Draft of New Proposed
ALM Structure by MCGM - NGO Council
Index of Contents:
2. Proposed Idea (Summary)
3 Next Steps (for BMC and NGO Council); and Steps taken
Need for restructuring the existing ALM structure:
5. Roles and Responsibilities of ALMs and the services, infrastructural
and funding support needed from BMC
Advanced (definition) and list of possible activities of an ALM
Locality (definition) – criteria for “size” and “identity” of locality
8. Management (definition)
9. Support needed from MCGM
10. Various Levels of engaging with BMC
11. Time and Hierarchy Level for resolving ALM issues
12. Funding sources for an ALMs
13. Role and Responsibilities and Authority of ALM, residents, and
BMC vis-a-vis each other
14. Regulating ALMs / Possible Legal Entity for an ALM
15. Review of the working of ALMs, BMC, and BMC-ALMs
16. Potential Problems / Issues
17. Synopsis of LACC (for reference)
1. Concept: Citizen groups to be formal partners of BMC in micro-planning, implementation, awareness creation,
monitoring and feedback so as to help BMC to better fulfill its mandatory
obligations of providing civic services to the city of Mumbai .
2. Proposed Idea (Summary): ..............
Next Steps (for BMC and NGO Council):
with Registrar of CS ? Fed. of Co-op Soc.
with Ward Officers & Councillors
with ALMs / DVYs
with interested NGOs e.g. AGNI, Dignity, CSF, AIILSG
out how to define ALM 'size' & 'boundaries'
roll out with existing ALMs even before registration in Coop. Soc.
(invite selected ALMs, or take up one Ward)
examples of citizen groups in other cities. Eg.: Bhagirdari in
New Delhi , and Janaagraha in
with ALMs on 6th and 9th Jan
Need for restructuring the existing ALM structure:
a) Citizens residing in or using authorised structures and paying
their taxes to the BMC are often dissatisfied by the responsiveness
of the BMC to their complaints and suggestions. Citizens’ charters
and a computerised complaint management system need to be backed
up by organised structures within and outside the BMC to improve
the delivery of civic services and responsiveness of the BMC through
b) Experiments tried out in the past such as ALMs and LACCs have
yielded valuable experiences but have inherent limitations as the
local citizen groups or ALMs are either individual volunteers, or
NGO representatives who are informal, or local citizen groups, recognised
by the BMC officials on the basis of some good work done by them
in waste segregation and management.
c) For the purposes of achieving scale and for providing a sustainable
organisational structure for the involvement of local citizens groups
consisting of residents or commercial establishment in a local area
in a) the communication, implementation and enforcement of the Rules
and b) the overall cleanliness and upkeep of public spaces in the
concerned localities, the ALM re-structuring is suggested.
5. Roles and Responsibilities of ALMs and the services, infrastructural
and funding support needed from BMC:
There are 5 aspects:
a) what are the different activities that an ALM can take up?
b) for doing these what is the infrastructural and service
and funding support needed from MCGM separately for each of these?
c) what is the procedural modality to be for interacting with
d) what is the mechanism if BMC does not respond to complaints?
e) What is the minimum qualification / requirements that an ALM
Hopefully, this should result in a fresh concept for ALMs.
An example is below:
- The minimum area covered by an ALM should be one lane. To have
one CHS as an ALM is just too unwieldy administratively for BMC
to deal with. Also the usefulness of ALMs to BMC is when public
spaces are included e.g. roads and footpaths.
- An ALM should agree to formally take responsibility of the various
areas / activities mentioned below. If not, what purpose is the
ALM fulfilling? Only of complaining? We need to be clear what is
the value that an ALM brings to the table.
- For each of these areas, the mandatory support required from MCGM
should be spelt out.
- We should also be clear about the responsibilities of residents.
Citizens have to move away from the 'we are free to dirty, your
job is to clean' mentality.
- To fund these activities, either MCGM should pay a big part of
the cost, as uniformly decided, or should enable ALMs to collect
funds via charges (in lieu of fines), advertising revenues, corporate
- A procedure for reviewing performance of ALMs by residents and
by BMC should be there. ALM office-bearers should be duly elected
or be properly representative of the locality.
- Periodic meetings between ALMs and BMC at various levels should
be there to review and modify procedures.
- The same to be applicable to various Local Citizen Groups e.g.
RWAs, CBOs, etc.
= Advanced Locality Management:
Each of the words are important.
6. Advanced == An ALM should be able to take on any / all
the activities listed below.
(Originally did 'advanced' quality 'locality' or 'management')?
List of Possible Activities of an ALM:
ALMs to be suitably empowered for the following civic areas
to ensure enforcement of BMC Rules:
6.1. Management of waste:
segregation, composting of biodegradable waste, recycling (through
rag-pickers, BMC, or independently)
6.2. Cleanliness of the locality:
ensuring sweeping and garbage pick-up by BMC incl. from waste bins
and dustbins, cleaning of drains, preventing public nuisance of
littering, urinating, defecating, vandalism, rodents, etc.
6.3. Beautification and Greening
6.4. Management of stray
dogs, cattle population, etc. (with help of empanelled Animal
6.5. Traffic and Roads-related issues - parking, signals, dividers, road repairs,
footpath repairs, street lights, repair of underground pipes / cables
6.6. Encroachment on
footpaths and public spaces - hawkers, vagrants, miscreants, nearby
6.7. Hawkers : nuisance
from hawkers - footpath traffic, littering, garbage, encroachment,
noise, etc. nuisance from shopkeepers or commercial organisations
6.8. Utilities: Management
of utilities such as water, electricity, etc.
6.9. Environment: Control
over noise and air pollution, as well as visual pollution such as
unauthorised advertisements, poster and political banners.
6.10. Unauthorised / illegal
6.11. Disaster Management
6.12. Information dissemination
6.13. Attendance and representation
at appropriate levels with BMC
== How to define 'locality'? In any case, the minimum size could
be a lane. It can not be one building or a couple of buildings because
when one is thinking of a system for an entire city, the number
of entities have to be a manageable number assuming the system works
& to have a workable system.
The following structure is proposed:
No. of units
Population covered by each unit
of Unit defined by
Arterial roads, physical boundaries of city.
Administrative unit for BMC
Roads, ward boundaries
For election purposes to the BMC
Local Area Citizen Groups
Roads, councillor ward boundaries
To facilitate formal BMC-Civil Society collaborations
Proposed new structure
At least a lane, both
sides of a road, a block, colony, complex
United by common interests / concerns
Existing – regulating guidelines proposed
In ‘A’ Ward, there are 4 Councillor Wards.
For Councillor Ward No. 3, 8
Local Area Citizen Groups have been proposed.
Each of these LACGs may have one or more ALMs or RWAs such as the Fort
Residents Welfare Association, the Nariman Point Churchgate Association,
the Oval Cooperage Residents Association, the Colaba Tourist Destination
Association (CTDA), etc. within it.
3 Nodes have been identified in Councillor Ward No. 2, where more
than one LACG is involved and where these LACGs will have to work
together: Flora Fountain, Kala Ghoda and Regal.
For the proposed new structure of the Local Area Citizens Group,
the following points are to be noted:
LACG must be registered as a Co-operative Society.
will allot a unique number to each LACG.
LACG can contain a number of smaller units such as ALMs, RWA’s,
housing societies, colonies, blocks, etc, and can be considered
to be a mini-federation of all these entities.
must cover a minimum population of 4000-5000 persons.
boundaries and demarcation of the LACGs will be jointly undertaken
by BMC and the local community.
of a building/entity in one or more LACGs is possible and permitted
where boundaries meet.
if any, in fixing the responsibility of a road / area that falls
along the boundary of 2 LACGs will be resolved jointly by the
BMC and LACGs and NGO Council, and using the established practices
for the same situation at Ward Level.
For the smaller entities (such as an ALM) below the LACG level, the
following criteria is specified:
be at least a lane
be bounded by roads
be both sides of a road
be a block with some defined characteristics.
be a complex or colony
be an area with a recognised character / identity
Management == It implies going beyond complaining and reporting and requesting.
It is necessary to have a joint system with BMC at all levels till
the problem is resolved. That means going beyond monthly ALM or
fortnightly LACC meetings. It also means that the Action Taken Reports
should be appropriately minuted at various levels of the BMC hierarchy,
and periodically reviewed in joint BMC - NGO Council - ALM meetings.
9. Support needed from MCGM:
MCGM to provide support as follows:
a) as mentioned in the relevant rules, procedures, circulars,
b) appropriate permissions, authorisation, funds, support, incentives,
c) MCGM to initially send a team to prepare a report jointly with
the ALM about the situation and remedial suggestions and to file
it with the relevant MCGM and/or police departments. Status to be
minuted in LACC meetings. Thereafter to send an enforcement squad
/ Nuisance Detector immediately when requested to do so by the ALM.
d) MCGM and other authorities to inform ALMs suitably in advance
about proposed activity in the ALM area to enable the ALM to give
feedback, prepare for it, inform citizens, etc.
e) MCGM internal procedures and policies to be suitably changed
as and when better suggestions obtained.
f) Monthly meetings should be held of all ALMs by the Assistant
Municipal Commissioner at the Ward Office.
10. Various Levels of Engaging with BMC:
a) ALMs to be manageable in number in each meeting level
b) Issues to be manageable in number in each meeting level
c) Generic problematic issues to be reviewed for systemic solutions
at appropriate decision-makers level
d) Specific unresolved issues to be reviewed and decision taken
at appropriate level
e) Issues to be plugged into existing BMC committees -- else new
committees be formed
f) Issues and policy decisions & minutes be publicly shared
for a) and b) --- fortnightly meetings at LACC level - one benefit
is that it involves the concerned Councillor also.
for c) and d) -- monthly meetings at Ward level with Councillors
for e) e.g. LACC
There could be individual ALM level web sites in due course that
should be accessible to all its residents and ward officers and
MCGM Head Office - MC level people. Data from the individual ALM
websites should be consolidated at the ward level and city
level after defining a common framework and terminology for identifying
common issues - eg. water, roads, stray dogs, encroachment,
etc. (Can possession of e-mail address be made compulsory?)
Such websites could also be very useful for ALMs for putting
up photographs of offending problems.
11. Time and Hierarchy Level for resolving ALM issues:
BMC should again make a formal affirmation of the Citizens Charter
( www.praja.org ) which states
what civic problem will be resolved in how much time period and
who in BMC is responsible for doing so.
Nodal ALM Officers should be appointed so that an ALM has to basically
deal only with that Nodal Officer. Generally, there would be 1-2
Nodal Officers per ward. The Nodal Officer should have sufficient
authority within the MCGM. Maybe the Asst Engineer (
Main ) can be this person.
Unresolved complaints should be dealt with at the following levels
a) fortnightly -- Councillor Ward level
b) fortnightly -- Ward Level
c) fortnightly -- at Addl M C level - monthly
d) after a month -- at M C level - quarterly
Minutes should be maintained along with Action Taken Report. Nominees
of the NGO Council to be included at each level.
For some specific type of complaints e.g. new encroachments, (new
illegal constructions - to be discussesd), there should also be
a fast track resolution mechanism.
H-West Ward ALMs (AMC - Mr. Anil Khote) have devised
a color coding system for tracking complaints - Green,
Orange and Red. The same could be followed
for all ALM and LACC complaints all over Mumbai.
12. Funds for an ALM to carry out the various activities and
fulfill its various responsibilities:
There are 3 possible sources of funds:
a) from BMC:
i) ALMs to be empowered to act as 'Agents' of BMC and
collect charges from offenders for cleaning up. This, however, does
not absolve BMC of its duties. ALM can also involve the BMC or Nuisance
Detectors when desired.
ii) Reduction in certain taxes / charges
levied by BMC.
b) from Residents: ALMs to be empowered to collect agreed-upon
fees (and charges?) from the residents there is a High Court order
enabling this or from the Co-operative Societies.
c) from Corporate Sponsors, or via fund-raising events, etc.:
ALMs are free to do so. Except if Corporate Sponsors need to publicise
their names, they have to follow standard norms which have to be
13. Role and Responsibilities and Authority of an ALM, the
residents, and the BMC vis-a-vis each other:
a) ALM and BMC: For this, ALMs have to be true representatives
of their locality. True representation can be either by having duly-elected
office bearers or by there being one representative of each Coop
Housing Society / commercial establishments / licensed hawkers.
In return, ALMs have to be formally acknowledged and empowered.
Note: BMC already has a relationship
with the Co-Op Housing Societies, commercial establishments / licensed
hawkers, since it collects taxes, fees and charges and / or from
them and or their Members and residents of the societies. The ALM
framework must recognize this and build on this. All co-operative
societies must compulsorily nominate one representative from their
side as being a representative of an ALM. [Necessary changes
in MCGM Legal Act and Maharashtra Co-operative Societies Act 1961
and MOFA (Maharashtra Ownership Flats Act), etc must be made.] [Are
b) ALM and Residents: [Residents have to follow what such
a duly-elected ALM truly-representative says - is this enforceable?]. Residents should
be encouraged to route their complaints to BMC through the ALM.
Accountability of an ALM to
be also defined.
Responsibilities of an ALM
to be also defined.
Note: The existing Co-operative societies act can give
a good framework to build on the same and if necessary be modified
also for the same. ALM responsibilities can be added to the
list of responsibilities that Office Bearers of a Housing Society
already have as per the Model Byelaws of Co-operative Housing Society
in Maharashtra . Model byelaws can
be prepared for co-operative societies / commercial establishments /
c) Residents i.e. Citizens and BMC: For BMC, it is part
of it's obligatory duties. For Citizens, it's the various rules,
procedures and fines that BMC promulgates from time to time.
14. Regulating ALM's / Possible Legal Entity for an ALM /
a) Corresponding requirements for Co-operative Society / Commercial
Establishments / Licensed Hawkers:
Just like there is a Federation of Co-operative Societies in Mumbai
that is the umbrella body of all Co-operative Socieites in Maharashtra
, the following legal structure could be present:
1.. All Co-operative Housing Societies must nominate one
member from their side to be part of an ALM.
2.. The ALM thus formed must be a registered under the Registrar
of Co-operative Societies, and can be considered as a Mini-Federation
of Co-op Housing societies concerned for the problems of the immediate
3.. ALM responsibilities can be added to the list of responsibilities
that Office Bearers of a Housing Society already have as per the
Model Byelaws of Co-operative Housing Society in Maharashtra.
4.. Necessary changes in MCGM Legal Act and Maharashtra Co-operative
Societies Act 1961 and MOFA (Maharashtra Ownership Flats Act), etc.
must be made.
5.. The existing Co-operative Societies Act can give a good
framework to build on the same and if, necessary, be modified also
for the same.
6.. ALM then has to follow the accounting, management,
legal, and statutory norms. The Registrar of Co-operative Societies
becomes the monitoring agency for such things rather than BMC. Specific
Model Bye-laws to be made. These could be done in conjunction with
the RoCS so that an ALM Co-operative Society can be a distinct type
of a society, just as a Housing Society is a distinct society.
b) Trust with the Charity Commissioner -- Problem is
that Elections are not mandatory. So not ok.
c) Informal Group as present -- Can not be a recommended
way for a City.
15. Review of the working of ALMs, BMC, and BMC-ALMs:
a) ALM working can be reviewed by third-party NGOs. Accountability
issues to be also looked into.
b) BMC working can be reviewed by ALM committee (?)
c) BMC-ALMs working can be reviewed by a joint BMC-ALM committee.
Nominee of NGO Council to be included in each.
16. Potential Problems
a) What if more than one ALM seeks to state a claim for
One thought: Once the ALM becomes a mini-Federation
of Housing (or other industrial societies) in a geographic area,
this problem will not arise.
17. Synopsis of LACC (for reference) For full circular, see www.karmayog.com/cleanliness/laccagni.htm
Background info/note on the LACC:
Local Area Citizens' Committees - since Dec 2004.
a. Geographic spread: one per Councillor
Ward i.e. 227 LACCs
b. Purpose: cleanliness, garbage,
water, sanitation, hawking, pedestrians, parking, roads, footpaths,
c. Committee: Asst Comm (Convenor),
Councillor, Jr. Engr. (maint), Jr. Engr (water), Jr. SWM Overseer,
Jr. Pest Overseer, ALMs, selected
citizen reps (VARs)
d. Meetings: every Saturday in MCGM
school. Asst Comm level must attend. Medical Officer, police, BEST,
utility officers to attend / be invited.
e. Responsibility: J.E. / J.O. to
minute, circulate, prepare action taken reports. Municipal Commissioner
himself will review monthly.
(LACCs however have too much to discuss in
each meeting to be easily effective. So our suggestion is of separate
Task Forces along with Nuisance Detectors.)