Providing public open space & pedestrian friendly, safe, active
streets as part of TOD to benefit maximum number of people.
A. Reference:

Issue:
The phrase Public use has been replaced with common use. This
dilutes the legal right for the public to use such spaces without
hindrance.
If the roads are not public, access to the open space provided
within the scheme may become restricted.
Recommendation:
The phrase Public use needs to be retained to legally enforce the intent
of the scheme

B. Reference:

Issue: Making the provision of public open space mandatory for only
larger developments will lead to absence of quality public open spaces in
areas with many small (< 4 Ha) individual developments.
Recommendation:
Provision of public open space shall be mandatory for all developments
under TOD irrespective of the size.
7. Other Recommendations:
The TOD guidelines and the regulations under review appear to be
made for green field projects. It is expected that the Authority would
prepare TOD guidelines & development regulations separately for
redevelopment zones within the existing city fabric.
The built structure provisions are stated in the MPD but the
management & operations are not covered by the regulations or the
MPD. Legal and binding provisions should also be made for Parking
management, fresh & waste water management, Green building
practices, urban design & street design. In the absence of such bye
laws the TOD policy intent of improving the quality of built
environment cannot be met.

8. Alternate model for Sustainable, Low carbon Development

LOW CARBON URBAN DEVELOPMENT
At COP Paris the Government of India has committed to low carbon
growth. The TOD policy states low carbon urban development as one of
its key objectives. This objective is well served by promoting rail based
mass transit system for long distance trips travel across the city and by
enabling walking and cycling for short local trips. This strategy reduces
carbon emissions per unit of travel in the city compared to a
predominantly personalized motor vehicle dependent system.
HOWERVER, THIS POTENTIAL GAIN OF LOW CARBON MOBILITY IN THE CITY
IS NEGATED AND MORE THAN LOST IN THE INCENTIVISED HIGH RISE
PATTERN OF DEVELOPMENT THAT RESULTS FROM THE HIGH FARs
PROPOSED FOR THE TOD 500 METRE INFLUENCE ZONE. This aspect is yet
to be technically evaluated and alternative strategies for high density
affordable development with lower carbon footprints need to be studied
before the TOD development guidelines are adopted.
HIGH EMBODIED ENERGY
The embodied energy ( energy invested in the production of building
materials) for high rise buildings, i.e buildings greater than 15mts. in
height , is 10 to 20 times higher compared to buildings up to 15 mts in
height. This is on account of the higher consumption of steel and cement
concrete per unit area, the provision of additional services and equipment,
and the increase in built-up area per unit of net usable area.
A rapid spread and expansion of this pattern of development would
constitute an explosion of carbon dioxide emissions. This is contrary to
National policy.
A compact urban morphology of buildings must be found where
the embodied energy in buildings is kept low, while achieving low
carbon mobility.
HIGH OPERATIONAL ENERGY
Vertical transport : The additional electricity consumption for vertical
transport lifts and pumps to transport people, goods and water for
buildings higher than 15mts. raises per capita electricity consumption by
10 to 20% - the taller the building the higher the percentage increase in
electricity consumption.
Thermal comfort: The upper floors of tall buildings are exposed to high
wind velocities that may be two to three times the velocities close to the
ground. Exposure of the building envelope to these winds during high
summer and high winter results in greater reliance on air conditioning and
electric heating to maintain reasonable indoor comfort. While this can be
countered by more sophisticated and more expensive engineering of
windows and building envelopes for upper income homes, for middle and
low income housing, high rise housing would, in the medium and long
term, result in a further 10% increase in operation energy due to residents
progressively resorting to air conditioning.

A compact urban morphology must be found where the

operational energy of buildings is kept low, while achieving low
carbon mobility.
MICRO CLIMATE
High rise high density would exacerbate the Urban heat Island effect due
to higher concentration of anthropogenic heat (air conditioning and
electrical equipment ) higher hard surface/mass absorption of heat and
concentration of motor vehicle movement. The upper floor of tall buildings
are unable to take advantage of the beneficial reduction in ambient
temperatures from greenery and trees near the ground.
SOLAR ACCESS for SOLAR CITY
The roof area of a five storey high building, provides sufficient solar PV
energy to be net zero on an annual cycle, though this will not suffice for
general use of air conditioners. High rise buildings (greater than 15mts
high) militate against the potential of solar PV. The taller the building, the
less the roof area in relation to its built up area, which means that urban
system of tall buildings can never hope to aspire to become solar cities.
Tall buildings will also cast shadows on the rooftops of shorter buildings in
their neighbourhood, thereby robbing them of their potential of solar PV
electricity generation.
An urban fabric where buildings are generally four to six storeys
tall will, clear tree tops and avoid mutual shading. They will all
have guaranteed solar access. THIS OFFERS THE GREATEST
PROMISE OF LEAPFROGGING TO LOW CARBON URBAN FUTURE
FOR DELHI.
EQUITY AND AFFORDABILITY
A key objective of the TOD Policy is to promote spatial and economic
equity with large scale housing developments in close proximity to the city
transport infrastructure for the middle and lower income groups. The
paying capacity of this economic cohort of citizen households is limited.
Buildings must be economical in cost of construction and in their
operational cost.
This is attainable with low/medium rise high density morphologies. High
rise developments would not be suitable for low income groups and will be
inherently costly in comparison to low/medium rise developments.
ECONOMIC VIABILITY AND ROBUSTNESS
The present proposal for a blanket FAR of 4 over the gross land area of
proposed TOD development is not economically viable. This results in a
global spread of buildings with an average height of 14 storeys!!!!! This
pattern of development has two drastic consequences:
- The inherent cost of development is raised by 20% and becomes
unaffordable building systems & technologies, finance &
financial risk, time for project implementation.

The price of land tends to rise speculatively on the basis of

permitted FAR even when there is weak market demand\
It is this factor (excessive FAR provision) which has led to
a glut in unaffordable real estate

The larger the scale of construction units, the less robust the building
types complex multi-storey buildings are less secure in calamities such
as earthquakes and fire. They are susceptible to failure during utility
breaks downs (or they need to invest heavily in backup systems).

RECOMMENDATION
75% of the land of a TOD project shall be of low/medium rise
development.
To meet the objectives of low carbon urban development twinning
compactness for efficient mobility with low carbon building morphology is
necessary. This is achieved by the following development parameters:
A. For the (intense) 500 meter zone around a mass transit hub :
Overall Maximum FAR : 3.0 of gross plot area
Overall Minimum FAR : 2.0 of gross plot area

For 75 % of the gross land area of a proposed TOD development

Max. FAR: 2
Permissible ground coverage of developable plot: 50%
Maximum height of buildings: 20 mts.
Minimum density: 225 dus per hectare

For remaining 25% of the land proposed TOD development

balance FAR may be utilized at a single location with no height
restriction.

B. For the (standard) 500 metre zone along the transportation corridor,
but greater than 500 mts from the mass transit hub :
Maximum FAR : 2.25
Minimum FAR : 1.5
Permissible ground coverage of developable plot : 50%
Minimum density: 150 dus per hactare

The above development parameters will ensure that the new development
is low carbon while catering to a wider range of income groups. The
pattern also maintains the scale & quality of streets and open spaces
where only a small part of the development is high rise.
Most importantly, these development parameters enable a building
typology which is economical & affordable for 75% of residents. The

potential exploitation of land value can be absorbed in the 25% high rise
zone.

I hope these suggestions are taken into consideration to achieve a fair draft of
the TOD regulations which leads to development that benefits majority of the
citizens.

Thanking you
Yours faithfully
Ashok B. Lall
Ashok B. Lall - Architects
2B, Ramkishore Road,
Civil Lines
New Delhi - 110054
Mobile: +91 9891487981
E: ashokblall@gmail.com