What’s up with Lahore's new building regulations?

The LDA is putting the cart before the horse and ramming it into Lahore.
Updated Oct 16, 2019 07:07pm

In a tweet in March earlier this year, Prime Minister Imran Khan announced that the cities of Pakistan must grow vertically in order to preserve our green spaces and reduce sprawl. Although well intentioned, Khan is neither an architect nor a city planner. His simplistic view of how to reduce sprawl in our cities does not come as a surprise.

Urban sprawl is a problem for its unsustainable consumption of land, extensive and costly transportation infrastructure, increased private vehicle use and poor pedestrian experience, all which eventually take a toll on public health. One of the methods of reducing sprawl may be vertical development but if done in isolation without accounting for a city’s unique cultural and economic context, it has the dangerous potential of further increasing the divide between the rich and the poor.

High-rise buildings require skill, technical expertise and building materials that are not always available locally. In a time when the economy is trying to rid itself of imports, high-rise buildings are not a solution to our problem. In a time where housing shortage exists primarily within the middle- and lower-income classes, high-rise buildings risk primarily catering to the rich. Much like the houses in our elite gated communities, they risk remaining unoccupied, to be used as pawns in the game of real estate speculation.

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Simpler ways of reducing sprawl include redesigning city blocks, particularly in urban centres, keeping them compact and allowing a variety of building typologies and uses within them. Conscious efforts to reduce car use, along with significant investments in public transportation and pedestrian infrastructure, are required.

These include taking stringent measures to discourage private vehicles in congested urban centres, enforcing the installation of wide contiguous footpaths, trees, benches and bus bays along all roads, implementing strict timings for freight vehicles, imposing fines and penalties for improper parking, providing adequate parking space near transit stops and having an almost war-like attitude against signal-free corridors and road widening.

Wider roads invite a higher number of cars, which in turn demand wider roads; it is a dangerous cycle. Moreover, car dependency means longer distances are travelled in lesser time, which further encourages cities to sprawl.

Therefore, in response to the prime ministers tweet, what the development authorities across the country should have done is provide comprehensive technical advice on how urban sprawl can be combatted and densities increased. Instead, the Lahore Development Authority, for example, geared its horses and prepared draft building bylaws to reflect exactly what Khan had stated in his tweet: vertical development.

The revision of the buildings regulations at this stage is highly problematic. Firstly, it is important to note that regulations are a means of implementing an official master plan in the city. A master plan is finalised after extensive consultations, data collection and research and stakeholder engagement. In Lahore particularly, where multiple departments are involved in the process of city development, a master plan must also address all the various plans, policies and strategies pertaining to the city.

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Currently, Lahore's master plan is undergoing considerable reviews and is not yet finalised. The afforestation movement in the city, a collaboration between the Commissioners office, the Lahore Biennale Foundation and the Lahore Conservation Society, begs the need for a formal urban forest policy. The Planning and Development Department’s Urban Unit is on the verge of officiating the Provincial Spatial Strategy, which outlines the principles cities must follow for inclusive and equitable development.

All these movements must first be reflected in the master plan, and once the plan is finalised, these can be translated through the building and zoning regulations. However, blind to these parallel movements, the LDA, as architect Kamil Khan Mumtaz so aptly stated at a seminar, "puts the cart before the horse" and rams into the city with its building regulations.

This and other concerns were voiced at a ‘public’ seminar held on 5 August at the LDA Sports Complex. I use the word ‘public’ sparingly because the time and day of the seminar – 11am on a Monday – indicates that the authority had no interest in having the citizenry of Lahore attend the seminar.

LDA representatives highlighted how rapid and uncontrolled commercialisation in the city has wreaked havoc on our infrastructure and public spaces. While the concern is accurate, I did not find its resolution in their draft of the building and zoning regulations.

The same concern was also recently also brought up in a meeting between the LDA and the Urban Unit, where one of the recommendations we gave was that they incorporate ‘informal street vendor’ as an official category and provide and regulate the space allotted to them. This will not only allow the city to plan ahead for possible ‘encroachment’ by these vendors, but in turn also support the large informal economy. The suggestion has not been reflected in their draft either.

The one clause in the LDA regulations that leaves me confounded is the amended parking clause. Clause 3.11 of the new document states that one parking space is required for every 1,600 square feet of covered area, whereas the old regulations asked for one parking space for every 1,000 square feet. This indicates that the new regulations are aiming to reduce the parking area within commercial plots.

However, a subsequent clause – 5.7.9 – provides monetary incentives if the builder provides additional parking on their plot. This makes one wonder what the LDA’s stance on parking is. And what was the point of reducing parking space in the new bylaw if they were going to add an incentive to the builder for increasing it anyway?

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Some good points in the building and zoning regulations include the installation of rainwater harvesting equipment in all future buildings (clause 5.6.6). What the document completely neglects, however, is applying this clause to golf courses. Golf courses, having large spans of green, are excellent sites for stormwater storage.

Additionally, in sections Q to U of clause 3.6.4, the use of insulation for buildings is reiterated. The regulations, however, fail to regulate the building materials to ensure that they do not absorb heat at a high rate in the first place. Logic begs that builders first be encouraged to use materials that are better suited to our climate, and then insulation be recommended as an added feature.

One noteworthy clause – 2.5 – that the LDA has added in their regulations is the allowance of four story apartments on a plot size as small as 10 marla. Previously, one could not build an apartment on a plot measuring less than 80 marla. If adequately regulated, these apartments can serve as excellent means of addressing the housing issue in Lahore.

However, additional incentives are required to encourage builders to focus on serving the middle- and low-income housing demand. Without such measures, irrespective of how well-intentioned the regulation is, the apartments will either not be built; or if built, will not address the housing crisis.

It is important to note that these regulations have no say over the areas under Cantonment and the Defence Housing Authority, both of which are the primary contributors of sprawl in Lahore, with the latter rapidly edging towards the border with India.

If the primary motive of such an extensive exercise was to address sprawl, and the exercise itself has no impact on areas most in need of such regulation, I can logically conclude that the exercise is futile.

However, I may be wrong. Soon after this seminar, it was reported that the LDA endorsed of a 40 storey building, a hotel, on The Mall. One can’t help but wonder if the ‘public’ seminar and the haphazard revision in regulations was yet another exercise to support the vested interests of a few at the cost of the city of Lahore.


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