EPG Submits Detailed Comments on Proposed Amendments to J&K Unified Building Bye-laws (UBBL) – 2021
New Delhi, 17 February 2025 – The Environmental Policy Group (EPG), a non-profit organization committed to the conservation of natural resources, environmental protection, and urban development, has submitted detailed comments and suggestions regarding the proposed amendments to the J&K Unified Building Bye-laws (UBBL) – 2021. The EPG, a petitioner of Public Interest Litigations concerning the 2014 floods and the implementation of the Solid Waste Management Rules, 2016, has secured significant orders from the Jammu Kashmir & Ladakh High Court to ensure sustainable development in the region.
Jammu & Kashmir’s Unique Characteristics
Jammu & Kashmir’s unique geographic and ecological characteristics demand that any amendments to the UBBL – 2021 be approached with caution and sensitivity. The region’s High-Risk Earthquake Seismic Zone 5 location, susceptibility to floods and landslides, and the fragility of its forests and ecosystems necessitate a sustainable and balanced approach to urban development. The devastating floods of 2014 are a stark reminder of the consequences of unplanned urbanization and ecological neglect.
At the heart of J&K’s identity lies its unparalleled natural beauty—its forests, lakes, rivers, and mountains. These ecological assets are key drivers of its tourism-based economy. Therefore, any changes to the existing building bye-laws must prioritize the preservation of this fragile environmental and cultural heritage, aligning developmental goals with principles of ecological conservation and disaster resilience.
Key Suggestions from EPG
In the spirit of participatory governance and sustainable urban development, EPG has submitted the following key comments and suggestions:
- Environmental Sustainability and Climate Resilience
- Mandate Environmental Impact Assessments (EIA) for major urban development projects.
- Strengthen green building norms, including energy efficiency measures, rainwater harvesting, and sustainable waste management.
- Incorporate climate adaptation strategies such as flood prevention, heat mitigation, and disaster preparedness.
- Legal and Regulatory Alignment
- Conduct a comprehensive review of existing bye-laws to address outdated provisions, gaps, and overlaps.
- Ensure consistency with national laws, including environmental, municipal, and disaster management regulations.
- Incorporate relevant judicial precedents to mitigate potential legal challenges.
- Inclusive Stakeholder Consultation
- Organize public consultations with residents, community groups, and marginalized populations.
- Seek inputs from urban planners, architects, engineers, and environmentalists.
- Align with municipal bodies, fire safety authorities, and utility service providers.
- Engage developers, builders, and construction professionals to ensure feasibility.
- Urban Planning and Land Use Optimization
- Analyze population growth trends, urbanization patterns, and land use efficiency.
- Ensure zoning compliance and infrastructure readiness in alignment with the master plan and Transit-Oriented Development (TOD) principles.
- Infrastructure and Public Safety Enhancements
- Assess the adequacy of utilities, including water supply, sewage, power, and transport networks.
- Update fire safety codes, seismic-resistant design guidelines, and universal accessibility standards.
- Integrate emergency evacuation plans and disaster-resilient infrastructure requirements.
- Economic and Social Inclusion
- Evaluate the impact of revised bye-laws on housing affordability and construction costs.
- Incorporate provisions for low-income housing and protection of informal settlements.
- Promote socially inclusive development to prevent displacement of vulnerable communities.
- Adoption of Smart and Innovative Technologies
- Encourage the use of smart building solutions, including IoT-based energy management.
- Promote modern construction techniques such as prefabrication and modular systems.
- Leverage GIS mapping and 3D modelling for effective spatial planning and assessment.
- Effective Implementation and Compliance
- Ensure bye-laws are practical, enforceable, and scalable across urban and rural areas.
- Establish a transparent monitoring and compliance mechanism.
- Conduct capacity-building programs for municipal authorities and stakeholders.
- Launch public awareness initiatives to communicate changes effectively.
- Comparative Best Practices and Global Standards
- Benchmark against national and international urban planning best practices.
- Align with global standards such as UN-Habitat, ISO norms, and other sustainable urban frameworks.
- Financial Sustainability and Incentives
- Conduct a cost-benefit analysis to assess economic viability for stakeholders.
- Explore innovative financing mechanisms, including public-private partnerships (PPP) and development grants.
- Pilot Implementation and Iterative Feedback
- Implement amendments in a pilot urban area to identify potential operational challenges.
- Gather feedback from stakeholders and refine regulations based on practical learnings before full-scale enforcement.
- Transparency and Public Access to Information
- Ensure that revised regulations are clear, concise, and easily accessible.
- Maintain detailed records of consultations, studies, and regulatory changes.
- Publish draft amendments for public review and integrate constructive feedback.
- Long-Term Vision for Adaptive Urban Planning
- Ensure that the bye-laws remain adaptable to future technological, demographic, and environmental shifts.
- Establish a framework for periodic reviews and necessary updates to maintain relevance.
- Impact of Climate Change on Events: The Cancellation of Khelo India Winter Games in Gulmarg
- The cancellation of the Khelo India Winter Games in Gulmarg serves as a stark reminder of the profound consequences of climate change. This decision illustrates how rising temperatures and unpredictable weather patterns can disrupt not only major sporting events but also the local economy that depends on winter tourism. The economic losses incurred by local businesses, such as hotels, restaurants, and ski operators, highlight the direct relationship between climate stability and regional prosperity.
Commitment to Sustainable Development
The Environmental Policy Group (EPG) sincerely hopes that these inputs will contribute to a more resilient, inclusive, and sustainable urban development framework in Jammu & Kashmir. EPG remains committed to supporting this process and welcomes the opportunity to engage further in consultations in the larger and long-term interests of the people of Jammu & Kashmir.
Conclusion
The EPG’s detailed suggestions and comments reflect its commitment to ensuring balanced development in Jammu & Kashmir. By prioritizing environmental sustainability, legal alignment, inclusive consultation, and smart technologies, the amendments to the J&K Unified Building Bye-laws (UBBL) – 2021 can pave the way for a resilient and sustainable future for the region.
We look forward to your kind consideration and an opportunity for further discussion on these recommendations.
Thank you.
Sincerely,
Faiz Ahmad Bakshi
Convenor – Environmental Policy Group (EPG)
Press Release
Subject: Comments/Suggestions on Proposed Amendments to J&K Unified Building Bye-laws (UBBL) – 2021.
Ref: Public Notice – Invitation for suggestions/comments on proposed Amendments to Unified Building Byelaws (UBBL) – 2021
Dear Sir,
The Environmental Policy Group (EPG) – a non-profit organisation (NPO)- A registered Trust-engaged in the conservation of natural resources, environmental protection and urban development have examined in detail the initiative of the Housing & Urban Development Department in undertaking amendments to the J&K Unified Building Bye-laws (UBBL)-2021. The EPG as a petitioner of Public Interest Litigations regarding the devastating 2014- Floods and Implementation of Solid Waste Management Rules, 2016 has obtained significant orders from Jammu Kashmir & Ladakh High Court to ensure sustainable development of Jammu & Kashmir. It is in the larger interests of the people of Jammu & Kashmir and sustainable developmental goals that we consider the importance of balanced development.
Jammu & Kashmir’s unique geographic and ecological characteristics demand that any amendments to the J&K Unified Building Bye-laws (UBBL)-2021 be undertaken with utmost caution and sensitivity. The region’s location in High-Risk Earthquake Seismic Zone 5, combined with its susceptibility to floods, landslides, and the fragility of its forests and ecosystems, necessitates a sustainable and balanced approach to urban development. The devastating floods of 2014 serve as a stark reminder of the consequences of unplanned urbanisation and ecological neglect. At the heart of J&K’s identity lies its unparalleled natural beauty—its forests, lakes, rivers, and mountains—not only as ecological assets but also as key drivers of its tourism-based economy. This landscape is a unique selling proposition (USP), positioning J&K as a globally preferred and popular tourist destination. Any changes or amendments to the existing building bye-laws must therefore prioritise the preservation of this fragile environmental and cultural heritage, aligning developmental goals with the principles of ecological conservation and disaster resilience. Hence, in the spirit of participatory governance and sustainable urban development, we submit the following comments and suggestions for consideration:
- Environmental Sustainability and Climate Resilience:
Mandate Environmental Impact Assessments (EIA) for major urban development projects.
• Strengthen green building norms, including energy efficiency measures, rainwater harvesting, and sustainable waste management.
- Incorporate climate adaptation strategies such as flood prevention, heat mitigation, and disaster preparedness.
- Legal and Regulatory Alignment:
- Conduct a comprehensive review of existing bye-laws to address outdated provisions, gaps, and overlaps.
- Ensure consistency with national laws, including environmental, municipal, and disaster management regulations.
- Incorporate relevant judicial precedents to mitigate potential legal challenges.
- Inclusive Stakeholder Consultation:
- Public Engagement: Organize consultations with residents, community groups, and marginalized populations.
-
Expert Involvement: Seek inputs from urban planners, architects, engineers, and environmentalists.
• Government Coordination: Align with municipal bodies, fire safety authorities, and utility service providers. - Industry Inputs: Engage developers, builders, and construction professionals to ensure feasibility.
- Urban Planning and Land Use Optimization:
- Analyze population growth trends, urbanization patterns, and land use efficiency.
• Ensure zoning compliance and infrastructure readiness in alignment with the master plan and Transit-Oriented Development (TOD) principles.
- Infrastructure and Public Safety Enhancements:
- Assess the adequacy of utilities, including water supply, sewage, power, and transport networks.
- Update fire safety codes, seismic-resistant design guidelines, and universal accessibility standards.
- Integrate emergency evacuation plans and disaster-resilient infrastructure requirements.
- Economic and Social Inclusion:
- Evaluate the impact of revised bye-laws on housing affordability and construction costs.
• Incorporate provisions for low-income housing and protection of informal settlements.
• Promote socially inclusive development to prevent displacement of vulnerable communities.
- Adoption of Smart and Innovative Technologies:
- Encourage the use of smart building solutions, including IoT-based energy management.
• Promote modern construction techniques such as prefabrication and modular systems.
• Leverage GIS mapping and 3D modelling for effective spatial planning and assessment.
- Effective Implementation and Compliance:
- Ensure bye-laws are practical, enforceable, and scalable across urban and rural areas.
• Establish a transparent monitoring and compliance mechanism.
• Conduct capacity-building programs for municipal authorities and stakeholders.
• Launch public awareness initiatives to communicate changes effectively.
- Comparative Best Practices and Global Standards:
- Benchmark against national and international urban planning best practices.
• Align with global standards such as UN-Habitat, ISO norms, and other sustainable urban frameworks.
- Financial Sustainability and Incentives:
- Conduct a cost-benefit analysis to assess economic viability for stakeholders.
• Explore innovative financing mechanisms, including public-private partnerships (PPP) and development grants.
- Pilot Implementation and Iterative Feedback:
- Implement amendments in a pilot urban area to identify potential operational challenges.
• Gather feedback from stakeholders and refine regulations based on practical learnings before full-scale enforcement.
- Transparency and Public Access to Information:
- Ensure that revised regulations are clear, concise, and easily accessible.
• Maintain detailed records of consultations, studies, and regulatory changes.
• Publish draft amendments for public review and integrate constructive feedback.
- Long-Term Vision for Adaptive Urban Planning:
- Ensure that the bye-laws remain adaptable to future technological, demographic, and environmental shifts.
• Establish a framework for periodic reviews and necessary updates to maintain relevance.
- Impact of Climate Change on Events: The Cancellation of Khelo India Winter Games in Gulmarg
The cancellation of the Khelo India Winter Games in Gulmarg serves as a stark reminder of the profound consequences of climate change. This decision illustrates how rising temperatures and unpredictable weather patterns can disrupt not only major sporting events but also the local economy that depends on winter tourism. The economic losses incurred by local businesses, such as hotels, restaurants, and ski operators, highlight the direct relationship between climate stability and regional prosperity. Furthermore, it underscores the pressing need for sustainable development and action regarding climate change, as ignoring these issues risks exacerbating both environmental degradation and economic instability in vulnerable regions.
The Environmental Policy Group ( EPG) sincerely hopes that these inputs will contribute to a more resilient, inclusive, and sustainable urban development framework in Jammu & Kashmir. We remain committed to supporting this process and welcome the opportunity to engage further in consultations in the larger and long-term interests of the people of Jammu & Kashmir.
We look forward to your kind consideration and an opportunity for further discussion on these recommendations.
Thank you.
Sincerely,
Faiz Ahmad Bakshi
Convenor- Environmental Policy Group (EPG)
