“Comprehensive Mobility Plan ignores environmental impacts, sustainable solutions”

The Comprehensive Mobility Plan includes projects like elevated corridors and road widening that'll lead to further environmental degradation. It gives less attention to sustainable options like cycling and walking too

The draft Comprehensive Mobility Plan (CMP) 2019 is essential for providing a long-term vision for Bengaluru’s transport and mobility. But the plan gives little importance to the environment; it does not consider mitigation factors against the city’s depleting green cover, or steps to prevent the heat island effect.

On the contrary, a project such as the elevated corridors — which is included in the document — would only further environmental degradation. Walking and other non-motorised modes of transport are not emphasised enough in the CMP as well.

Besides, the process by which CMP was developed raises a fundamental question about the validity of the document itself.

The process behind CMP

Among the overall responsibilities of the UMTA (Unified Metropolitan Transport Authority) or BMMA (Bengaluru Mobility Management Authority), the CMP suggests preparation of the CMP itself. This being the case – which appears very appropriate – how can the current CMP be considered valid? This CMP must pass through the BMMA as soon as the latter is constituted.

Guidelines also mandate that broad-ranging consultations within government departments, experts, NGOs and civil society must be held both during and after the formulation of the CMP.

But the current CMP has been formulated without the constitution of the UMTA or even broad stakeholder consultations as mandated.

As citizens, we too support the constitution of an empowered UMTA (BMMA) and therefore would urge that this CMP be kept on hold. It is important to follow the process laid down, so as to establish a general consensus that paves for smooth implementation over the long term.

  • Primacy of environment in the CMP formulation:

A perusal of the CMP indicates that environment is not the central focus; the document does not address mitigation strategies in this context. This approach must be challenged and we submit that course correction be done.

The CMP does not take into consideration the resilience of transport infrastructure to rain and flooding. It is common knowledge that traffic breakdowns and gridlocks happen with regularity during heavy rains. The CMP must take this into account and make appropriate recommendations.

  • Current state of Bengaluru environment

  • Depleting green cover

An IISc study forecasts that, in 2020, the built-up areas in Bengaluru will exceed 93 percent and green cover will be reduced to less than 3 percent. In 1973, the green cover was 68 percent. The extent of reduction in green cover may be noted.

Another IISc study states: “Inventorying of trees show that Bangalore city has about 14,78,412 trees, which accounts to one tree for every 7 persons, compared to the requirement of 8 trees per person to sequester human’s respiratory carbon.” What this means is that there is no tree cover available to sequester the carbon emissions from vehicles that burn fossil fuels.

  • Urban heat island effect

The CMP must recognise and acknowledge that transport and mobility infrastructure and the use of fossil fuels in vehicles are among the biggest contributors to air pollution and climate change.

As concerned citizens, we would desire that the CMP notes the current state of Bengaluru’s environment and plan accordingly.The CMP must take into account any further preventable loss of green cover, and ensure mitigation of the urban heat island impact on account of the huge numbers of major projects identified.

  • Projects that must be reviewed on grounds of environment

The elevated corridor (costing Rs 18,480 cr) and road widening projects (Rs 19,200 cr) involve significant destruction of trees, and contribute to the urban heat island effect.

While the stated objective in the CMP is to substantially increase the share of public transport and also reduce the number of private vehicles through various policy measures, allocating such large amounts to projects that essentially cater to private vehicles appears contradictory.

  • Safety of Pedestrians

As per a report in Times of India, “Pedestrians accounted for nearly 40% of all road accident fatalities in Bengaluru in 2018, according to traffic police data. Some 276 pedestrians were killed in 2018, second only to two-wheeler riders. A total of 684 road fatalities were recorded in Bengaluru — with 29 pedestrian deaths being reported in December. The number of injured pedestrians stood at 1,220.”

The CMP lacks in its vision for pedestrian safety. A statement of intent would be “we will provide walkable footpaths and other infrastructure to citizens and eliminate pedestrian deaths on the road”.

  • Other specific observations on CMP sections

1.7 Stakeholder’s identification: It is not clear why the proposed suburban rail network is not included as a stakeholder. Along with the Metro (BMRCL) and buses (BMTC), suburban rail is a key component of urban mass transport.

2.5 Primary Traffic Surveys: In no survey is NMT-related data, such as the current state of footpaths and cycle paths, included. The survey data should include encroachments of different kinds (vendors, construction material, illegal parking etc) as well. ‘Strategy 5: Improve efficiency of road infrastructure’: The CMP states “A large part of the capacity of the road network in the city is blocked in unproductive and inefficient usage, due to improper planning as well as unregulated behaviours. Parking is a key culprit, taking up 25 to 50 per cent of urban road widths”.

While this is very relevant, the above does not take into account that with lack of or unusable footpaths, pedestrians are forced to walk on the roads (thus impeding traffic and putting their lives at risk). If this is taken into account, the capacity of the road network is further diminished.

In this background it is not clear how and why a substantial amount has been budgeted (Rs 19,200 crores across all project phases) for road widening projects. This approach is clearly shortsighted and indicative of misplaced priorities.

4.1.2 Transit Oriented Development Policy 2019: 

Considering that the population of Bengaluru is expected to grow substantially in the future as per numbers stated in the CMP itself, it appears impractical to imagine that 60 percent population will be concentrated around the TOD zone. There must be models to test and prove that TOD is feasible, before it can be even considered.

Therefore predicating the success and outcome of the CMP on the TOD model and allocating Rs 32,000 cr (Phase 3), appears premature and must be subject to further scientific enquiry and wider expert inputs. Also, it is not clear on what items this amount would be spent.

Forecast Modal Share (Option 2) (page 21):

It is indeed astonishing that modal share by NMT – cycling and walking – have not been taken into account at all. In fact, the IISc study estimates NMT modal share of 16.8 percent for 2030 and 19.3 percent for 2050. This in itself must be considered as completely short-sighted and lacking in vision.

Cycling and walking has not got enough attention in the CMP. File pic

Also, the scenario of 73 percent modal share of public transport under the TOD concept must be reviewed on these grounds.

9 Some ideas that do not seem to have been considered:

  • Decongestion of Majestic bus stand area
  • Shifting of agricultural markets from areas like Yeshwantpur, which has already been proposed

Additionally, the following need serious consideration:

  • Emphasis on walking and cycling Infrastructure (this is wholly inadequate in the CMP)
  • Defining car-restricted roads
  • Encouraging carpooling and high-occupancy lanes

4.12 Fiscal measures:

The CMP strongly argues in favour of curbing growth in private vehicles. Various measures for disincentivising private transport and pushing people into public transport have been suggested. Other welcome measures such as parking fee and congestion fee (on page 195) would also impact the number of vehicles on the road.

But CMP does not estimate the impact on the number of vehicles on the road as a result of all these measures. Hence it must consider withholding projects that would accommodate more vehicles on the road, such as elevated corridors and road widening.

5 Data collection and survey findings:

It would be essential to get Primary Surveys done for the CMP to be formulated based on proper data.

Household Interview Survey: What was the purpose of the Household Survey? Why were lower income groups that use NMT or public transport not included in the sample?

Task 2.7 Service Level Benchmarks (of the CMP Toolkit) recommends several Primary Surveys, which does not appear to have been carried out. In the absence of relevant Primary Surveys, benchmarks cannot be established.

13 Prioritisation of projects:

a) The projects promoting walkability, cycle paths, and NMT in general, are:

Phase 1: Construction of FoBs/Construction of footpaths/Public bicycle sharing – hubs/Elevated walkways. These would cost Rs 675 cr or less than two percent of the total Rs 35,835 cr.

Phase 2: Construction of FoBs/Construction of footpaths/Public bicycle sharing – hubs/Elevated walkways/Cycle tracks/Pedestrian streets. Cost estimate is Rs 1,684 cr out of Rs 69,110 cr (2.4 percent).

Phase 3: Tender Sure roads/Cycle tracks. Cost estimate is Rs 482 cr out of Rs 1,25,159 cr or 0.35 percent.

All NMT initiatives should be prioritised from Phase 1 onwards, and substantial allocation should be made for this. This will also lead to a reasonable modal share for NMT.

b) Projects which aim to disincentivise private transport:

Disincentivising private transport is a very powerful way to control the number of cars and two-wheelers on the roads. Indirectly, lowering bus fares to the point that it disincentivises even the use of two-wheelers, should be implemented. On the whole, allocation to these initiatives is inadequate.


The Toolkit for CMP states the key outcomes of a CMP:

  1. Improvement in mobility for all socio-economic groups and genders
  2. Improvement in air quality
  3. Improvement in safety and security for pedestrians, NMT, and liveability in the city
  4. Increase in sustainable transport mode share and a decrease in private motor vehicle use
  5. Achievement of desirable indicators and benchmarks
  6. Becoming integral part of Master Plan

The CMP should attempt to make these outcomes measurable. In the present CMP, the outcomes are not explicitly stated in most cases.


  1. Nimisha Agarwal says:

    More than 1000 people have already sent their objections to BMRCL regarding this https://act.airalert.in/petitions/send-comments-on-bengaluru-comprehensive-mobility-plan

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