Townships and Large Housing Schemes: The Case of Ahmedabad: Kahinee Shah

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Int'l Journal of Research in Chemical, Metallurgical and Civil Engg. (IJRCMCE) Vol.

3, Issue 2 (2016) ISSN 2349-1442 EISSN 2349-1450

Townships and Large Housing Schemes:


The Case of Ahmedabad
Kahinee Shah

 2013).2 Public and private sector interventions, due to the slow


Abstract—Ahmedabad has always been a hub for the real estate development and few drawbacks, still fail to reduce the demand.
sector. Private developers have come up with affordable housing The public sector reforms include government policies and
schemes and townships in the western part of the city. The concept of programs implemented at central and state level. Many of these
an integrated township was introduced in Gujarat with the first programs are PPP ventures. The private sector actions include
township policy in 2006 by GUDCi. A new residential township policy
the development of
was again introduced in 2009 with changes concerning bank guarantee
and minimum area of the township. Looking at the kind of investment
1) Stand-alone schemes based on GTPUDA ACT vi ,
and the kind of approvals needed, many developers prefer developing Development Plan (DP) and building by-laws
housing schemes. But many fiscal and FSI benefits mentioned in the 2) Integrated township models based on the state integrated
township policy also attract them. People often look at the benefits of a township policies.
township pertaining to its scale and the kind of lifestyle it promises to These two private sector models of development have their
offer. But what we overlook is the developer’s perspective linked with own institutional and implementation framework. Many
its institutional framework. This research highlights and focuses on stand-alone affordable housing schemes and other large scale
behind the scene aspects for both the developments and their
processes.
housing schemes have been prevalent in the city. AMC, AUDA
and the revenue department play a very important role in the
Keywords—Property Development Process, Townships, process development of these projects. These schemes are
Stand-alone schemes, Time and Cost, Private sector. developed based on the zoning and land prices in the area. The
townships can be developed in any zone, but because of the
I. INTRODUCTION large area under development many of them have been
sanctioned in the outskirts of the city. Under the Gujarat
Background Integrated Township Policy, these townships can have fiscal
Limited housing supply has been a point of concern in Indian benefits from the government. Apart from the local authorities,
context. According to the estimates of Technical Group the state government interferes in the approval process. Now
constituted by Ministry of Housing and Urban Poverty this concept of township with more investment and a prolonged
Alleviation (MHUPA), urban housing shortage during the 11 th completion time, attracts few developers only. Time and cost
five year plan, at the end of 2012, was 18.78 million in urban have a major impact on this type of development. In this
areas and 43.67 million units in rural areas, with 95% of the total context, this research aims to compare the property
pertaining to EWS ii and LIG iii 1 . According to Cushman & development process for the two different development models.
Wakefield Research, the total housing demand in the country by
2017 could be as high as 88.78 million units. Around 23% of Aim
this total demand will be generated in the top eight cities of To compare the property development process of townships
India. Of the 18.78 million units to be required the township to large scale housing schemes.
projects are collectively promoting their projects to a market
accounting for only 0.16% of the total people affected by Objective
housing shortage. A report by McKinsey states that 20 metros  To study the framework for property development process in
and cities across the country need to build around 20-25 new Integrated Township and Large housing schemes.
townships closer to them. In Ahmedabad also, housing shortage  To carry out a comparative assessment and understand their
has led to increasing slum population in the city. The official impact on time and cost.
estimates by the AMCiv of the proportion of slum population
Overview of Integrated townships
are: 16.0 per cent (0.46 million) in 1991, 25.8 per cent (0.91
million) in 2001 (AMC 2005) and 13.0 per cent (0.73 million) Although the word township has been commonly used, there
in 2010. The latest estimate of 17 chawls in the AMC area is 958 is no one nationally accepted definition or format. Therefore
(consisting of textile mills’ chawls and new low-income anything from 25 to 2500 acres qualifies or is termed as a
housing), which house around 149,002 households (AUDA v township. In the past India has witnessed various types of

2
Biometric socio-economic household level survey, as quoted in AMC and
Kahinee Shah is with CEPT University, India PAS 2010. “Slum Free Cities: A Case for Ahmedabad,” Presentation at the
1
Alleviation, Ministry of Housing & Urban Poverty. "Annual Report." Workshop to Advance City-Wide Strategies for Slum Upgrading, CEPT
2011-2012 University, Ahmedabad, August 13, 2010.

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models as far as townships are concerned. After independence, congested cores and aimed to augment the respective deficits in
eastern India saw the emergence of industrial towns like the region.
Jamshedpur, Bhilai, Rourkela, Durgapur etc. These townships
Government’s Role
have corporate or industry promoters running their
administration and services, but with the consent of the  Green Channel: The developer of the township will be
respective governmental authorities. Besides this, several cities allowed self-certification, deemed clearance (such as NA on
have emerged from the design boards like Bhubaneswar, qualification of township), and time limit for clearances.
Chandigarh, and Gandhinagar. Thereafter, the country saw a  Single Window: A single window or dual window system
series of satellite towns like Faridabad, Gurgaon etc. and sub would be created for the scales of townships.
cities namely Dwarka, Rohini, Navi Mumbai etc. come up. It is  Land Assemblage: The developers do majority of the land
the ever increasing urbanization that also gave rise to residential assemblage. The government will intervene only if required
townships in different states of India. From 2001-2006 the for residential assemblage through compulsory acquisition or
different township policies in Lucknow, Maharashtra, Uttar by consent for which the framework will be set in terms of fair
Pradesh, Gujarat, Andhra Pradesh put forward their first price valuation committee. To facilitate the developer’s
attempts to form the township policies. Since then there have initiative for land assemblage the government will consider
been many changes and reforms in the policies. Different grant of permission for bonafide townships, new tenure
agencies, consultants, developers have given varied estimates premium rationalization, government lands on lease, land
about the number and extent of townships that have either been parcels subject to Charity Commissioner’s jurisdiction and
constructed or are been planned for the future. According to the registered as charities (GAUSHALA), WAKF lands,
MoEF(Ministry of Environment and Forests), since 2006, 39 Devasthan inam lands, Prasayata Inam lands, Khar lands etc.
township projects have been granted environmental clearance3.
Fiscal Incentives
According to EIA (Environmental Impact Assessment)
notification any area development and township projects above Pre Development exemptions extended to the developer such
50 acres have to get environmental clearance from the MOEF. as Stamp Duty Exemptions, Tax waivers on construction
Township projects also seem to have won favours from both material, scrutiny fees etc. Post development exemptions
national and foreign investors. Real estate consultancy and extended to the individual plot owners such as Entertainment
research firm, Jones Lang LaSalle (JLL) reported that the Tax waivers, Luxury Tax waivers etc.
international investors since 2006 have put in about US$ 15.8 Special Benefits
billion in this sector. Of which, US$ 2.7 billion went to • The government can enter into a PPP agreement with the
residential projects and US$ 2.4 billion to township projects, developer on extension of government land, infrastructure or
which is the second highest investment amongst all types of assets for the townships. Since the project is approved under
projects, while rest went into commercial, SEZ projects etc. In the township policy, the advantage of the NA clearance is,
case of private equity, township projects have received that a specific parcel of land, which is to be developed, need
investment of nearly US$ 122 million by 2011, which is also on not be NA. For e.g. For a 100 acre of township, If 40 acres of
the higher side.4 cluster is to be developed, NA conversion for an equivalent
There is no denying the fact that the integrated townships are area of land across the whole township is acceptable.
going to have sizable impact on the urban development However by the end of complete development of 100 acres,
scenario. Therefore, it is most logical and appropriate to have a the land parcel as a whole must be NA. The conversion is
strategy and a policy in place to deal with its regulation and done under the Bombay Land Revenue Code, 1879 as
monitoring. These policies need to ensure that the all important applicable to Gujarat and the Gujarat Land Revenue rules,
principles of inclusiveness, equity, environmental sustainability 1972. The charges payable to the authority are 80% of the rate
and transparency are addressed adequately in these policies. mentioned in the Annual Schedule of Rates (ASR).
Further, it is important to have adequate clarity and harmony Non-agriculture permission will be automatic
amongst the state and the central government’s policies and • Exemption from Urban Land ceiling and Regulation Act,
perspectives dealing with integrated townships to ensure that the 1976
development is regulated and has proper directions. • Government land falling under township area, leased out to
Overview of Gujarat Residential Township Policy (2009) the developer at the current market rate
The Gujarat Integrated Township Policy defines township as • Floating FSI in the township
any multi-functional node such as housing, social, educational • 50% concession in development charge
and welfare institutions, commerce and entertainment FSI regime
complexes and non-polluting industries premises within cities The township will be allowed in a blanket FSI of 2.25 on
and urban centers of the state as counter magnets to the gross site + 0.25 additional development rights (ADR) subject
to payment of premium plus compensatory FSI for EWS
housing. (2006) Total FSI permitted on Gross plot area shall be
3
MoEF’s response to CSE’s RTI, sum of Global FSI and Additional FSI as under; (2009).Global
http://cseindia.org/content/conspiracy-silence FSI (GFSI) shall be 1.0
4
Anon, 2011, Real Estate, Indian Brand Equity Foundation, November,
www.ibef.org Overview of townships in Ahmedabad

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The “Integrated Township Policy” was introduced in 2006. NA land: 84 acres


This policy was revised in 2009 under “The Residential Planned: 149 acres
Township Policy”. In 2008, the AUDA and the state screening Developed: 57 acres
committee appointed to review the proposal for township, gave Total phases: 5
approval to 5 townships, of the 9 proposals submitted. The Anticipated completion in year: 2020
committee held back four major township projects. The The development process for Godrej garden city started 7
townships need an approval from the state government as well years ago (2009). The concept of “Integrated” township gave a
as from AUDA. The screening committee issued final order to different character to the project. The idea was to give access to
one township, while four township projects received amenities within the township so that the people would confine
most of their time within the township itself.
in-principle approval. (Received approval only from AUDA).
Land Assembly
Townships Approval Status (2008)
Applewood Approved Godrej as a company does not invest into land parcels. They
Arvind’s group township (Moti Bhoyan) In-principle prefer joint ventures for large project like the garden city. For
Shantigram In-principle this project particularly, they entered into a joint venture with a
Sahara City In-principle
private party Shree Siddhi Group. For liquidity of the project,
Safal Group's township near Sanand In-principle
Arvind’s group township (Jethlaj) Not approved the land was owned by the joint venture partner i.e. Shree Siddhi
Godrej Garden City Not approved Group. They own 210 acres of land dedicated to the project.
Smile City Not approved
Ozone Group's township(Santej) Not approved
Procedure for notification and securing permission
Arvind Group's township project fell under the buffer zone A prescribed officer by the state government, who is a
for a bird sanctuary, so the company was asked to obtain member of the local body or development authority (AUDA in
clearance from forest and environment department. Moreover, this case) shall carryout survey and studies for any area to be
the canal adjoining Ganesh Housing's Smile City Golf considered for township development and recommend to the
Township became a hindrance to the project. The township government to declare any area, to be a notified area.
projects of Godrej and Ozone were in the same year (2010) not Subject to the provisions of the township policy and the
given approval for some technical reasons. Post this, the GDCR, the state level screening committee reviewed the
committee made it mandatory to make a six monthly review of proposal received from AUDA (prescribed officer) for Goderej
the progress of the project. It also stated that in the first phase of Garden City. The same was given the gazette notification under
the development, the developer of the township has to, with the the policy in 2009 by the State government. After applying to
prior permission of the screening committee, construct the first the state government for the proposal, they were given the
draft of the town planning or TP road. permission to secure in 2009.After getting all the necessary
By 2015 8 townships were given the final order approval approvals, they commenced the development in September
which are currently in their various phases of development. 2010.
• Arvind Smart Value Home LLP Maintenance
• Applewoods (Sandesh Ltd)
At cluster level and individual tower level separate societies
• Sky city (Sahara city)-(H N safal and Goyal)
are formed. An apex society under the Godrej group is formed,
• Super city (K .B Zaveri and Shrinivas )
which monitors the maintenance of these separate societies and
• Shantigram
looks after amenities and infrastructure outside these clusters.
• Godrej garden City
For public parks, they maintain it for 7 years (according to the
• Arvind Group's project at Jethlaj
policy) and then hand it over to AMC
• Arvind Group's township at Moti Bhoyan
Site-2: Bakeri City
Site Selection
Of the 8 approved townships in Ahmedabad as of 2015, General details and stages of development
Godrej garden city is selected as the first case study. The site is Total Land area bought: 5, 43,056 sq.mt.(134.19 acres)
within AMC limits, hence can be compared to the framework of Land in possession: 4, 79,000 sq.mt. (118.3 acres)
any large housing schemes within the limit. Also, spread over an Land sold to developers: 2, 25,263 sq.mt (55.66 acres)
area of 210 acre (8,49,840), it is one of the few townships which Remaining Land: 2, 53,737 sq.mt (62.69 acres)
has completed planning for 70% of the area(149 acres) and Developed: 1, 88,709 sq.mt (46.63 acres)
developed 40% of it (57 acres). Total schemes: 19 (1 commercial)
The second case study selected is, Bakeri City spread over an Bakeri Group became active in the Vejalpur area during
area of 140 acres, a large housing scheme with basic amenities, 1991.The project came to be known as the Shrinandnagar
also within the AMC limits. township until in 2008, when they changed it to Bakeri City.
Site-1: Godrej garden city Spread over an area of 140 acres, the housing scheme is one of
the oldest housing projects in the city.
General details and Stages of development
Total Area: 210 acres

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Detailed Framework of Bakeri City & Godrej Garden City:

Fig. 1: Detailed framework of Bakeri City

Fig. 2: Detailed framework of Godrej Garden City


society in 1991 under which they signed the agreement with the
Land Assembly
trust to buy the land. The land was further subdivided into 27
Bakeri group bought a land in Vejalpur area from the equal parts-27152 sq. mt each for transfer of property and
Vejalpur rabari panch (trust) in July 1991.The area of the land ownership. As mentioned in the ULCA (urban Land ceiling Act,
was 543056 sq. mt. They formed a Sakal cooperative housing

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1976), the price at which the land was to be sold, was decided by Act,1976
the government. This land was sold at 25 Rs/sq. mt. After Non-agriculture 6 months
3 months (automatic)
applying for permission to develop under the ULCRA(Urban permission (subdivided land)
Land Ceiling and Regulation Act), they got the approval in Master Plan
4 months (phase wise)
4 months
1994. Approval/building plan (scheme wise)
Environmental clearance Almost 8 months-1 year
Land Clearance Height clearance 6 months 6 months
NA clearance-The land was converted to nonagricultural land Possible interventions
first in 1994 followed by 1997 and 1999.Each time the period
was 6 months. It took 2-3 years for the land approvals and Environment clearance is mandatory for projects of/above
clearances followed by the levelling of the entire land parcel size 20,000 square meters and township projects having more
which took another 8 years. than 50 HA area. Environment clearance is a pre-requisite for
Building Plan approval. Getting the environment clearance is a
Maintenance
lengthy process which often takes 8 months to 1 year presently.
The developers are in charge of the maintenance for 3 years This delays the approval of building plan and therefore further
and then they hand it over to the authority. The internal roads, approvals and NOCs. The environmental clearance should be
water and sewage facilities are provided by the AMC. obtained by the local authority (e.g. AUDA) for the entire DP
Analysis (Development Plan) and the Town Planning Scheme (TPS)
should be strictly based on this plan. Developers need not obtain
Comparable parameters for the two cases: separate environment clearances for individual projects if the
project is if the project is planned according to the DP & TPS.
Godrej garden city, a township approved under the state
This will hugely save time and costs of projects.
township policy and Bakeri City, a large housing scheme, have
If the project is planned as per the DP since it is already zoned
different parameters that affect the completion time and the cost
for the concerned activity, the requirement of NA permission
of project. For two different entities, they can be compared by
for real estate projects could be condoned. Deemed clearances
the following parameters:
must be given wherever there is a delay in giving approvals. The
1) Parameters Affecting Time:
NOC from Airports Authority of India takes about 6 months and
Approvals
could be relaxed selectively. DP should clearly mark the areas
Phase-wise construction
which would require AAI clearance for projects, area outside
2) Parameters Affecting Cost:
this need not require AAI NOC and be free to develop as per the
FSI and Built up
DP and TP scheme.
Developer’s role
Project Cost Phase wise construction
TABLE 3: Built comparison for a comparable year
Parameters Affecting Time
Category Godrej Garden City Bakeri City
Approvals Total Phases/Schemes 5 19

Total no. of units 3420 5574

No of units ready 2184 5574


Time to complete the 2006-2020 (14 1991-2015 (19
entire project years-anticipated) years)

TABLE I: Approval comparison of two sites Comparable year Upto 2016 (2184 Upto 2001 (
Approvals Godrej Garden City Bakeri City units) 2160 units)
State approval for Gazette
2 years Type (BHK) 1,2,3,3.5 1,2,3,1HK
notification
Development permission Area developed (sq. 230671 68425
under the Urban Land 1 year
mts)
Ceiling And Regulation

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Fig. 3: Project completion time


The 2 years gap for Godrej Garden city is due to the delay in years. However the area developed by Garden city was much
permission to secure (Gazette notification). The same process higher. If the 2 year lapse could have been saved, the following
for the housing society took 1 year. Also since it is spread over could have been the earning potential of Godrej Garden City
a huge area, it needs to be approved of clearances that Bakeri by 2016.
city is not compelled to.
TABLE III: Possible scenario of earning potential for Godrej garden City
Parameters Affecting Cost
Data "then" in 2016
FSI and Built up "If"Completed in 2014
Units 2184 3420(2184+1236)
TABLE II: Earning Potential calculations Residential Built
up 427954.5 755750.25

Total built up 1,727,640.00 1,727,640.00

% area 24.77 43.74


FSI 2.25 2.25
Basic sale price 31,000 31,000
Earning potential 17277 30511

The FSI and built up for a project can be used to find out the
earning potential for a project.
Earning Potential (residential): %area *FSI* Basic sale price
The basic sale price is considered for the current year. The
earning potential and the basic sale price are directly
proportional and hence by 2020 it would increase
proportionately. Godrej Garden City has a higher earning
potential due to higher FSI. The earning potential cannot be
increased by simply increasing the selling price of the property.
While Bakeri city has a high earning potential due to the higher Fig. 4: Earning potential for two case studies
basic sale price of the land.
As mentioned above, Godrej garden city produced the same
number of units in 10 years that Bakeri City constructed in 8

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For 3 bhk unit Bakeri city Godrej garden city per sq ft


Rate per sq. ft. 4050 3690
Unit cost 7350750
Area of the unit (3bhk) sq.ft 1815 1800
Discount 15% 1102612
Net cost 6248137 6642000
Maintenance Advance 252000 140 rs
Legal charges 10000
AMC charges 27,000 15 rs
Area Development charges 180000 100 rs
Club house charges 20000
Fig. 5: Possible earning potential for Godrej Garden City Total 6792637.00 7131000
544500.00
Service tax 245893.4594 863460 13
Again the result has been derived by keeping a constant sale
Registration fees @1% 67926.37 71310
price. This price would increase by 15-20% every year (primary
survey of developers in Bakeri group). The anticipated date for Stamp duty 307500 325458 4.9
project completion for Garden City is 2020.In the current year, Total 7413956.83 8391228
the potential is 17277; the table shows the outcome, if it would
have completed by 2014 and then followed by 2016. The
CONCLUSION AND FINDINGS
earning potential right now (17277) is almost half as much as it
could have been (30511). Even though Gujarat has a single window process, there are
delays in the project due to rigid scrutiny and approval process.
Developers Role Godrej garden city was initially rejected and then approved in
TABLE IV: Project cost bared by the developers in both the case studies. 2009.This rejection happened at the state level intervention.
Godrej Garden City Bakeri City The single widow process states, to authorize a development
Offsite Developer bears the Developer pays commissioner to exercise powers equivalent to that of a state
infrastructure entire cost betterment and government body. Under the township policy, the state
development charges government appoints a prescribed officer different for
for 40% of the
surrendered land
townships developed in Municipal areas and those developed
Maintenance Cost The developer bears for The developer within AUDA or AMC boundary. Within 30 days from the
at least 7 voluntarily bears for t h e receipt of application they have to recommend the state to either
years (policy) first three years on an approve or reject the township approval. However the screening
average. committee comprising of principle secretary, UDDvii principle
secretary, Finance department, Officer on special duty, UDD,
Project Cost comparison again reviews the proposal and then the state government gives
Here a 3bhk unit from having almost the same area are the gazette notification. Townships require fast track approval
compared on bases of the additional cost along with the net cost process to allow optimal return on capital. Since the DP has
of the unit. The difference in the net cost of the unit for the demarcated zones for residential areas, the stand alone schemes
township and Bakeri city is less. But area development charges, do not need a further approval. In a way, allowing the townships
club house charges and higher service tax are charged for the to come up in any zone, makes the process longer. If the DP
township that makes the unit almost 10 lakhs more expensive allotted special zones where the townships can be developed, it
than that provided by the housing schemes. The fiscal benefits would not have to go through the process of gazette notification
of the township policy regarding service tax waivers are not from the state government. The zone would be cleared at the
quite implemented here. time of DP plan approval process. This would reduce the
process by 1 year. Next obstacle is the Environmental clearance
which takes 8 months to 1 year.
High taxes and development charges, increase the selling price
of the property, thereby narrowing down its target group.
Instead of a fixed maintenance period of 7 years, the policy can
make it flexible like in the Bakeri city. This would reduce the
maintenance charge for the townships. Scheme wise
development and possession is faster than phase wise
development. This is because every phase in the township also
has a commercial or an institutional development to be
completed before launching it and applying for BU. Reforms in
the township policies, also cause delay in the process. Factors
TABLE V: Cost Comparison
like minimum area, maximum permissible FSI were changed in

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the Godrej garden city when the policy was revised in 2009. [9] (November 2010). Working with the Market, Approach to Reducing
Urban Slums in India. The World Bank, Finance, Economics and Urban
This prolonged the process by 6months in negotiations with the Development Department.
government. They also increased the residential area from 65% [10] (2015). Retrieved from www.ficci.com
to 87% in the revised plan. Housing schemes have the benefit of [11] Alleviation, M. o. (2011-2012). Annual Report.
flexible land use, whereas the townships have to stick to the [12] Bank, N. H. (2012). Trend and Progress of Housing in India.
[13] Darshini Mahadevia, R. D. (September ,2014). City Profile:Ahmedabad.
policy regulations. Entering in a PPP agreement with the [14] ITPI. (199). Urban Development Plan Formulation & Implmentation
government would benefit a township, in terms of external Guidelines. New Delhi: Ministry of Urba Affairs and Employment,GoI.
infrastructure connectivity, extension of land and faster [15] LaSalle, J. L. Affordable Housing in India.
[16] Pritam P Hans. (July 2013). Going to Town. MoneyToday .
approval process. For PPP project, the mobilization of [17] Roy, M. (2006-2007). Comparative assessment of townships in real estate
resources also becomes speedy. market. Thesis, Ahmedabad.
[18] Today, I. (n.d.). businesstoday.intoday.in.
REFERENCES
[1] (n.d.). Retrieved from www.cseindia.org.
[2] (n.d.). Retrieved from www.urbannewsdigest.in
[3] Utpal Sharma. (2007-2008). Integrated townships towards development
of the city: a case of Pune. Thesis.
[4] ww.cushmanwakefield.com. (n.d.).
[5] www.nhb.org.in. (n.d.).
[6] www.mhupa.gov.in. (n.d.).
[7] www.spa.ac.in. (n.d.).
[8] Wakefield, A. C. (April 2014). CHALLENGES & OPPORTUNITIES
FOR THE HOUSING SECTOR IN URBAN INDIA. Research Publication.

i
GUDC-Gujarat Urban Development Corporation is positioned to facilitate by
assisting state government and existing agencies in formulation of policy,
institutional capacity building and project implementation and to assist in the
funding and implementation process.
ii
EWS- Economically Weaker Section-Households with monthly income upto
5000 Rs. as revised by the Ministry of Housing and Urban Poverty Alleviation,
Government of India
iii
LIG- Low Income Group-Households with monthly income between 5001
Rs.- 10,000 Rs. as revised by Ministry of Housing and Urban Poverty
Alleviation, Government of India
iv
AMC- Ahmedabad Municipal Corporation is the local self government of the
city which emerged as the first people's representative council or democratic
body in India. It is responsible for the civic infrastructure and administration of
the city.
v
AUDA- Ahmedabad Urban Development Authority (AUDA) was established
by the State Government of Gujarat. The prime objective of the AUDA's
formation was to carry out the sustained planned development of the area
falling outside the periphery of Ahmedabad Municipal Corporation. In addition
to the area falling under the Ahmedabad Municipal Corporation's limit, it also
includes 5 growth centers and 169 villages of Ahmedabad district.
vi
GTPUDA ACT-Gujarat Town Planning and Urban Development Act
vii
UDD- Urban Development Department

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