COMMENTS

My 2 cents.

1. This act should empower and should confer authority in BMLTA to be the sole transport policy making authority for Bangalore Metropolitan Region with functions of urban transport planning, regulation and implementation.
2. This act should identify citizens as the important stakeholder of the BMLTA.
3. This act should make the public consultation to be  mandatory for all the policy making, planning, regulation and implementation processes from BMLTA
4. The Sec 5.4, Preparation of a Master Plan for the land based transport infrastructure for the BMR taking in to consideration the plans already prepared by stakeholders like BMTC, BBMP, BDA, BMRCL and any other government agency for any part or whole of the BMR; ...should be promoted to Sec 5.1. This should be the primary function of the BMLTA.

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[Let us collect all our feedback via comments here, can then send a link to this post to DULT]

Here is my first batch, review comments for Sections 1 - 9.

Section 3

• Section 3.3 - why no representation from Railways? Is South Western Railway not assumed to be a part of City's transportation landscape in future?
• Would it be possible to add a slot for special guest for short tenures of 1 year. These guests could cover things we have not seen and planned for yet. To start it off, can invite someone from Land Transport Deptt of foreign cities (Say Singapore), or eminent people from other cities of India. (Say Mr Sreedharan).
• Will sound odd to say this, but would be good to add a "Program Management Expert" to the panel. Running programs involving 5 powerful civic agencies would be no mean joke. IF a Babu does it, he/she would bring his/her own bias and style. An experienced program manager from outside will be required at the highest level to meet the goal mentioned in Section 5.1.

Section 4 (Goals)

• Section 4, Objectives in general. Why be scared of putting number targets in objectives? 55% use of PT by 2012, 65% bu 2014, 75% by 2016? These could depend on Metro completion etc, but take number targets please, or we wouldn't know
• On same lines, start with a survey that lists some current parameters like Road use % for Private Transport vs PT vs and Non-Motorized transport, and % use of PT for commute. Could pick 4-5 numbers like these as baselines, so that we have a way of evaluating BMLTA's performance year over year.
• Nice to see 4.14 - encourage participation of private sector, great to mention this.

Section 5 (Functions)

• Section 5.4 - "any other government agency" is a loose phrase. Why not mention at least the ones we know - BESCOM, BWSSB, and KSPCB - by name?
• Section 5.9 as well as 5.1 to some extent - I think BMLTA must start with a precise list of things it will regulate or coordinate. Or else, we could be spending time in public hearings or courts to decide what is and what is not on BMLTA's scope.
• Section 5.17 - why expert committee from "time to time"? This makes the whole job of BMLTA look very transactional or tactical. 1 expert committee per project approach is going to delay things. Replace this instead with "BMLTA will define guidelines for resolving conflicts across BMTC, BMRC, BBMP, BDA, BMRDA, and other agencies like BESCOM, BWSSB". There could be multiple guidelines, and would consist of operation guidelines and not gyaan (as gyaan will come via the BMR Masterplan). This comment covers 5.18 as well.
• Section 5.19. Great to mention this (private participation" as a goal. But why limit to "operation of rolling stock". Either more items, like "upkeep of commuter amenities", "information and ticketing systems", or better, don't mention the specifics, but set a goal for outsourcing in a way like - "minimum 40% of operations should be outsourced pending formation of clear regulatory guidelines".
•  

Section 6 (powers)

• Very hard for me to comment on these as I don't know the extent of similar powers that rest with the parties to BMLTA, esp BBMP (and BDA, BMRDA in some cases)
• For example, if 6.11 (acquire land) and 6.13 (dole out contracts) are agreed upon, is it only for projects executed by BMLTA, or for any project in transportation area in the city?
• This section 6 kind of dilutes the theme for me - is BMLTA planning and coordinating body (which will issue interoperability standards for all, and audit them on it), or an execution/implementation body as well for special projects?
• Who will enforce compliance to what is mentioned in section 5.22 (standards). A key power BMLTA needs is enforcing compliance to standards (5.222), regulatory guidelines (5.20), safety guidelines (5.21) etc. It is be these enforcements that BMLTA will be able to do its core job (which is mentioned in 4.2 and 5.1).

Section 7

• Without a clearer section 6 based on Theme of coordination and compliance, this doesn't need tighter review right now.

Section 8 & 9 (land acquisition)

• I thought BMLTA does the thinking (the right way to acquire, time-frame, coordination guidelines). But this, and relevant line in section 6 tells us that BMLTA will be executing projects as well. And then, the line is not clear for things like - will BMTC build things like TTMCs, or BMLTA? It would be nicer if BMTC builds, but BMLTA says where, and issues design guidelines. At least I am not clear

Will continue with other sections (10 to 24) a bit later. Don't understand some of the details there.

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SB,

I haven't read the full act in detail yet, but at least it's a start - the act will need streamlining & modifications of course. Let's hope this does not end up with creation of another power entity that gets embroiled in controversies about jurisdictions & authority.

This is coming about a year or two late since major decisions need to be taken urgently wrt selection of mass transit modes along various corridors (this is being done currently by DULT, I think).

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Section 5.19. Great to mention this (private particpation" as a goal. But why limit to "operation of rolling stock". Either more items, like "upkeep of commuter amenities", "information and ticketing systems", 

Reading it again, I think it could be phrased something like this

5.19 - To provide license to individual service providers including in the private sector in performing various functions with the end objective of safe and effective operation of the rolling stock;

But yes, Other than retaining assets everything else should be a candidate for private participation. The concession model may vary.

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 After reading through the draft act fairly quickly, I think the whole of BMLTA as defined by this act is a terrible idea.  This will be yet another parastatal agency which will be answerable to no one with all kinds of vaguely defined authority and expertise. They will get into turf wars with all the other agencies and we cannot do anything about it.

Then there is the movement of goods which is completely absent from this whole plan.  Goods is a large chunk of land transport.

I say scrap this bill and come up with a more comprehensive plan.

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