UBBL-2021: HUDD invites suggestions to proposed amendments

Jammu, Jan 15: In a significant development, J&K Housing and Urban Development Department (HUDD) has invited suggestions and comments from the public on proposed amendments to J&K Unified Building Byelaws (UBBL)-2021.

The suggestions have been invited by the Department through a public notice, bearing no date of issuance, displayed on its website. The department has fixed January 18, 2025 as the last date for submission of suggestions and comments.

It is this limited window of hardly four days or so for the public consultation process which has left the major stakeholders with frayed nerves.

Another major concern is that the proposed amendments have not been widely publicised through local newspapers and other means of information which will restrict the ability of citizens, including researchers, industry and environmental stakeholders to effectively and actively participate in this consultation process.

In fact, the manner in which the department has put this public notice on its website leaving no clue when exactly it has been issued, has also not been appreciated.

Environmental Policy Group (EPG) and Kashmir Chamber of Commerce and Industry (KCCI) among major stakeholders have taken a lead to share their concerns on this account.

In fact, the convenor Environmental Policy Group (EPG), Faiz Ahmad Bakshi, who is also secretary general of KCCI, has even written to the Chief Minister Omar Abdullah to air his (Bakshi’s) reservations and seek his (CM’s) intervention. The Chief Minister holds the charge of HUDD.

EPG, KCCI have sought extension of consultation period by a minimum of 90 days.

WHERE ONE CAN SUBMIT SUGGESTIONS TO PROPOSED AMENDMENTS

The documents are available at https://jkhudd.gov.in and suggestions and comments can be submitted to the Commissioner Secretary to Government, H&UDD, Civil Secretariat, Srinagar or via email to principalsecretaryhudd@gmail.com with the subject line “comments/suggestions on proposed amendments to J&K Unified Building Byelaws (UBBL)-2021”.

WHAT ARE RESERVATIONS OF EPG, KCCI

Environmental Policy Group (EPG) and Kashmir Chamber of Commerce and Industry (KCCI) have expressed concern over what they stated “insufficient public consultation process surrounding the proposed amendments to the Jammu and Kashmir Unified Building Byelaws (UBBL) 2021.”

EPG, a well known environmental advocacy organization in Jammu and Kashmir, while sharing its reservations with the Chief Minister, has stated that the current consultation framework presents several critical inadequacies that demand his (CM’s) immediate attention.

“The deadline of January 18, 2025, offers an exceedingly narrow window for meaningful public engagement, hindering our capacity to thoroughly evaluate the environmental implications of these regulations. Particularly concerning are the impacts on green spaces, water management, and sustainable construction practices, which require comprehensive analysis and stakeholder input,” Bakshi has pointed out.

Moreover, the communication of the notification concerning these amendments has been grossly inadequate, he has asserted.

“While the proposed changes are posted on the department's website, they have not been effectively disseminated through local newspapers, in either English or vernacular languages. This lack of publicity significantly restricts the ability of environmental stakeholders, including conservationists, ecological researchers, and engaged citizens, to contribute valuable insights regarding the environmental ramifications of the proposed modifications,” EPG has pointed out.

Bakshi said that the anticipated amendments would undoubtedly lead to substantial environmental implications throughout the Union Territory, influencing essential areas such as green building standards, rainwater harvesting protocols, solar energy initiatives, waste management solutions, and the conservation of ecologically sensitive regions.

“Therefore, it is crucial that environmental organizations are afforded sufficient time to evaluate how these changes align with sustainable development objectives and strategies for climate resilience,” he noted.

Additionally, EPG has advocated for a significant enhancement in the accessibility of the proposed amendments. “Organizing targeted consultation sessions that specifically address the environmental dimensions of the building bylaws—such as discussions on energy efficiency standards, green building certifications, and protective measures for the environment—would be highly beneficial,” it has suggested.

Furthermore, according to EPG, creating a dedicated platform for environmental organizations to submit comprehensive assessments would ensure that ecological concerns are appropriately integrated into the final regulatory framework.

“We also recommend the establishment of standard operating procedures that embed environmental impact assessments into all future amendments of building bylaws. This initiative should include the formulation of permanent environmental advisory committees and routine review mechanisms to confirm adherence to environmental protection standards,” Bakshi has written to the Chief Minister.

“Given the profound implications of the UBBL amendments for environmental sustainability and ecological balance within our Union Territory, it is evident that a thorough and inclusive consultation process is not merely desirable but essential for aligning these regulations with our environmental protection objectives,” he has opined.

Seeking immediate intervention of the Chief Minister to “rectify these issues and to promote a more inclusive and environmentally aware consultation process”, Bakshi has stated that such efforts will not only improve the quality of the final regulations but also safeguard the ecological health of the region for future generations.

Meanwhile, the KCCI too has echoed similar concerns regarding the proposed amendments to the Jammu and Kashmir Unified Building Byelaws (UBBL) 2021, notified by the Housing & Urban Development Department.

“The brief window is particularly challenging given that these are complex building regulations requiring detailed technical review by various professionals. The notification's dissemination has been notably insufficient,” it said.

“The lack of direct communication with professional bodies and trade associations has further limited public awareness. This is particularly concerning for rural and semi-urban communities who will be significantly affected by these changes but may remain unaware of them,” KCCI has pointed out.

“These amendments will have far-reaching implications for a broad spectrum of stakeholders across our Union Territory. This includes business chambers, architectural and engineering firms, construction companies, property developers, municipal corporations, urban local bodies, residents' welfare associations, individual homeowners, small business owners, environmental groups, and urban planning experts,” it stated.

Each of these groups deserved an opportunity to review and provide informed feedback on regulations that would directly impact their work and lives, it added.

While recommending a 90-day period for consultation, KCCI recommended that the extension should be accompanied by mandatory publications in leading newspapers across both regions, radio announcements in local languages, and official notifications through district administrations.

“Furthermore, the accessibility of these amendments needs significant improvement. Looking ahead, we would also recommend developing standard operating procedures for future building bye-law amendments, creating permanent stakeholder consultation committees, and establishing regular review and update mechanisms with public participation. A dedicated digital platform for continuous stakeholder engagement could further strengthen this process,” it proposed.