Memorandum of 22/05/05 in response to press notice of 07/05/05, published on 16/05/05, inviting views for examination of Sjsry by Lok Sabha standing committee on urban development

Sir,

I am qualified development planner, researcher and trainer. In 1993-94, as consultant to the (Indo-Dutch) Indian Human Settlements Program, I prepared its training manual and ran its programs on ‘Action Planning for Urban Poverty Alleviation’ at Human Settlements Management Institute (HSMI, R&T arm of HUDCO) and Rajasthan Institute of Public Administration. In 1995-96, as HSMI Senior Fellow, I ran programs on this, among other areas, at HSMI and at UP Academy of Administration. Shortly after SJSRY was announced at PM’s urban poverty conference, a national event that HUDCO-HSMI facilitated in 1996, I left HSMI on differences about its approach to training as an activity unmindful of impact and near abandonment of research leading to endorsing rather than informing policy (SJSRY marking in programs that it subsumed modifications contrary to what training feedback pointed to being a case in point). In 1996-97, as Senior Consultant assessing urban poverty impacts of DfID’s slum projects in Vizag, Vijaywada and Indore, I found startling problems and the all-round refusal to acknowledge or rectify these led me to quit mainstream consultancy and, later, to protest extrapolation of these flawed paradigms to policy. Since 1997 I have worked as consultant to, among others, enterprises pursuing enforcement of statutory development frameworks (eg, mandatory Master Plan provisions for space for informal sector units, workplaces for urban village communities, industrial units, cultivation and dairying activities, etc) and, where such frameworks do not exist or are inadequate, demands for their articulation (eg, for community-owned tourism in consonance with development and conservation goals in hill, coast and urban areas).

I mention all this to clarify that this memorandum arises from a considered view as a development expert, viz, that so-called poverty alleviation schemes, unless embedded (via action planning) in statutory development planning frameworks, are inherently incapable of meeting development goals and run against the constitutional goal of growth with equity that development planning law operationalizes through equitable allocation of development resources (while so-called poverty alleviation schemes seek to, in effect, condone rather than rectify unlawfully inequitable development under the garb of ameliorating its symptoms).

I am aware this view has no space in emergent consensus on “double digit inclusive growth” that, with reform to all but abandon planning law to permit duality in interventions (for poor and rich) by de-linking urban poverty alleviation and urban development argues – with practically no counter-argument from professions or politics – for substituting equity with targeted “inclusivity”. I am not presuming to press here a counter-argument and the foregoing is only stated as the context in which I wish to place on record the following:

  1. Apropos SJSRY training, with nodal role for HSMI, SJSRY training funds were perhaps invested in fixed deposits to make HSMI ‘independent’ of HUDCO. No assessment of HSMI’s SJSRY training has been made and HSMI is making some evaluation of SJSRY.
  2. Apropos SJSRY skill development, HUDCO’s Habitat Polytech wound up in 2003. Before that it was training construction workers through a union, partner in Narela Building Centre. None of the massive construction in Narela by DDA, etc, was contracted to the Building Centre; Delhi Government’s DSIDC started a rival building-centre type project; and NIUA was advocating training for jobs in yet to shift industries. No assessment has been made of worth of SJSRY skill development vis-à-vis such missed job-opportunities.
  3. Apropos SJSRY research, a study on street vendors was commissioned in 2002 through HSMI to School of Planning and Architecture, while MoUD Task Force constituted a drafting committee headed by HUDCO CMD to make national policy. These initiatives ignored significance of a statutory solution (of space in markets, etc) that Parliament had approved in Delhi Master Plan in 1990. In 2003 SPA, HSMI and HUDCO chiefs were all relieved. In 2004 NDA cabinet approved the policy (20/01/04) and MoS circulated it to CMs for adoption (19/02/04). Under UPA, ministry letters to Chief Secretaries listed it among second generation reforms under URIF (15/06/04) and sought status of action taken (12/08/04). In 2005 MCD-NGO project, under supervision of the SPA Professor who supervised the SJSRY study, to “pilot” the policy through a roadside market for 150 hawkers stands challenged in court by residents of that (low income) housing area. No assessment has been made of implications of such SJSRY studies / policy-support.
  4. Apropos SJSRY implementation through network of community based organisations, the assumption that structures expected from broad-based UCD / UBSP interventions would also be triggered by SJSRY has failed. There is no evidence of independent community structures and most poverty alleviation investments are NGO mediated, even as the assumption that such intermediaries reduce capture is not borne out by micro studies that also throw up evidence of extra-constitutional regulation as well as capturing of other public resources in name of ‘facilitation’. In the afore-mentioned “pilot-project”, for instance, hawkers are contributing 50 lakhs for rehdis/stalls and 10 lakhs per year for license and other charges – while the ‘facilitating’ NGO has 35 lakhs from MPLADS, more from tax-free donations and whatever it makes from arbitrary annual collections. No assessment has been made of such unanticipated implementation mechanisms.
  5. SJSRY convergence with slum programs for actualising wage employment and micro-enterprise benefits (in, respectively, slum improvement works and in-slum units) is legally flawed as slum programs are ad-interim and in-slum investments are wiped out with slum clearance – which is most unfair to micro-credit/enterprise ‘beneficiaries’ since their private investments are wiped out too and can also be additionally problematic, such as when families are declared ineligible for resettlement on grounds of being non-residential users for running duly facilitated home-based enterprises. This convergence is equally detrimental to slum policy goals, since it diverts investments from the solution (low-income housing) to the problem (in-slum investments), while necessary land is lost in the unnecessary diversionary delays. Urban poverty alleviation interventions evolved (or, rather, drifted away in the last decade) from slum interventions, but no assessment has been made of why they were preferred to holistic shelter solutions embedded in law and encompassing a full gamut of socio-economic/livelihood, socio-physical/infrastructure and socio-political/community rights
  6. In general, SJSRY thrust on micro-credit, etc, has served to supplant the space allocation thrust of planning law. In the capital, discourse spawned by SJSRY study and policy on street vendors has come to fruition in the proposal to abandon in Master Plan 2021 their space in markets, etc. Amidst closure of small / tiny industries in wrong places only because space for 1 lakh units is being diverted for profit, skill development and micro-credit for industries continues. Amidst all-round enabling of eco-enterprises, traditional communities in riverbed and ridge faced summary eviction in 2004 for commercial projects and eco-tourism parks run by NGO/private enterprise and several ‘migrants’ from Uttranchal (in whose name Tehri water is claimed as Delhi’s right) face eviction in Delhi and, back home, offer of micro-credit for marginal livelihood in their eco-tourism economy whose control is on offer to NGO/private enterprises anywhere. No serious assessment has been made of implications of the drift from control of economic resources to fringe livelihood benefits that the micro-mini-credit/enterprise thrust has spawned, not even to extent of estimate of the cost of entitlements, notably to use of land, with which the poor have paid for paltry investments for ‘alleviation’ of their poverty.

When it was launched SJSRY had seemed to cautious experts a less than fully considered scheme and less a scheme than scheme-dressing for decision to de-link urban poverty and urban development, already institutionalised by bifurcating the ministry into two departments on 08/03/95 – one for urban development and one for urban employment & poverty alleviation. (On 09/04/99 the two were merged back and on 16/10/99 the ministry split into two; on 27/05/00 the two were merged back and on 27/05/04 split again). A decade later the hypothesis that SJSRY was not intended as synthesis of prior schemes but as dilutor to facilitate a paradigm shift fits well the reality of continuous failure to address reservations about the de-linking paradigm and recurrent hype about its patently defunct flagship scheme.

Between issuance on 07/05/05 and publication on 16/05/05 of Standing Committee’s press notice inviting views on SJSRY (of which at least IIPA and HSMI are making / have made purportedly independent evaluations), on 13/05/05 PIB issued a PMO release saying, in section on SJSRY, “A Task Force under the Chairmanship of Secretary (UEPA) has been set up in the Ministry with the objective to evolve a viable micro-credit mechanism for the urban poor/informal sector”. Earlier PMO had issued a release about the national commission for informal sector constituted on 20/09/04, in Ministry of SSI. Meanwhile, MoUD / MoUEPA have not cared to address reservations expressed since 2001 about Task Force, etc, making national policy for street vendors, not even in court matters or while clearing Plan modifications regardless of statutory Public Notice responses raising these issues. Nor have they cared to initiate action against “pilot-project” being illegally developed in name of their policy, not even after residents of employees’ housing under MoUD’s own care have challenged it in court. MoUD / MoUEPA communications about this policy were addressed to Chief Secretary (to whom was also addressed a CVC reference of 10/09/04, also copied to PMO, for action plan in context of the Master Plan solution), but it was MCD that “adopted” the policy first in 2002 before cabinet approval and then on 27/10/04 and has issued a curious Public Notice about this, only on 22/05/05, perhaps in reaction to a challenge to its NGO “pilot-project” raised on 17/05/05 in the matter still pending in court. Memoranda about this policy drift were submitted to Standing Committee (in response to press notice of 16/06/03, inviting views for examination of DDA) by hawkers themselves, not mentioned in the list of invitees for hearing on 30/05/05 that is annexed to your letter of 18/05/05 for that.

Amidst such hopeless anomie, I am only taking this opportunity to place on record an expert view on SJSRY that has existed for as long as SJSRY has.

Yours truly

Gita Dewan Verma, Planner