The document is a letter from an organization called Mission Gurgaon Development to the Secretary of the Ministry of Environment and Forests regarding a review of the draft revision of the Regional Plan 2021 for the National Capital Region. The key points are: 1. The organization has grave concerns about environmental dilutions and gaps in the revised draft plan that could damage eco-sensitive areas like the Aravali ranges and river beds. 2. Several important environmental safeguards in the current plan, like restrictions on construction in conservation zones, are being diluted or removed in the revised draft without proper review. 3. The revisions could open up forest land and groundwater sources to development, violating environmental laws.

1. mission
Reg No: DR/GGN/291 of 2010-11
A people’s movement for good
governance
®
GURGAON
DEVELOPMENT
To: Dr V Rajagopalan, I.A.S.,
Secretary, Ministry of Environment and Forest,
CGO Complex, Lodhi Road,
New Delhi 110003
17thOctober 2013
Email ID : vrg.iyer@nic.in
Fax : 91- 11-24362746
Telephone No. : 91- 11-24360721
Dear Sir,
Sub:Review by MoEF on Draft Revision of the Regional
Plan 2021, prepared by the NCR Planning Board, for
which public comments were due Aug 30th 2013.
1. The National Capital Region Planning Board (NCRPB) is
currently undertaking an exercise of revising the Regional
Plan 2021, for which the public comment period ended on
August 30th 2013.
We have grave concerns about the
dilution of environmental safeguards in this revision
process, as well as additional environmental gaps. These
dilutions and gaps will lead to loss of eco-sensitive areas in
the NCR, and damage the strategic ecological assets of the
NCR – especially the Aravalli ranges and river beds, and
irreversibly impact groundwater recharge capacity and
drinking water security, wildlife habitat and biodiversity,
and drastically reduce the natural adaptive capacity of the
NCR region to climate change impacts. Accordingly we
request MOEF to examine the current Regional Plan 2021,
the Revised Draft Regional Plan 2021 at a priority basis,
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and provide their inputs from a technical and statutory
perspective. The details are as follows.
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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2. mission
Reg No: DR/GGN/291 of 2010-11
A people’s movement for good
governance
®
GURGAON
DEVELOPMENT
The Regional Plan
2. The Regional Plan 2021 is prepared basis the statutory
mandate of the NCRPB Act, 1985.
a. The objective of the Regional Plan is to control landuses, avoid haphazard development and promote
balanced growth and development in the NCR.
b. Chapter IV, Section 10, sub-section 2, of the National
Capital Region Planning Board Act, 1985, states that,
“The Regional Plan shall indicate the manner in
which the land in the National Capital Region shall
be used, whether by carrying out development
thereon or by conservation or otherwise” (emphasis
added).
3. It is thus, clear, that the Regional Plan is a very important
instrument in deciding on lands that need to be conserved,
through control of landuse and determining the zoning and
policy proposals for ensuring conservation of eco-sensitive
areas such as the Aravalli ranges, Yamuna and other river
flood plains, and allocating land for forests etc.
4. Indeed, the Regional Plan 2021 provides for a Natural
Conservation Zone which covers the Aravalli Range in the
NCR, river beds and flood plans, etc, and this Natural
Conservation Zone has a limit on construction of 0.5%, that
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effectively zones this area for conservation and precludes
construction.
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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3. mission
Reg No: DR/GGN/291 of 2010-11
A people’s movement for good
governance
®
GURGAON
DEVELOPMENT
5. The NCRPB is currently finalising a revision of the
Regional Plan 2021. Accordingly, the NCRPB had prepared
a Revised Draft Regional Plan 2021 which was put out for
public comment by August 30, 2013- it is now engaged in
the process of compiling the comments and objections from
various quarters for a final review prior to notification.
The Regional Plan 2021 revised draft - dilutions and gaps
6. Based on a comparison of the currently in-force Regional
Plan 2021 with the proposed revised draft of the Regional
Plan 2021, we find that there are serious gaps and omissions
in the Regional Plan 2021 with respect to the conservation
of Aravalli hills, other environmentally sensitive areas, and
other environmental matters.
What is worse is that the
limited environmental safeguards in the current Regional
Plan 2021, are being further sought to be diluted and/or
removed, in the Revised Draft Regional Plan 2021.
7. Having inspected the relevant files of the NCRPB, under
the RTI Act, 2005, we find that without verifiable inputs
from any traceable competent authority / technical experts
at the Centre/States or from Research groups/ NGOs/
Academics, key safeguards for environmental/biodiversity
protection have been diluted or/and removed.
8. The Revised Draft Regional Plan 2021 is littered with small
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and large changes. As the NCRPB has not provided any
summary listing of the proposed changes, any review would
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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4. mission
Reg No: DR/GGN/291 of 2010-11
®
GURGAON
A people’s movement for good
governance
DEVELOPMENT
ideally require a line by line comparative reading of the
current Regional Plan 2021, and the Revised Draft Regional
Plan 2021, to identify the deletions and additions.
9. For your convenience, we list here some of the Key
environmental safeguards in the current Regional Plan
2021, that are being diluted in the Revised Draft Regional
Plan 2021:
a. Deletion of restriction on construction of 0.5% in
the Natural Conservation Zone. (Chapter 17,
Section 17.5.3 of current RP 2021)
b. Removal of line that states, “No such activities
should be undertaken in the Aravalli range in
NCR.”, in section 14.2.(ix) of current RP 2021
which in effect extends Aravalli notification
(issued my MoEF on 7 May 1992), to Faridabad
and Delhi in Aravalli notification
c. Inclusion
of
development
guidelines
in
Conservation Plan provisions, that would in effect
allow real estate and other development through
the Conservation Plans.
d. Land Suitability Analysis is a key step in
identifying eco-sensitive areas for conservation
within urban areas. However the revision limits
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Land Suitability Analysis to new towns, thus in
fact, gutting this requirement as most growth in
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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5. mission
Reg No: DR/GGN/291 of 2010-11
A people’s movement for good
governance
®
GURGAON
DEVELOPMENT
the NCR is via expansion of existing towns, which
would now be excluded from this provision.
10.In addition, other environmental concerns and gaps with
respect to the Revised Draft Regional Plan 2021:
a. Decline of forest cover, yet no reservation of areas
for forest.
b. Forest cover diluted to green cover.
c. Flood risk – due to sand mining etc in river beds, but
no proposal for areas off limits to sand mining, and
other areas for sustainable sand mining in the river
beds and flood plains
d. Issue of drinking water security and carrying
capacity, and identification of Aravallis, as an
important groundwater recharge zone, as has been
asserted by the MoEF under oath in the Hon’ble
Supreme Court, in the MC Mehta case in 2008 (in
WPC 4677 of 1985).
e. The Hon’ble Supreme Court ordered a “ban on
mining activity and pumping of groundwater
imposed in an area upto 5 km from Delhi-Haryana
border on the Haryana side of ridge and Aravalli
hills.” (order dated 6.5.2002 in WPC 4677 of 1985).
The implication of this order is that no exploitation of
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groundwater and digging of borewells can be
permitted in the 5 km zone from the Delhi border and
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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6. mission
Reg No: DR/GGN/291 of 2010-11
®
GURGAON
A people’s movement for good
governance
DEVELOPMENT
falling in Haryana Aravalli hills. This needs to be
reflected in the Regional Plan 2021.
f. Wildlife Habitat and Corridors need to be
identified
g. Eco Sensitive zones in the buffer of Asola sanctuary
need to be identified both in Delhi and in the Haryana
side.
h. The Mangar Sacred grove and an essential buffer
need to be identified and zoned as a no-construction
zone.
i. Concerns regarding hazardous and solid waste
disposal in ground water recharge zones and ecosensitive areas.
11.Prima facie, these proposed changes will dilute the National
Conservation Zone provisions and open up recorded forests,
as well as yet to be identified deemed forests as per
dictionary meaning, qua Godavarman 12.12.96 & 06.07.11
judgments, in Southern Haryana and elsewhere, for nonforest activities, in contravention of Section 2(ii) of the
Forest Conservation Act.
12.MoEF may also exercise its wide-ranging powers to restrict
activities under the Environment Protection Act, 1996
(specifically, Section 3(1) and 3(2) (v) of the EPA, 1986
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and Rule 5 (3)(d) of the Rules, 1986.
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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7. mission
Reg No: DR/GGN/291 of 2010-11
®
GURGAON
A people’s movement for good
governance
DEVELOPMENT
13.When small and large real estate projects covering mere
tens of hectares require Environmental Review and
Clearance under the Environmental Protection Act 1986, it
will be a travesty if a Regional Plan covering thousands of
square kilometers including highly ecosensitive zones such
as the Aravallis is permitted to be revised, with likely
massive
negative
impacts
on
the
environmental
sustainability and carrying capacity of Delhi NCR, without
any environmental review and input from the MoEF.
14.This is a recipe for disaster and negates the principles of
sustainable development, the precautionary principle, intergenerational equity, carrying capacity as well as the various
international protocols on biodiversity and green house gas
emissions
that India has signed, i.e. Convention on
Biological Diversity ratified by India on 18.02.94,
Convention to Combat Desertification ratified by India on
17.12.96, Montreal Protocol on Substances That Deplete
the Ozone Layer acceded to by India on 03.03.03,
Stockholm Convention on Persistent Organic Pollutants
ratified by India on 13.04.06, United Nations Framework
Convention on Climate Change ratified by India on
01.11.93, 26.08.02, & Decision 5/CP.17 at Conference of
the Parties on its seventeenth session, held in Durban from
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28 November to 11 December 2011 which was attended by
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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8. mission
Reg No: DR/GGN/291 of 2010-11
A people’s movement for good
governance
®
GURGAON
DEVELOPMENT
H.E. Ms. Jayanthi Natarajan, Minister of Environment and
Forests, India.
15.You are therefore requested to review these and other
aspects that are critical to the strategic environment
sustainability of the NCR region, to the NCRPB.
16.You are also requested to ask the NCRPB to keep its
revised draft Regional Plan 2021 on hold till it is reviewed
by the MoEF.
17.We will be happy to share our analysis with the MoEF and
request a personal hearing for the same. A copy of the
suggestions and objections filed with the NCRPB are
attached for your reference (Annex 1).
For Mission Gurgaon Development
Lt Col (Retd) Sarvadaman Singh Oberoi
Treasurer
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About Mission Gurgaon Development
Mission Gurgaon Development (MGD) is a people’s movement
launched by the residents of Gurgaon against inadequacies in
governance and resultant poor development in Gurgaon. Our
vision is to ensure that Gurgaon becomes an epitome of urban
living, affording a nurturing quality of life to its empowered citizens.
The goal is to usher in reforms in local governance, through
implementation of the 73rd/74th Constitutional Amendment Act.
MGD is the first and only think-tank in Gurgaon that works for and
advocates for systemic changes in governance based on
decentralization, accountability, transparency, and participation of
citizens in governance decisions.
543 Sector 23, Gurgaon; Tel: 9312404269, 9818768349, 9871628217; E-mail: missiongurgaondevelopment@gmail.com
Governing Council: Vinay Shankar, Patron, Former Secretary, Govt of India Devinder Chopra, Patron, UN retiree Maj Gen Satbir Singh, SM,
President, Vice Chairman IESM Dr Nalini Bhargava, Vice President, Educationist Dr Bhawani Shankar Tripathy, General Secretary, Development professional
Col Sarvadaman Oberoi, Treasurer, RTI activist Vakul Cowshik, Member, Social worker
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www.missiongurgaondevelopment.org
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