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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
Jan 2006

1. Concept
2. Proposed Idea (Summary)

3 Next Steps (for BMC and NGO Council)
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
7. Locality
8. Management

9. Support needed from MCGM
10. Various Levels of Engaging with BMC 
11. Time and Hierarchy Level for resolving ALM issues
12. Funds for an ALM to carry out the various activities and fulfill its various responsibilities
13. Role and Responsibilities and Authority of an ALM, the residents, and the BMC vis-a-vis each other
14. Regulating ALM's / 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: ALMs to be partners of BMC in micro-planning, implementation, awareness creation, monitoring and feedback so as to help BMC to fulfill BMC's mandatory obligations of properly providing civic services to the city of Mumbai.

2. Proposed Idea (Summary): ..............  

3 Next Steps (for BMC and NGO Council):

- Discuss with ROCS ? Fed. of Co-op Soc.

- Discuss with Ward Officers & Councillors

- Discuss with ALMs / DVYs

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

- Figure out how to define ALM 'size' & 'boundaries'

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

Steps taken: 
 - 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. Citizensí 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.  

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 self-appointed or 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 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 following ALM re-structuring is suggested.

5. Roles and Responsibilities of ALMs and the services, infrastructural and funding support needed from BMC:  

There are 4 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 by 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?   

Hopefully, this should result in a fresh concept for ALMs. An example is below:  

- The minimum size of 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 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.

List of Possible Activities of an ALM:  

ALMs to be suitably empowered for the following civic areas to ensure enforcement of BMC Rules:

[  ] segregation of dry and wet waste  
[  ] composting of biodegradable waste  
[  ] selling off or giving away of recyclable waste - through ragpickers, BMC, on own  
[  ] clearing off of debris promptly and separately from other waste  
[  ] sweeping and garbage pick-up by BMC incl. from waste bins and dustbins  
[  ] beautification and tree plantation within and outside ALM premises  
[  ] nuisance from nearby slums - garbage, urinating, defecating, 'dadagiri', etc.  
[  ] gutter cleaning by BMC  
[  ] stray dogs, cattle, etc. (with help of empanelled Animal Welfare Orgs)  
[  ] other nuisance complaints - littering, urinating, etc.  
[  ] traffic-related issues - parking, signals, dividers, road repairs, footpath repairs, street lights
[  ] encroachment on footpaths - hawkers, vagrants, miscreants, nearby slum dwellers  
[  ] nuisance from hawkers - footpath traffic, littering, garbage, encroachment, noise, etc.  
[  ] nuisance from shopkeepers or commercial organisations  
[  ] water  
[  ] electricity  
[  ] rodents  
[  ] noise  
[  ] air pollution  
[  ] unauthorised advertisements, poster and political banners, construction  
[  ] attendance and representation in LACC 

[  ] ..................      

Other Roles:

[  ] Communicating Rules & Procedures to its Constituent members 
[  ] to be involved in Disaster Management Procedures
[  ] medical services
[  ] ..................      

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.     

What are the various options of defining 'locality'? What are the pros and cons of each?  

Some Criteria: 
a) they need to be physically located next to each other within a defined geographical area.
b) there has to be some common defining character / characteristic e.g. Marine Drive vs. Marine Lines
an area which is easily understood in common parlance e.g. Nariman Point or Khotachiwadi
a "group" of buildings/societies/structures that have a unifying identifiable character or distinct association.  
look at the city map and physically define based on size and character  
f) ......

Some suggestions for size:
- minimum 1000 / 2000 families?
- maximum 10000 / 20000 families?
- polling booth - there are 8100 - easy for govt administration but too many and too heterogenous a mix
- slums, industrial, commercial may lend themselves to easier defining except that each may be too large
- by councillor ward - 227 - these are too large in geographic size and heterogenous, even though they are equal in population size
- by pin code - doesn't seem relevant
- lane (not a long road) -- i.e. the Cooperative Housing Societies (CHS's) on both sides of a lane. Where lane/street/road is very large or undefined, maybe an ALM must include at least 5 multi-storeyed  buildings / co-operative societies that are adjacent/geographically connected to each other, and cover at least 1000 families/households/units. (this suits the numbers required, since 1000 families is approx. 4000 persons, so the city will then have approx 15 million/4000 = 3750 ALMs - that is quite manageable - some wards will have more based on population, etc. Also Dattak Vasti will replace ALM in slum areas, via 400-500 Dattak Vastis. If 40% population are in non-slum areas, then 1500 ALMs will cover the city.)

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.    

appropriate permissions, authorisation, funds, support, incentives, etc.    
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.   

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.    
MCGM internal procedures and policies to be suitably changed as and when better suggestions obtained.    
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
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.     

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  
    d) after a month -- at M C level
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, 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 fines from offenders. 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.
b) from Residents: ALMs to be empowered to collect agreed-upon fees 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. In return, ALMs have to be formally acknowledged and empowered. 
      Note: BMC already has a relationship with the Co-Op Housing Society since it colllects taxes and charges from Members and residents of the societies. The ALM framework must recognize this and build on this. All co-operative societies must compulsorily nominate one resident 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.    
b) ALM and Residents: Residents have to follow what such a duly-elected ALM  truly-representative says. 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 .        

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) Co-operative Society:  

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