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Air Funnel Zone: Creating TDR out of Thin Air

Is creating TDR for restricted areas really resolving Mumbai’s housing crisis?

In July 2024, the Government of Maharashtra announced that the redevelopment of buildings affected by the air funnel zone is a significant issue in suburban Mumbai wherein, redevelopment is not feasible due to height restrictions. For instance, if a building can only have 30 stories but needs 40 for feasibility, the State Government grants the developer 10 additional floors through TDR.

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This Air Funnel Zone, designated to ensure aviation safety around airports during take-off and landing, has been in place in Mumbai at the now Chhatrapati Shivaji Maharaj International Airport since 1928 i.e. nearly a century, and virtually covers 50% of Suburban Mumbai including Vile Parle, Andheri, Kurla etc. ​In Navi Mumbai, virtually 65% area including Ulva, Chinchpada, Khandeshwar, Mansarovar are covered by the air funnel zone (Refer Fig. No.1)

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At UCM, we advocate for a balanced approach to Air Funnel Zones (AFZ) and Transfer of Development Rights (TDR). We are concerned about granting TDR for areas that were never intended for development, particularly in suburban Mumbai and Navi Mumbai. We believe TDR should be used more strategically to promote genuine growth in areas that require it most. Our goal is to ensure that development policies align with long-term sustainability and equitable urban planning.

Facts and Reports 

  • The Airports Authority of India created Colour Coded Zoning Maps (CCZM) which indicate permissible building heights within a 20 KM radius of civil aerodromes, using color-coded grids based on the area’s latitude and longitude.​

  • No buildings or structures over 150 meters tall can be built within 20 kilometres of the airport without permission from Civil Aviation Authorities;​

  • Under Greater Mumbai's 1991 DCR, TDR compensation was introduced for circumstances where land was reserved for public use, roads, heritage structures, housing for slum dwellers, and redevelopment.

Colour Coded Zoning Map of Mumbai and Navi Mumbai (CCZM), June 2016

  • No buildings or structures taller than 150 meters are allowed​

  • The restriction applies to areas within a 20-kilometer radius of the airport​

  • Exceptions require explicit permission from Civil Aviation Authorities

Issues/ Implications 

  • The Government of Maharashtra is generating TDR for land in an air funnel zone which never had any development potential as it was established in the 1930s, predating all surrounding developments.​

  • The same applies to the new airport at Navi Mumbai, as the land around it will have height restrictions.

  • The allowance for transferring TDR is absurd, as it will mean that TDR from nearly 50% of Mumbai’s suburbs and 65% of Navi Mumbai will now have entitled development rights which were not there to begin with;​

  • Further, the Government is also suggesting that the TDR can be used anywhere in Mumbai, hence, generating so much unwarranted TDR will only create a hyper-imbalance in the markets. Areas with high real estate rates will become sought after and areas which actually need housing will remain barren.

Research Questions 

  • What is the relationship between the TDR generating zone and the receiving zone so that they effectively operate in tandem to ensure a balanced and sustainable urban development?​​

  • Will the revenue generated from TDR sales be reinvested into public infrastructure, such as roads, utilities, and public spaces, so that the entire city benefits from increased development rather than just developers and private landowners?​​

  • How is the larger public benefitting from such TDR?

Strategic Framework

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  • Government Clarification required: Before implementing TDR regulations, the government should explain how it works, who benefits, the state's gains, and its impact on the area.​​

  • ​Sustainable Urban Development: Assess infrastructure and development patterns to align TDR with planned growth goals.​​​

  • Transfer of TDR: The areas where TDR is being transferred must be evaluated with clear rules, public disclosure, and third-party oversight for their ability to accommodate increased development.​​​

  • Assessment of current infrastructure: This includes water supply, sewage systems, road networks and social infrastructure like schools and hospitals​.​​​

  • Environmental Impact Assessment: Urban environment, Infrastructure strain, Public service capacity and Aviation safety risks â€‹â€‹â€‹â€‹

  • Policies aligned with Mumbai's urban planning goals: Balanced development, improved public infrastructure, sustainable urban growth

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© Urban Centre Mumbai, 2024 (Est. 2020)

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