Earlier this month, the Union cabinet issued its approval for the Adani Group to construct rental housing for slum dwellers on 103 hectares of marshy tracts in Mumbai that were used to produce salt.

Adani’s Dharavi Redevelopment Project aims to rehouse 6.5 lakh residents who live in the 2.5-sq-km precinct that is considered to be one of the world’s largest slums. It is a joint venture between the Maharashtra government and the Adani Group.

The salt pan land will be used to provide rental housing to Dharavi residents who are “ineligible” to get free homes because they are living in tenements that were built after the cut-off year of 2000 set for beneficiaries.

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This cabinet’s decision has been criticised both by the Opposition parties and environmentalists.

Shiv Sena (Uddhav Balasaheb Thackeray) leader Aditya Thackeray declared that construction on salt pan land would “ruin Mumbai”.

Environmentalists too have long warned against such a move. Salt pans are part of a contiguous ecosystem of wetlands and mangroves that act as natural buffers against floods in Mumbai – a city prone to waterlogging, said Debi Goenka, an environmentalist and the executive trustee of the Conservation Action Trust.

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Salt pans occupy 798 hectares of Mumbai’s total area of 45,828 hectares or 4,355 sq km, according to the Development Plan 2014-’34, which lays out the blueprint for all development in the city.

Officials claim that using these low-lying areas for government housing schemes and slum redevelopment projects is essential if the residents of the congested city of Mumbai are to be provided adequate housing. According to the 2011 census, more than half the city’s residents – over 52 lakh – live in informal settlements

Among the advocates for construction on salt pan land is Maharashtra Deputy Chief Minister Devendra Fadnavis. “It is very clear that if we do not properly utilise salt pan lands, Mumbai’s redevelopment will be impossible,” Fadnavis said in March 2023.

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As the dense, coastal city of Mumbai struggles to find space to house its 1.24 crore residents, the Maharashtra cabinet early in August had approved a policy to allow homes for persons displaced by infrastructure projects to be constructed on salt pan lands.

To even the casual visitor to the city, the construction of infrastructure projects is visible everywhere: metro lines and link roads are being built in several places, even as roads are being widened. In the space-starved city, this involves demolishing perhaps thousands of homes – though the authorities do not have a specific number yet.

But the decision to allow construction on salt pan lands is controversial. Several parcels of such land lie in the Coastal Regulation Zone, where new construction is not allowed up to 500 metres of the high-tide line.

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Even the Mumbai Metropolitan Region Development Authority, the Maharashtra government body responsible for preparing plans and monitoring key projects, acknowledged in a report that salt pans protect the city from being swamped during high tide and serve as a drainage area during the monsoon.

Mangroves along the Vashi Creek. Credit: Rudolph A Furtado, in public domain, via Wikimedia Commons.

In an assessment report in 2022, the Intergovernmental Panel on Climate Change, a United Nations body, warned that by 2035, the city will be at even greater risk as sea levels rise. It ranked Mumbai second among the 20 largest coastal cities that will incur major economic losses due to flooding and sea level rise by 2050.

Instead of building on salt pans, experts have suggested other solutions. For instance, Deepti Talpade, programme lead of urban development and climate resilience at the WRI India research organisation, contended that the challenges of public housing could be resolved by allowing “in situ” development for existing slum areas – to rebuild on the same plots on which they stand to provide better infrastructure services, rather than displacing residents.

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She said that vacant plots of government-owned land could also be used for the purpose. After all, she noted, the land occupied by salt pans is too inadequate to resolve city-level housing shortages.

Housing demand, available land

According to the 2011 census, the number of slum households is nearly 11.01 lakh of the 26.65 lakh households in the city.

Mumbai’s Development Plan 2014-’34, which projected the population in the city to be 1.28 crore in 2021, estimated that the city would need 10 lakh affordable tenements by that year.

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Of the total, it said 3.5 lakh units would be required by the economically weaker sections, or those with annual incomes of up to Rs 3 lakh. Low-income groups with an annual income between Rs 3 lakh and Rs 6 lakh would need 3.5 lakh units. Middle-income groups, whose annual income ranges between Rs 6 lakh per annum and Rs 18 lakh, would need three lakh units.

To build these units, an estimated 1,475 hectares of land would be required. Crucial to this plan is granting a floor space index of three on these plots. The index refers to the ratio of the total built-up area permitted on a plot of land to the area of the plot itself.

This means that if the floor space index is set at three by the government, a 1,000-square-foot plot could accomodate a structure with a built-up area of 3,000 square feet.

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The floor space index currently allowed in Mumbai for general development is two and for slum redevelopment projects it can go up to four.

The development plan has earmarked 130 hectares of salt pan for affordable housing.

Credit: Reuters.

Need for a buffer

Attempts to allow construction on salt pan land in Mumbai have a long history.

In 1995, when the Shiv Sena was voted to power in Maharashtra, its government launched the Slum Rehabilitation Scheme, allowing private players to get involved in slum rehabilitation projects. As an incentive, these firms were granted extra floor space index, which could be used in other construction projects.

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In 2007, the Congress government made a representation to the Centre to allot 2,177 hectares of the salt pan land to rehouse project-affected persons.

In 2015, the Fadnavis-led Bharatiya Janata party government in the state appointed a committee to prepare a draft policy to enable the government to use salt pan land for housing projects, slum rehabilitation and infrastructure development.

These proposals did not make any headway.

In 2015, media reports said the Maharashtra government had approved a proposal to open up salt pan land for slum rehabilitation and construction of affordable houses. The draft Maharashtra Housing Policy proposed that year said the state’s Slum Rehabilitation Authority would propose that Centre exclude salt pan land from the Coastal Regulation Zone.

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The matter remained unresolved until 2016 when the Mumbai Metropolitan Region Development Authority established in a report that barely 10.1 hectares of the city’s salt pan land is suitable for housing – 1.25% of the total.

The survey had found that it was not possible to build on large swathes of salt pans as they were either designated as wetlands, covered with mangroves or under litigation and title disputes.

However, after the Union Ministry of Environment and Forests revised the Wetlands Conservation and Management Rules to exclude salt pans from wetlands in 2017, a new survey was started to assess if development could be carried out on such land.

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The findings of the survey are not in the public domain, but in February, the Maharashtra government approved a proposal seeking 283 acres, or 114 hectares, of salt pan land from the Centre for the redevelopment of the Dharavi area.

Dharavi residents during a demonstration against a redevelopment plan, in Mumbai in June 2007. Credit: Reuters.

Dignified housing

But experts in planning, ecology and urban resilience and those who study the Slum Rehabilitation Authority’s work in Mumbai have been sceptical of such plans.

Prasad Shetty, a founding member of the School of Environment and Architecture in Mumbai, pointed out that in the nearly 30 years that the slum rehabilitation scheme has been operational in the city, it has done little to solve the housing shortage.

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When the scheme was launched in 1995, the Shiv Sena government had promised to relocate 10 lakh slum households to multi-storey buildings. However, till 2022, only 2.36 lakh units had been constructed under the scheme, Citizen Matters reported.

Even the structures that have been built do not afford a dignified life to residents, said Shetty. This is because these buildings are packed together too tightly to give residents adequate sunlight and fresh air. The units are also simply too small for families to live comfortably, Shetty pointed out.

Several reports have found that the slum rehabilitation buildings in Mumbai do not meet National Building Code standards. The standards require buildings to have a minimum of 150 lux, the measurement of the total amount of light that falls on a surface. But he rehabilitation homes get only 112-120 lux, according to a 2017 study by the Environmental Policy Research Institute.

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The same study also showed although the building codes prescribe a minimum wind speed of 0.25 metres per second inside homes, the breeze in these homes was negligible.

A year-long study, carried out by the non-profit organisation Doctors For You in three rehabilitation clusters in the city’s eastern suburbs from September 2017 to December 2018, showed that cramped houses and lack of daylight and ventilation led to the spread of the tuberculosis bacteria. “I cannot fathom which government would push people towards those living conditions,” said Shetty.

He also said that the resettlement and rehabilitation programmes in the city have garnered the reputation of being designed to benefit real-estate developers rather than the actual residents.

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Both Shetty and Goenka suggested that the authorities should focus on providing better infrastructure services in existing slum areas rather than pursuing plans to construct rehabilitation settlements on salt pan land.

“A more reasonable solution to the problem is the government extending a generous hand for repair and retrofitting of the current structures,” said Shetty.