To:
Shri. Jayesh Ranjan, IAS
Vice-Chairman
Hyderabad Urban Development Authority
Hyderabad

Sub: Reg. Seeking reply on the report appeared in Eenadu regarding proposed Construction of a Multilevel Parking Complex in Necklace Road

Ref: Our letter dated 15 th March 2006 (Annexture II) & your response to my letter dated 17 th March 2006 (Annexture I)

Dear Jayesh Ranjan Garu,

This is in continuation to my earlier letter and your reply to my letter that I would like to bring to your kind notice the following points:

The Technical Committee of APPCB met all the stakeholders on 6.7.2001 on Buddha Poornima Project with reference to the Hon'ble High Court judgment dt. 15.6.2001 on W. P. No. 23768 of 2000. In this discussion one of the four projects relate to “Amusement Park in the vacant land of NTR gardens” -- That means, it is not meant for parking complex as proposed now by HUDA but it is meant for Amusement Park.

At the out set we would like to reiterate that NTR Garden, IMAX Theatre and the 2.5 acres area now proposed for construction of Multi-Level parking facilities, are in the land originally farming part of Hussain Sagar Lake. This land mainly comprises of reclaimed area from Hussain Sagar due to bunding of the lake area, consequent to lying of the road, now known as NTR Marg.

HUDA as Buddha Purnima Greenbelt had developed this reclaimed land, by planting more than 8000 plants in 1993 as part of Urban Forestry Programme. By doing so HUDA has sought to improve the environment and ecology of the reclaimed area. Moreover the 4 hectares area of Buddha Purnima Project, now allotted for establishment of IMAX Theatre and the adjacent open area earmarked for Amusement Park, was shown as water body, vide Land use Certificate issued on 11-7-1995, till its land use was changed to commercial use in 1995.

We would like to emphasize that the High Court order dated 15-6-2001 precludes raising of any further permanent structures including those involving commercial activities, on or near water spread or catchment area of Husain Sagar. However, the other aspects of the proposed activities via, construction of an amusement park etc (not involving raising of permanent structures) may be allowed with prior clearance of AP PCB ensuring that creation of such entertainment parks etc would result only in sustainable development which would not create any ecological imbalance. This clearly says that there should not be any permanent structures [multi-level parking is a permanent structure, no body can deny this fact] on or near water spread or catchment.

Therefore the contention of HUDA that the proposal to construct Multi-Level Parking facility, in 2.5 acres land, which was originally part of water body and subsequently converted for commercial use – namely amusement park – will not be in deviation of the Hon'ble High Court Order in WP No. 23768 of 2000 is not correct and tenable.

Your observation “the Hon'ble Supreme Court Committee has commented that the NTR Gardens are now on relatively high ground and therefore, may be left alone” does not imply to construct a highly polluting activity like permanent structure of multi-level car parking. Concentrated parking facilities always create more traffic and pollution problems rather than solving them.

The main issue dealt by the Technical Committee of APPCB relate to traffic problems, air pollution and noise pollution. In this connection, the committee said that there could be no net addition of vehicular traffic and consequently net addition of air pollution attributable to the developments proposed, on all roads surrounding the lake. In this connection the Technical Committee proposed that “public convenience shall be provided by the project proponents for the use of the public visiting these places. The bus service circling the lake as suggested by Charles Correa should be considered for implementation. This will reduce the visitors to the project area using their own vehicles for access to different components of the Buddha Poornima Project; The proposed road from the lake to the Secretariat on the northeastern side shall be a pedestrian way only; No entry shall be provided to Amusement park and I-max theatre from NTR Marg and these two along with NTR gardens can be interconnected to permit internal pedestrian movement, etc”.

What all these means is that to visit any component on and around Hussain Sagar lake shall be interconnected with pedestrian pathways with bus-bays on a circular path using non-polluting buses around the Hussain Sagar – now even the MMTS stops are available for visitors these could be effectively utilized. The parking of vehicles can be made at different points on different sides not connecting directly Hussain Sagar Surroundings/catchment area.

Here we would like to bring to your notice “The Times of India” [21.3.2006 on page 4] report with a caption “Necklace Road: High-risk zone”, wherein it reported the death of a child at Eat Street on Necklace road by a speeding vehicle. This is all happened basically because the indifferent attitude of concerned officials who do not want displease the powerful people running the commercial establishments around the Hussain Sagar lake with high connection at seat of power keeping a nilson's eye on the illegal constructions/activities and not implementing the APPCB Technical Committee suggestions.

Appeal: The proposed Multi Level Parking facility for 1000 vehicles, to cater for the future levels of growth is a myth. Unless the efficient and affordable Public Mass Transport System is developed, no amount of Parking facilities, Widening of Roads, Building of Flyovers etc will be able to cater for the growing levels of personalized vehicular traffic. “It is like trying to cure obesity by loosening the belt” 

We, therefore, appeal the authorities to create more appropriate and pragmatic parking-sites at different places outside the Hussain Sagar purview/catchment area and making the interconnections through non-polluting buses [and using MMTS stops] by connecting bus-bays to internal pedestrian pathways to all components on or around Hussain Sagar Lake. The parking needs of secretariat could be met within the secretariat compound itself. It is not a good idea to please the secretariat at the cost of Hussain Sagar Lake environment.

Looking forward for your early response

With Regards

Yours truly,

S/D, 15 th March 2006
[Dr. S. Jeevananda Reddy]
General Secretary
Forum For A Better Hyderabad .

Annexure I

Dear Dr. Jeevananda Reddy Garu,

          This is with reference to your letter of 15 th March 2006 regarding  construction of multi level parking complex on Necklace road, about which a news item appeared in the Eenadu on 11 th March 2006.  The factual position in this matter is as follows: 

A large number of visitors are coming to HUDA's NTR Gardens, Lumbini Park and Laser Show in their own vehicles.  The present parking facility available on the NTR Marg (outside NTR Gardens) and adjacent to Lumbini park is completely inadequate due to which most of the vehicles are found parked on the main road itself, causing inconvenience to the traffic flow. 

HUDA has therefore decided to construct new parking facilities to cater to all the vehicles that are coming to the above mentioned locations.  Keeping in view the levels of growth in the city, the proposed parking facility will cater to thousand vehicles cars and will be necessarily multi level.  A part of rear side of NTR Gardens area (measuring 2.5 acres) has been identified for this purpose.  Neither the location selected, nor the nature of construction planned, will be in deviation of the Hon'ble High Court judgment in WP No.23768 of 2000.  The location so selected is neither on or near the water spread area or in the catchment area.  All necessary approvals of the A.P. Pollution Control Board will be obtained as required by the above mentioned judgment.

The committee constituted by Hon'ble Supreme Court in SLP 5594/95-04 to report upon the encroachments and pollution levels in the Hussain Sagar Lake in its recommendations has observed that the four car parks on the Necklace Road , namely, at People's Plaza, Necklace Road Railway Station, North of Khairatabad STP and opposite I-Max Theater, should be closed down.  Once these recommendations are implemented, there will be no parking facility at all for visitors to that area except the one which is now proposed.  Moreover, parking space requirements in the Secretariat is also rapidly increasing.  The proposed Multi level parking facility in NTR Gardens can accommodate this requirement also. 

While recommending serious action against various activities in and around Necklace road, regarding NTR Gardens, the location of the proposed Multi level parking complex, the Hon'ble Supreme Court Committee has commented that the “NTR Gardens are now on relatively high ground and therefore, may be left alone”, implying that the activities in the NTR Gardens are neither contributing to the lake's pollution, nor can be construed as encroachments in any way.

The decision to construct Multi level parking to cater to thousand vehicles in an area of 2.5 acres within NTR Gardens has been taken after examining all the factors as explained above. 

Yours sincerely

Jayesh Ranjan, IAS
Vice Chairman,
Hyderabad Urban Development Authority (HUDA)

Annexure II

To:
Shri. Jayesh Ranjan, IAS
Vice-Chairman
Hyderabad Urban Development Authority
Hyderabad

Sub: Seeking reply on the report appeared in Eenadu regarding proposed Construction of a multilevel parking complex in Necklace Road

Dear Jayesh Ranjan Garu,

I, on behalf of Forum For A Better Hyderabad, would appreciate getting a reply on the report appeared in Eenadu [11 th March 2006] that HUDA is planning to construct a multilevel parking complex in Necklace Road to accommodate around 1000 cars at a time – tenders will be closed by 23 rd March 2006. The location of this is cited at between Imax Theatre and NTR Garden on an area of 2.5 acres. The report also says that you have mentioned that there is no restriction for construction of such a multi-storied building.

In this regard I would like to bring to your kind notice the judgment by Hon'ble High Court with reference to W. P. No. 23768 of 2000, judgment delivered on 15 th June 2001 says as follows [main portion of the judgment]:

• No further permanent structures including those involving commercial activities may be allowed to be raised on or near the water spread or catchment area;
• It also directed that the construction of an amusement park etc may be allowed subject to examination and certification by AP Pollution Control Board that creation of such entertainment parks etc would result only in sustainable development and would not create any ecological imbalance.

In pursuance of this direction, committee consisting of all stakeholders, the Technical Committee of APPCB stipulated the condition that the net traffic flow should not increase though all these projects -- Unfortunately, around Necklace Road Jungle Raj is prevailing with no government agency having control, the Food Court and Jalavihar managements are going ahead with illegal constructions in violation of CFE order given by APPCB. Even liquor is sold here!!! Most unfortunate!!!

We, therefore, appreciate getting a reply that whether the Eenadu report is correct or not. If not, what is correct version?

Looking forward for your early response

With Regards

Yours truly,

S/D, 15 th March 2006
[Dr. S. Jeevananda Reddy]
General Secretary,
Forum For A Better Hyderabad.

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FORUM FOR A BETTER HYDERABAD

8-2-590/B, Road No.1, Banjara Hills, Hyderabad – 500 034

Forum / 2005                                                                                   October 12, 2005

The Vice –Chairman & Managing Director

Hyderabad Urban Development Authority,

Paigah Palace, Police lines

Secunderabad -500 003

Sir,

          Sub: HUDA  Public Consultation Programme on 10 th October 2005

                    At the outset we would like to thank HUDA and BPPA for giving an opportunity once again to the representatives of the FORUM to participate in the Public Consultation Programme on “Hussainsagar Lake and Catchment Area Development” held on 10^th October 2005. We also take this opportunity to compliment HUDA for  the efforts being made by HUDA to  protect and preserve some of the lakes in and around Hyderabad.

                    Further to our views expressed on the subject, in letters dated 20-10-2003 and 20-11-2003 and at the Public Consultation Programme held on 10 th October 2005, we would like to reiterate that to restore Hussainsagar lake to its past glory in all respects, it is essential to:

• Prevent further shrinkage of the water spread area of the lake, and
  to clearly notify and demarcate the water spread area of MTL and FTL

• Remove unauthorized / illegal structures within  notified  water  spread
  area  up to MTL

• Fence (not high wall)  the demarcated water spread area of MTL and
  undertake  suitable plantation of the area between MTL and FTL, where ever practicable, to act as  bio-filter, which is not to be permitted for reclamation,  landscaping   by lawns, paved pathways  etc

• Prevent further inflow of untreated and under-treated domestic sewage, industrial effluents etc and   dumping of toxic materials in the lake, AND

• Clean up, improve and protect  shoreline and catchment area of the lake before taking up dredging and disposal of hazardous lake sediments.

Water Spread Area

                  As per the presentation paper made available on 10 th October, the Maximum and the Present Water Spread Areas are 5.70 Sq.Kms (1408 Acres) and 4.81 Sq.Kms (1188 Acres) respectively, with FTL of 513.43 M and the volume of 27.18 MCM at Spill Level of the lake. The Surplus Weirs need to be suitably designed or strengthened to facilitate, only the water in excess of FTL of the lake is discharged. This arrangement will improve the water holding capacity of the lake.

Development Components

                  We generally agree with the development components proposed in the presentation paper, with regard to 1) Sewerage Treatment 2) Catchment Area Improvement 3) Shoreline Improvement and 4) Social Development, by incorporating the suggestions made above. But we do not agree with the proposal for resorting straight away to dredging and disposal of hazardous lake sediments. The treated water from STPs should conform to the standards specified for reusable water or for discharge into surface waters. Immediate action needs to be taken in respect of the existing 20 MLD  STP, whose discharges into Hussainsagar are not in conformance with the above standards and are in violation of the provisions of  EP Act , 1986

Dredging and Disposal of Hazardous Sediments

               The STPs will not be able to degrade, or remove or reduce the total load, of the toxic substances and chemical compounds, that find their way into the sewers / drains from Hospitals, Nursing homes, Clinical labs, Chemical laboratories etc except diluting their concentration levels. The other aspect is the storm-water run off contaminated with hazardous substances, finding their way directly into the lake through storm water drains.  Before planning dredging operations, it is essential to identify both point source and non-point sources of hazardous pollutants like Arsenic, Mercury, Cadmium, Lead etc and to take necessary steps for preventing them entering into the lake.

Conclusion

                The priority may please be given to the components, other than the dredging and disposal of hazardous sediments, with focus on protection and preservation of water spread area of the lake and identifying & preventing the hazardous wastes entering the lake. The break up of estimated costs for different components, the time schedule, progress of implementation of the project etc may please be made available on the website apart from frequent interaction with the stake holders and the community. 

                                                         Thanking you.

                                                                                              Yours cordially,

                                                                                  Capt.J.Rama Rao I.N. (Retd)

                                                                                                  Chairman

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PROTECTION OF HUSSAIN SAGAR - A Heritage Site

Date: 14.7.2005

To

The Members of

The Committee Constituted by Supreme Court on

Hussain Sagar Lake

HYDERABAD

Dear Sirs,

Sub: Protection of Husain Sagar,  a Heritage site – Regarding.

                                                 ***

We recommend that the Hussainsagar lake be declared as a Heritage Structure in Category 1, and its surroundings, which will constitute its precinct, be clearly demarcated and then declared as a Heritage Precinct under Regulation 13.1 of HUDA Zoning Regulations, 1981. We have written to The Hyderabad Development Authority and the Heritage Conservation Committee of the state government in the matter and a copy of our letter is enclosed.

The Government of India has identified 21 fresh water lakes in the country for conservation under the National Lake conservation Plan. In the first phase, work will be done in ten lakes, and Hussainsagar is included in this first phase.    

Definition of Heritage Precinct.

Heritage Buildings( HB) are defined under  Regulation 13.1 of HUDA Zoning Regulations, 1981  as  “ Buildings, Artefacts, Structures, and/or Precincts of Historical and/or Aesthetical and/or Architectural and/or Cultural value.” Heritage Precinct is an entire zone, designated as such, which is to be conserved in entirety, including its surroundings, and not merely the notified heritage buildings in that zone.

Sub-section 7 of this regulation states that “buildings included in Heritage Precincts (HPs) shall maintain the skyline in the precinct [without any high-rise development] as may be existing in the surrounding area, so as not to diminish or destroy the value and beauty of the said listed HB/HP. The development therein shall be in accordance with the guidelines framed by Vice Chairman (VC), HUDA in consultation with Heritage Conservation Committee (HCC).” HCC  is appointed by the state government 

 In its Notification No 3023/PR/HUDA/2000 dt 30-4-2000, HUDA went on say that “The notification of HP’s will imply that development proposals, street furniture, road-widening proposals and outdoor publicity within the Heritage Precincts shall need to be approved by the VC HUDA and the HCC before permission is granted by the MCH or other competent authorities.”

Grading of HBs & HPs   HUDA regulation no 13

These are categorized into Grade I, Grade II and Grade III, depending on importance.

Grade I: No interventions on exterior or interior, except for conservation, when only absolutely essential, are permissible.

Grade II (A): Only internal changes and adaptive re-use, external changes subject to scrutiny, can be permitted.

Grade II (B): In addition to above, extension/additional buildings in same plot, subject to harmonizing in terms of height and façade, may be allowed.

Grade III : External and internal changes, adaptive re-use, extensions, additional buildings in same plot, but harmonizing especially in height and façade, are permissible. Reconstruction is allowed when building is structurally weak

Heritage value of Hussain Sagar

Mohammad Quli Qutub Shah founded  Hyderabad in 1591 on the banks of Musi River. The city has a glorious tradition of tanks and lakes. Hussain sagar  links Hyderabad with Secunderabad with a bund, known as the Tank Bund, which is  2.5 Km long. The  bund was built even before the founding of  the city Hyderabad and the Charminar.

The excavation of the lake was carried out in 3 years, 7 months and 19 days from the date of commencement.

Sultan Ibrahim Qutub Shah-II asked his son-in-law Hazarath Hussain Shah Wali, who was a great Engineer of that time to construct a Palace, a Mosque, a Garden and a Tank. The people of the city called this water body  Hussain Saab Cheruvu. Subsequently on completion of the tank, the Sultan named it after his son-in-law Hussain Sagar. The characteristic features of this bund were its stone masonry construction, its  architectural design and shape ,its butterfly sluices with provision for automatic outflow of surplus water..

The first source of water supply to Hyderabad is Hussain Sagar Lake. The Lake was constructed in 1562 AD on the Tributary of Musi. It covers an area of 8 Square Km. In 1891 a Slow sand filter was setup in Narayanaguda and the lake was used to provide Drinking Water. The water of Hussain Sagar Lake was sufficient for the people of Hyderabad then. The first piped protected water supply to the city  was started from the Lake.  The old water pipe lines are still functional.  The water of this lake was used for irrigation as well as drinking purpose for over 350 years.

The area of this lake in the past was about 1664 hectares.  This area has progressively decreased to 350 to 400 hectares.

It is a treasure and heritage water body which connects Hyderabad and Secunderabad cities. That’s why they are called as twin cities.  One cannot think of twin cities without Hussain Sagar Lake.

The lake is an ecological asset to the twin cities as its water spreads not only caters to the water needs of the twin city people but also charges ground water in the areas around it.

The water of this lake served the drinking water needs up to around 1930.  The water was reasonably good up to 1976 with rich aquatic life.  Birds from Europe used to halt in the lake in the winter season during their migration to the southern region.

Shrinkage and pollution of the lake.

Man-made damages to the lake.

Why the Lake should be brought under the purview of Regulation 13(1)

The quality of Hussain Sagar water has gradually decreased during 20 to 30 years, mainly owing to the  continuous ingress  of  untreated domestic sewage and industrial effluents.

The Government has continued to fill up the lake areas to convert them to centers of commercial activities in the name of promoting Tourism/Ecotourism,  and a concrete jungle may come up in and  around the notified areas of Hussain Sagar Lake.  The citizens of twin cities will be denied the opportunity in enjoying the pristine beauty of this lake. The construction of the Necklace road across the lake has choked the flow of water to and from the lake and the surrounding areas. The road has created air and noise pollution and daily garbage. The construction of the ‘Eating city’ right on the banks of the lake and touching its waters is indefensible. The  natural rocks in the lake waters where hundreds of migratory birds from different parts of the country and also from outside the country  congregate, known as the rock island, is being converted to a park with recreational facilities and eating facilities.  Despite imposition of the High Court’s ban on permanent structures in the banks of the lake, such structures are being constructed. An Imax theatre has been constructed despite the opposition of the lovers of the Forum. Of late, the authorities , with Japanese funds, are trying to dredge the lake bed  but the problem is they have no proper disposal of the refuge but propose to dump it along the banks in the name of making a pathway along the lake, thereby further reducing the size of the lake against the Court’s order.

Previously, the lake abounded in fishes. Today, the water is so polluted that not a living creature can be found in the lake.

About six  authorities are now involved in activities around the lake, namely, the tourism department, HUDA, the Buddha Purnima authorities, etc. This is hampering an integrated view.

We consider, the only way to prevent further shrinking and deterioration of the lake, and to restore and conserve its environment,  is  to bring it under the purview of Regulation  13.1 of HUDA Zoning Regulations, 1981, and declare the Lake as a Heritage structure in category 1 and its demarcated surrounding areas as a Precinct. Thereby, an expert body like the Heritage Conservation Committee appointed by the state government can look into the heritage aspects and can recommend a heritage-centred development and  tourism.    Side by side the environmental aspects can be taken care of by involving the pollution control board, which should be an autonomous, statutory body like the state vigilance commission.

Thanking you,

Yours sincerely,

                                                                                  (VEDAKUMAR.M)

                                    President

Forum For A Better Hyderabad

Encls:     1.  Xerox copy of  old photograph of Hussain Sagar.

                                 2.  Xerox copies of 4 old maps of Hussain Sagar.

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