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  Home >> ALM / LACC >> Draft of New Proposed ALM Structure by MCGM - NGO Council


Draft of New Proposed ALM Structure by MCGM - NGO Council
23rd Jan 2006

Index of Contents: 
1. Concept
2. Proposed Idea (Summary)

3 Next Steps (for BMC and NGO Council); and Steps taken
4. Need for restructuring the existing ALM structure:
5. Roles and Responsibilities of ALMs and the services, infrastructural and funding support needed from BMC
6. Advanced (definition) and list of possible activities of an ALM
7. 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): ..............  

3. Next Steps (for BMC and NGO Council):

3.1.  Discuss with Registrar of CS ? Fed. of Co-op Soc.

3.2.  Discuss with Ward Officers & Councillors

3.3.  Discuss with ALMs / DVYs

3.4.  Discuss with interested NGOs e.g. AGNI, Dignity, CSF, AIILSG

3.5.  Figure out how to define ALM 'size' & 'boundaries'

3.6.  Begin roll out with existing ALMs even before registration in Coop. Soc. (invite selected ALMs, or take up one Ward)

3.7.  Study examples of citizen groups in other cities. Eg.: Bhagirdari in New Delhi , and Janaagraha in Bangalore .

Steps taken: 

3.3 Meeting with ALMs on 6th and 9th Jan 

4. 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 citizen participation.  

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 BMC? 

d) what is the mechanism if BMC does not respond to complaints?   

e) What is the minimum qualification / requirements that an ALM must have?

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 sponsorships, etc.

- 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.   

ALM = 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 of locality
6.4. Management of stray dogs, cattle population, etc. (with help of empanelled Animal Welfare Orgs)  
6.5. Traffic and Roads-related issues - parking, signals, dividers, road repairs, footpath repairs, street lights, repair of underground pipes / cables of utilities
6.6. Encroachment on footpaths and public spaces - hawkers, vagrants, miscreants, nearby slum dwellers  
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  construction
6.11. Disaster Management
6.12. Information dissemination
6.13. Attendance and representation at appropriate levels with BMC    

7. Locality == 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

Limits of Unit defined by

Reason for unit







Arterial roads, physical boundaries of city.

Administrative unit for BMC

Existing unit


Councillor Wards



Roads, ward boundaries

For election purposes to the BMC

Existing unit


Local Area Citizen Groups

Approx. 3000

4000 - 5000

Roads, councillor ward boundaries

To facilitate formal BMC-Civil Society collaborations

Proposed new structure



30000+ variable


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:

  1. The LACG must be registered as a Co-operative Society.
  2. BMC will allot a unique number to each LACG.
  3. An 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.
  4. LACGs must cover a minimum population of 4000-5000 persons.
  5. The boundaries and demarcation of the LACGs will be jointly undertaken by BMC and the local community.
  6. Overlapping of a building/entity in one or more LACGs is possible and permitted where boundaries meet.
  7. Differences, 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:

  1. Must be at least a lane
  2. Can be bounded by roads
  3. Can be both sides of a road
  4. Can be a block with some defined characteristics.
  5. Can be a complex or colony
  6. Can be an area with a recognised character / identity

8. 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, etc.    
b) appropriate permissions, authorisation, funds, support, incentives, etc.    
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.    
g) .....

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 ( ) 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 till resolved:
    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 set.  

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 changes required?]    
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 / licensed hawkers.      

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 geographic area.

  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 / Issues:  

a) What if more than one ALM seeks to state a claim for a locality?   
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 

 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, etc.  

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.)  


It is one of the beautiful compensations of this life that no one can sincerely try to help another without helping himself. --Charles Dudley Warner