Bengaluru’s draft Comprehensive Mobility Plan 2019, published by the BMRCL and DULT, has come under attack for several reasons, primary among which is its reliance on faulty and outdated data. The document is problematic from several perspectives – legal, technical, financial, and also in terms of sustainability.

1) Any successful travel demand model (TDM) must understand the people’s daily travel pattern (origin-destination), and their preferred mode of travel. Past TDM projects have identified the TAZs (Transportation Analysis Zones) without considering the economic strata of the public.

In other words, they mix up different sections of the society which have distinct travel preferences: The poor section rely on Atal Sarige or concession pass for survival. The middle class prefers the economy of the ordinary buses. The upper middle class can afford rides in metro and Volvo buses. 

But, as a result of this omission, the ‘modal split’ step becomes void, and the results become questionable. 

2) The data used is more than a decade old. We cannot assume that the same data is applicable today, even with some projection, because the city has not grown uniformly: Much of the growth has happened in pockets, which changes the travel patterns asymmetrically. Rather than wasting time in projections, it is best to collect data afresh.

3) The data spans across several years. Not only is the data old, it comes from different years. It is like a doctor trying to diagnose the patient by reading medical tests that were conducted over multiple years.

4) The data was originally collected by different agencies for different projects and purposes. Each one would have specific assumptions and omissions, which cannot be ignored when such data is combined. The CMP, however, recklessly combines the data without any restraint.

5) The sampled areas are representative of the whole city. Some readings were collected from small localities, which are not representative of the entire city. For example, the household survey sample was 0.4% (ref: p92); which is too small to assess the income levels and travel mode preferences in a given population. A sampling strategy must be drawn up to decide how many samples to draw from which area.

6) CMP refers to different areas under a common name. Since the CMP copies the data from various past studies, the “study area” is different in each case. But the CMP uses a standard expression “study area” throughout the document. Worse, it does not show the study area on a map. 

This creates a total confusion as to how the study area is related to the whole city, plus the two new areas with leapfrog development (BMICAPA and BIAAPA). 

7) This collage of data is not strategy-based. A CMP should lay down a well-laid strategy based on data, and translate the strategy to well-coordinated actions by different agencies. Instead, this document is a collection of disparate efforts made by different agencies, and even business startups! In this, it resembles a city guide!

The CMP refers to data collected for RMP 2015 (very old and outdated data), coupled with a collage of fancy projects mooted by various ministers in newspapers. (only the most farcical announcements were omitted, such as pod taxis and air ambulance.)

Also, the “base year” itself is not clear: Is it 2015, or 2019? Based on what is the “base year” counted? (note that each of its constituent studies had their own base years. But CMP cannot claim any of them as its own base year!) That is why CMP must make a fresh attempt to collect the data and analyse it.

8) The CMP ignores some basic ground truths. For example, 

1. Out of the 40,000 intersections in Bangalore, only 1000 have signal or peak-hour manual intervention. The other 39,000 intersections are uncontrolled. How is that problem to be tackled?
2. The private sector buses, mini-buses and vans outnumber BMTC by a factor of 5. And yet they are totally ignored. The CMP does not propose any regulation for them.
3. Social media technology has made car-pooling possible, where even affluent class opts for pooling of their cars. This trend is neither acknowledged, nor explored.
4. The rented scooter business has found traction in the city. But the CMP has not provided for any parking for them. The users would have to abandon them on the main road, causing congestion and accidents.
   

Is the CMP valid at all?

The CMP is a case of the tail wagging the dog! The Metro was supposed to be launched in Bengaluru, based on a Comprehensive Mobility Plan. But Metro was launched without CMP. A substantial amount of planning is already done and executed, without taking into account how it integrates with the other modes of transportation.

So, when this state of affairs was challenged in a PIL filed with the Karnataka High Court, the BMRCL had to respond; as it was found stranded at the gate.

And so BMRCL did prepare the requisite document, but post-facto. This is like shooting first, and then painting a bull’s eye around the bullet hole!

Worse, BMRCL prepared the CMP despite the fact that it is only a SPV formed to handle the metro assets separately from the main parties of the JV, and so it does not have the authority to prepare the integrated plan for the whole area, or on behalf of the other agencies who handle the other transportation modes. 

The other direct mobility partners, such as BMTC and suburban rail, were not involved; nor were the association of private bus and cab operators. In addition, the other stakeholders (BBMP, BDA, BWSSB, BESCOM, etc) were not involved in authoring this document at all; although they have a direct role to play in implementation of this CMP.

The net result of all this is that the CMP is not a legally valid document.

Urban planning:

1) The entire proposal requires the city to become a high-density urban cluster, from the current 4381 persons/km2 to 40,000 persons/km2 (which is 9 times denser). That will make us the second-densest city in the world after Manila.

Are we ready to accept that our living spaces will shrink by a factor of 9? How will BWSSB cater to such a high-density population (water and sewage)? A similar proposal in Pune was shot down due to this specific reason.

2) The “TOD” idea is misrepresented in the CMP. The CMP relies upon the theory that a highly dense city area built along an efficient mass transit route will entirely rely on that transit system, and the residents will shun all other modes of transport.

Also, this strategy calls for a lifting of Floor Area Ratio (FAR) restrictions in those areas. This will attract developers to those areas. They will build far taller and denser buildings (in theory there is no floor limit). More population density means more cars and two-wheelers in a given area. 

But is this theory correct? 

3) The TOD area does not automatically discourage private transport. Our bye-laws must have a separate provision for the TOD areas, to make it far more expensive to own private transport there. Also, they must impose a far higher daily congestion fee to all private vehicles if they enter a TOD area. But this is not done. 

4) The theory won’t work for most of the existing areas in Bengaluru. Even if skyscrapers are allowed, they won’t come up in significant numbers in the vast army areas, the city core area, and the urban sprawl between IRR and ORR.

Even if a few skyscrapers come up in a given area, they won’t bring the projected benefit: To get the benefit of TOD, the entire area must have skyscrapers. On the contrary, if only a few skyscrapers come up, they will add to the existing congestion.

The only place where TOD can work is in virgin areas, outside the current city limits. 

5) Implementing TOD in new areas does not solve the city’s problem. Even if the new population growth happens exclusively in the new TOD areas, the existing BDA area (741 km2) will still continue to have congestion. And the new population would have to travel to the old city for work (ITPL, Electronic City, ORR, Sarjapura Road), which would cause new congestion!

6) Mixed land use may not mean short travel-to-work! The TOD policy encourages mixed land-use: Building homes and workplaces close. But most nuclear families have working couples, and 1-2 children who go to school or college. It is very unlikely that all of them find a workplace or educational institute that are in close vicinity. 

7) Why are the leapfrog development areas being absorbed under a pretext? A leapfrog development is an out-of-turn development of areas that are far from the city center. The CMP calls for greater densification (by 9 times) of the existing city. The densified area will need much more water and electricity. They will also generate much more sewage. Thus we will be forced to revamp our water, electricity and sewerage systems by a factor of 9. This is a huge commitment, which needs a huge amount of debt.

But then CMP proposes to incorporate the BMICAPA (NICE corridor) and BIAAPA (KIA) areas in the proposal. Thus an unfair advantage would be passed on to the new areas, for which the city has to take on a debt.

Note that when the ciy is unable to pay for extravagant development, the entire city suffers, as in the case of Detroit. In fact, several articles show a close relation between Detroit’s municipal failure and its mobility plan disaster.

Here are some case studies:
Link1, link2, link3, link4, link5, link6, link7

That lesson should not be lost to us! 

8) The CMP does not prove that the Metro will achieve the mandated 14% economic internal rate of return (EIRR). The metro project is mandated to achieve a minimum EIRR of 14%. This is a prerequisite, without which the plan cannot be accepted.

Note that EIRR must be calculated over a long term (next 30 years). Metro will need to replace aging trains every few years, at a huge cost. That cost also must be added to the EIRR.

The CMP does not provide any such calculation or justification.

In other words, the Metro project is likely to be a huge liability for us. How can we accept a project without checking whether it will pay for itself?

Financial grounds: Who foots the bill?

The total cost of the CMP, if implemented, is Rs 2,20,104 cr. But the CMP proposal does not project any revenues, break-even period, etc. (This again shows the lack of in-depth planning, or the hurry in which it was prepared to meet the court deadline.)

Typically, these projects cannot pay for themselves (they cannot generate enough revenue to pay back the original principal + interest). So, any agency that pays for these schemes will have to write off the loan later.

Note that this cost is related to only the mobility plan and not for utilities (electricity, piped gas, water supply and sewage) for the newly densified population is not included. CMP cannot disown the indirect costs by fancy accounting tricks.

What’s more, the agencies themselves are already bankrupt. BWSSB is deeply in the red, and cannot pay back its current debts. The lenders are violating laws and financial prudence by not calling in the outstanding amount.

The BBMP is unable to pay its vendors for 2-3 years, or pay its telephone bills, or pay the wages of its pourakarmikas PKs. So how can they take up such an expensive project? The lifecycle costs over the next 30 years, when the infrastructure ages and needs repairs/replacements. We have just woken up to such costs after the activists took BBMP/BDA to court on maintenance of flyovers. The agencies themselves had no clue.

Let us examine the likely sources of such big lending:

• International lenders like JICA: 

Japan has negative interest rate, so JICA can lend us money at “low” rates, and establish monopoly of Japanese firms on our projects. This serves the Japanese interests well. But this will definitely lead us to a Greece-like situation, where heavy borrowing was done for worthless projects, but no one objected during the boom days. In our case, the Metro project has not proved its worth (that is can generate the prerequisite EIRR of 14%).

• Government of India

Only four cities have job growth in India. Bengaluru is one of them. That means we cannot hope that other cities (or rural folks) can pay for our extravagance. Neither can the GoI sponsor such a scheme. In fact, GoI has imposed the 14% EIRR precondition to ensure that the project is worth the debt (which we are not proving).

• Government of Karnataka

Bengaluru earns 40% of the GSDP. That means we are the major earner for the state, and we are expected to be self-supporting. We cannot borrow from the rest of the state. This means GoK cannot lend money to us. If that happens, know that someone is re-routing our own money at a stiff interest.

• PPP project

People are often lured with this magic mantra. But the investor here will make sure that the user pays for it. Bangaloreans must be careful against the obfuscation of the source of funds in the name of state or central loans and grants; or the recipient being an SPV rather than BBMP.

Would we take on such debt on a personal basis?

The debt to raise money for the CMP amounts to Rs 1.8 lakh per person. A family of four has to pay off 7.2 lakh. As about 50% of Bangaloreans cannot pay such debts due to poverty, the remaining public has to underwrite the debt. Thus the debt level rises to Rs. 15 lakh per family.

This figure does not even take into account the old debt we already have (through BBMP and BWSSB, etc), and which we are unable to pay off. Are we personally ready to accept such debts? 

The proposed costs are a rip-off! Metro should be scuttled at this price-point!

The estimated cost of the project is atrocious! (ref: pp 26-28). All items are overpriced by a huge margin. If the project cost is inflated like this, the target earnings would skyrocket, which in turn would force Namma Metro to set its ticketing prices (and real-estate rentals) too high to be sustainable. Then Metro would have to be scuttled in its infancy.

So the question is, how was Metro able to even launch the multiple phases if this level of profitability is not projected? Was it by ignoring the >14% EIRR condition?

CMP contains hitherto rejected ideas

1) The CMP is based on outdated data and failed ideas rejected in the past. For example, the Elevated Corridor idea was dropped after technical objections were raised. However, it is still included in the present collage.

No attempt is made to justify the components. Even more ridiculous ideas were mooted like helicopter ambulances, air taxis and pod taxis, without any regard to their viability. Are those projects finding rebirth under this umbrella scheme?

2) When the city is allowed to be densified by a factor of 9, the various forms of illegal constructions may be legalised unfairly. In other words, this would be the mother of all Akrama-Sakrama schemes.
Note that there is no easy way to detect which building has weak foundation (including earth compaction), or whether the foundation and RCC structure can withstand the load of the extra floors. 

Missing the ‘how’ 

1) There are no specific steps to achieve densification at the cost of urban sprawl. In the western idea of “urban sprawl”, people prefer to live in suburbs in large villas with no vertical stacking. Providing basic amenities to such spread-out dwellings is expensive (electricity, water, gas, steam, etc).

In India, we have urban ghettos, in which the houses are stacked to 3 floors. Typically, they are build wall-to-wall, with no provision for off-street parking. The rampant on-street parking block all public roads, and make public transport impossible.

Over time, such buildings house unlicensed commercial activities (including factories), posing danger to the entire neighbourhood, and causing unregulated pollution. The on-street haphazard parking and storage of combustible/toxic material make them a ticking time-bomb (Example: Chikka pete, Balepet, etc). The CMP does not attempt to tackle this Indian “urban sprawl”, by regulating land use, parking, mobility, etc.

2) There are no specific steps to encourage compact city with mixed land use

The CMP talks about making the city compact by introducing mixed land use.The very idea behind having a “mixed use” model is required for meeting all needs locally, so that people don’t have to travel far out in the city for their needs.

The clear implication is that such establishments must remain strictly local, and not cater to outside population. For example, if a restaurant becomes popular, people from all over the city come to dine there. This creates congestion and parking problems, not to speak of noise problem, and even law-and-order problems. Some businesses need clients from all over the city even to survive. For example, pubs, large hospitals, large hotels, etc. This distinction is not made in any “mixed use” land use policy. 

3) The mixed land use is not effective in reducing travel distances. In an ideal world, mixed land use policy creates job-places very next to residential areas, and so people don’t have to travel very far. The same applies to schools and colleges, which are supposed to be near the residential areas.

But in IT, there are two factors that defeat this idea: IT industry is concentrated in high-density pockets, away from residential zones. (ITPL, electronic city, ORR); The IT industry has a high churn rate, which means an IT employee would not be  settled at one place for multiple years. She is more likely to find her next job in another cluster. Thus she may have to travel long distance; and, in case of working couples, both partners may be working in different parts of the city. It is impossible to find a home that is always close to the workplace.

As regards education, there is absolutely no guarantee that your favourite school or college is near your residence. Thus education-based trips are bound to be long.

4) There is no road network to reach interior areas after densification. If the aim is to densify the city up to 40,000 people/km2, then we have to provide wider roads and metro tracks in the interiors of the city. But p30 of CMP does not show such a network that reaches deep inside the areas that are divided by the main corridors.

5) There is no reference to minimum guaranteed living standards. While the CMP ominously recommends a densification to 40,000 people/km2, it does not specify commensurate living standards.For example, research shows that a minimum of 9 m2 of UGS (urban Green Space) per person should be allocated, the CMP broadly hints at total annihilation of trees from the city, under the road-widening scheme and footpath-making scheme.

6) Worse, the CMP hints at wide-scale land-acquisition beyond the available road width (aka “Right of Way”) for most roads. This will surely lead to large-scale tree-felling, as a minimum of two lanes have to be created (in some cases, two footpaths also have to be created).

In the past, GoK had already mooted ideas that open spaces in Bangalore would be reduced. After a sustained public outrage, a lame explanation was produced, that “the government meant some other city, and not Bangalore.” BWSSB has not guaranteed 140 lpcd water supply to their consumers. In fact, they are at pains to explain that as they expand the network, the per capita water we get will go down.

So, when the CMP directly affects the standard of living, it should specify what are the new minimum standard that prevents the city from turning into a ghetto.

7) The basics are not settled in the proposal: Three main ways to mitigate congestion are ignored.

1. 1. Pooled car usage is desirable, but there is no provision to encourage HOV vehicles. (e.g. BPL does not allow car pooling)
   2. Private buses and tempos are not recognized as valid modes.
   3. Rented vehicles (bicycles and scooters) need extra parking across the city, which is ignored. 

8) There are no plans to ensure adequate road density. A lot of government land is encroached. A lot of roads that ought to be public property is locked up inside “gated communities”. The direct result is loss of road connectivity.

Compared to developing a new road, recovering such roads should be much easier. But that was never attempted. Neither is a list of such assets in public domain. And now this CMP avoids the recovery of crucial assets.

There are no plans to review why BDA “fails” to carve out a grid of roads from newly denotified areas. Why is the entire area gifted away to developers, and why are some least convenient roads accepted as alms? 

9) The CMP admits that all the currently planned measures won’t be effective!

Table on p. 17 admits that even after implementing all the currently proposed schemes, the BAU-DM model will yield a totally unacceptable results: The public transport share will slide from 48% to 36% (public transport will slip from ½ of all trips to ⅓ of all trips). Note that this includes the Elevated Corridor scheme, despite the fact that GoK had withdrawn the scheme after facing technical objections.

10) Doubling of BMTC buses won’t be effective, unless they are managed better. The following steps must be taken:

1. It is far cheaper and efficient to set the routes as per hub-and-spoke model; where the hubs are interconnected with high-capacity rapid transit links. 
2. Currently BMTC has “metro feeder” services that ply long distances, instead of covering lateral destinations from the metro line. BMTC is still not willing to cede the first-mile and last-mile connectivity links to private sector or other partners, which can operate in a rigorously regulated environment.
3. BMTC runs nearly empty buses for software parks. It has thus forsaken its primary duty to move the public. It must have a separate fleet for contract services, and then measure both fleets separately on separate metrics. If BMTC fleet is doubled at this juncture, it will be able to run many more empty buses on contract, and create a far worse congestion of BMTC buses in the city. Even at the end of the contract run, a bus has to deadhead for several km before it can join the normal service! 
4. Unfortunately, BMTC also enjoys the state’s monopoly on the city’s roads, so it can hide its inefficiency by misappropriating BPL lanes for itself, while private bus operators suffer discriminatory treatment from the state. Perhaps the biggest loser is the urban user, who uses these private services under duress.

11) CMP must deal with buses and IPT operated by private sector. The Karnataka government is guilty of turning a blind eye to private operators. Rather than regulating their operations, GoK lets them operate at will.

Finally, if someone loses limb or life, GoK pays a compensation out of taxpayer’s money, while grandstanding about its own generosity. How can this go on, despite a CMP? 

12) The CMP must acknowledge that roads are extremely expensive assets. When roads are so expensive, why are they not protected zealously, and insured? (CMP does talk about insurance).

Consequently, any encroachment of road (partially or fully) must be assessed at the same rate and the penalty amount (and jail term) must be commensurate. The CMP must bring an end to brazen loot of public property with money-back guarantee. If any public servant fails to protect roads assets under his care, or causes delays in the process, he must be penalised.

Fines for dumping waste or sewage have risen to lakhs, even though the cost of the property is far less. Then why do we treat our roads so casually?

13) A common CMP is not compatible with different bye-laws for BMRDA areas. On the one hand, the CMP professes to bring together all areas under one regime. It also states that land use and mobility are interrelated. If so, why do we have one CMP for the whole area and different land use policies for the BMRDA areas? How will one CMP fit six different sets of bye-laws?

Also consider that like the 110 villages, the peripheral areas will get absorbed in a multi-centric mega city. Then the differences in the land use policy will surface, and we will be forever talking about letting off “violators” if the constructions are dated before a target date.

We can understand if a ULB like Pune or Delhi has to deal with historic buildings and roads (usually, heritage items have to be preserved, so they cannot be modernized or built upon). But this lack of foresight is unacceptable in a modern, freshly built city.

Specific deficiencies in the CMP document

• We need a zoomable, high-resolution map
  The map on p30 shows multiple features, which can be only analysed if presented on a zoomable map, where we can selectively turn some layers on/off. A low-resolution A4-size map embedded in a pdf is too inadequate for the purpose.
  
• The plan must be binding to all participants; otherwise it is worthless
  Section 1.1 (p 32) is full of motherhood policy statements, which no agency bothers to follow, and no one is punished for non-compliance. These principles are never converted into standards, benchmarks, metrics, procedures, and inspection/audit checklists. Also, as long as they are not binding commitments, they are worthless. Some of the statements are so inane that they cannot be implemented at all. They are inserted in the CMP document as decoration. The rest of CMP has no derivatives from this section.
• Protection of lakes, wetlands and drains are not addressed
  In section 1.1.3 (p 33) (Environmental Quality), the CMP does not call for Protection of lakes, wetlands and stormwater drains (including their buffer zone). In practice, a lot of these assets are sacrificed for the sake of mobility or even access.
  
• The CMP does not comply with National Environmental Policy, 2006
  In section 1.1.3 (p 33) (Environmental Quality), the CMP does not call for compliance with the principles listed in the National Environment Policy, 2006.
  
• The plan does not show a viable scheme with EIRR >14%
  Section 1.1.4 (p 33) (Economic viability) stipulates that users must pay share of all costs with due consideration to equity concerns. That means non-users would be protected from paying for the infrastructure they are not using. In other words, the entire expense must be self-financed (with 14% EIRR) from ticketing alone; and not from subsidies or commercial income of the property created by Metro. But the plan does not show how to actually implement this.
  
• The plan does not address non-containerised goods movement
  In Section 2.2.6 (p61), the non-container goods are not considered at all! They have a huge logistics chain that involves getting the goods in the city, re-distribution and delivery. These vehicles create a significant amount of blockage in the city.
  • • White goods
    • Furniture
    • Consumer goods (FMCG)
    • Grocery
    • Vegetables and fruits
    • Solid waste
    • Water tankers
    • Cement mix and other construction material
      
• The plan does not attempt to reduce accidents even with higher speeds
  In Section 2.2.8 (p.62), the CMP just describes the road accident numbers for the city, and lists the most accident-prone areas in the city. This section also admits that the apparently low fatality rate is due to the fact that all roads are congested, and there is no scope for high-speed driving. However, the CMP does not identify the strategy plan to achieve higher speeds with low accident rates.
• The plan promotes high-cost-no-benefit items like Elevated Corridors
  In section 3.1.4(c) (p114), the CMP admits that despite having the Elevated Corridor, the share of public Transport will slide to 36%. The congestion will cause bankruptcy of BMTC. Then why should we have a big-ticket item like  Elevated Corridor at all?
  
• The income data must be analysed separately for each economic level
  The CMP p 92 shows average income for the city. However, just one figure cannot define the entire city: The city has distinct pockets with different affluence levels (on one hand, we have UB City and Whitefield; and on the other other hand, we have Vivek Nagar). The income level influences the number and type of vehicles owned by a household. It also defines the preferred mode of transport. Therefore the income ranges and averages must be found for each pocket separately.
  
• Instead of expense for transport, the plan must talk of “share-of-wallet”
  The CMP p93 shows average monthly expense on transport. But like the previous point, this also depends on the mode of transport. Further, the same amount (e.g. Rs 2500/month) would put different levels of financial stress on the family, depending on their monthly income. Therefore, we should focus on “share of wallet” (monthly transportation expense calculated as a percentage of the monthly income). This will help in defining the ticket pricing strategy.
  
• Something wrong with the trip data!
  The per capita motorised trip rate is 0.91 (Ref: p93). Of those trips, 49.9% are return trips (ref: p94). If we put these two figures together, we get that return trips are made by 0.91/2=45% of the public. In other words, 55% people do not venture out of their homes? Or their trips are so small that they don’t count in the official numbers. Given the nature of the city, we would not have such a large percentage of home-bound housewives, or retired people. On the contrary, a lot of single working men and women live in the city. To conclude, there is a major problem with this data!
• No accounting for 36% of the air passengers!
  The CMP states that 64% of the passengers disperse through bus and car/taxi (p100). There is no auto option at the airport. So how do 36% of the passengers go home?
  
• Private operators get a raw deal!
  The government pretends that there is no private bus/van business in the city; despite the fact that they outnumber BMTC by a factor of 5!  The CMP was supposed to be the first document that acknowledges this activity; and integrates their operations with the government-run mobility agencies. (Their routes, frequencies and timetables should be compatible with BMTC, Metro and trains.) But the CMP misses that chance. Instead, it tries to palm off the unprofitable routes to private sector through auction. (Ref: point vii on p136).
• The ‘on-contract’ BMTC buses run nearly empty all the time!

Point xii on p136 recommends that BMTC should run chartered services for IT companies and garment companies. But most of the BMTC buses are run on long routes with very few employees on board; and they do not take up other passengers or pass-holders. Thus most of the BMTC’s carrying capacity is wasted during peak hours. Thus, by running a large number of empty buses during peak hours, BMTC creates congestion, rather than dissipating it!

After the peak hours, these buses are returned to normal service. But at that time, the demand drops sharply, and these buses end up running almost empty. Thus, most “on-contract” BMTC buses are run nearly empty during the whole day. This is criminal waste of the taxpayers’ money!

Even after doubling its fleet, BMTC proposes to increase its on-contract buses. This will completely wash out all benefits of the doubling the fleet!

• Fancy ideas that don’t have budget or owners

In section 4.2.2.1 (p.137), the CMP recommends that camera-based regulation system “should be” installed to prevent use of BPL by private vehicles. The words clearly indicate that this is just a fancy idea, and no agency has taken the onus to set up and operate this feature.

The ensite road network development (Section 4.3) and freight movement plan (Section 4.7) is full of such “high-level” suggestions. Most of this cannot be implemented for want of money. Let all the concerned departments make a budget for the listed items, and present this as a unified CMP implementation budget. If presented in piecemeal fashion, we will not be able to judge its viability.

All such ideas must be assigned to specific agencies for time-bound implementation, and the overall required budget must be declared in the CMP.