Express Investigation | Adani-Maharashtra roadmap for Dharavi: state clears move to shift over 50,000 people to waste dump

The Dharavi redevelopment roadmap

Indeed, as per CPCB’s 2021 guidelines for development projects in a “closed” landfill – one that’s no longer in operation — facilities such as hospitals, housing and schools cannot be built inside a landfill and a 100-metre no-development-zone from its boundary is mandatory.

But Deonar is no closed landfill; instead, it’s an active landfill, spewing toxic gases and discharging leachate (the liquid that drains out of waste piles, potentially contaminating groundwater, surface water and the soil with toxic organic and inorganic pollutants).

According to a 2024 CBCB report submitted to the principal bench of the National Green Tribunal, an average 6,202 kg of methane is emitted from the Deonar landfill every hour, making it one of the top 22 methane hotspots in India.

Which is why, the state’s decision to move Dharavi residents to the Deonar landfill site raises several questions – and eyebrows.

The roadmap for rehab

Of the 600-acre sprawl of slums and factories that make up Dharavi, 296 acres have been earmarked for the Dharavi Redevelopment Project (DRP) that aims to transform Asia’s biggest slum into a modern urban hub with improved housing and amenities. It proposes to provide in-situ and ex-situ rehabilitation to the residents living there. Senior IAS officer SVR Srinivas is the CEO of the project.

The redevelopment will be carried out by the Dharavi Redevelopment Project Private Limited (DRPPL), now called Navbharat Mega Developers Private Limited (NMDPL), a special purpose vehicle (SPV) in which Adani Properties Private Limited (APPL) holds 80% and the balance 20% is with the state Housing Department’s Slum Rehabilitation Authority (SRA). Srinivas is also the Chairman of NMDPL. As per the records available with the Registrar of Companies, NMDPL’s paid-up capital is Rs 400 crore against an authorised capital of Rs 5,000 crore.

Besides Srinivas, BMC commissioner Bhushan Gagrani is also a director in this special purpose vehicle.

There are nine other directors on the board of NMDPL, including Pranav Adani who is also a director on the board of Adani Enterprises. The other eight are senior executives or directors of various Adani Group companies.

Srinivas said while construction work on the Dharavi rehabilitation project will begin by the second half of 2025, NMDPL has a seven-year deadline for rehabilitating the residents, both within and outside Dharavi.

Beneficiaries under the Dharavi project have been divided into two categories: eligible (those who had housing structures built on or before January 1, 2000) and ineligible.

While almost 1.5 lakh “eligible beneficiaries” will get “in situ rehabilitation”, meaning free housing units at Dharavi itself, the government announced that nearly 50,000-1 lakh of the 4 lakh “ineligible beneficiaries” will be given rental units at “nominal” rates at the Deonar dump.

For the remaining “ineligible” residents, the government has earmarked land at Kurla Dairy, Wadala and the salt pans between Kanjurmarg and Mulund.

Records obtained by The Indian Express show that on September 27, 2024, the BMC handed over 124 acres within the larger 311-acre Deonar landfill to the state government for the rehabilitation project. Since then, no waste has been dumped in the site.

Once the survey of beneficiaries is done, housing department officials said, this land will be handed over to the NMDPL.

The 124-acre land parcel allocated to NMDPL contains nearly 80 lakh MT or 40 per cent of the total solid waste at the dump at present.

Each agency has its own reason

The Indian Express contacted each of the key stakeholders involved in the project to ask why and how so many people were being housed in an active landfill site. The response of each is telling.

DRP CEO Srinivas said that given the “crisis of land” in Mumbai, there are “few options” when it comes to getting large land parcels for development. “In total, we will need an approximate land size of 200-300 acres for the Dharavi Redevelopment Project. Therefore, considering the limitations, we chose the Deonar landfill,” he said.

Both the state government and the Slum Rehabilitation Authority (SRA) said it was NMDPL that selected the site.

Said Mahendra Kalyankar, CEO of SRA: “Even though we own 20% stake, the onus of selecting the land parcel was with DRPPL (NMDPL) since they are a special purpose vehicle responsible for executing the project. The decision of selecting the said site was made by them which was later approved by the Housing Department.” Since the land didn’t belong to SRA, he said, the authority did not have much to do when it came to evaluating the norms.

Valsa Nair Singh, Additional Chief Secretary, Housing Department, said, “We only cleared the proposal based on the demand DRPPL (NMDPL) and the CEO (SVR Srinivas) made, as the decision of selecting and allotting a land parcel is being made at the level of project authorities and not at the government level.”

A detailed questionnaire was sent to the Adani Group asking why a hazardous landfill at Deonar was chosen for this project. The Adani spokesperson declined to comment.

The question of clean-up

Having chosen Deonar, an active landfill, as the site for the housing project, another big question remains: who cleans up the site?

Three months after the government directed BMC to hand over the land to the state, it asked the municipal body to carry out bio-mining (scientifically treat the waste) on the 124-acre Deonar land parcel. However, BMC handed over the land parcel in an “as-is” condition – with the legacy waste intact — to the state government.

When asked who would clean up the site, BMC Commissioner Gagrani told The Indian Express, “The land on which the Deonar dumpyard stands never belonged to the BMC. It was handed over to the civic authorities by the state’s revenue department in the early 20th century, specifically for the purpose of solid waste management. Now this land has been handed back as per the state government’s demands in an ‘as-is’ condition. As a result, the quantity of waste still remains there.”

While NMDPL declined to respond to a question on whether it would clean up the site, letters show that it put the onus on the BMC early on.

“Given the land has been used as a dumping ground in the past, appropriate action of cleaning the dump over next two years by BMC may also be tied up and facilitated,” read an April 2024 letter from NMDPL’s head of land acquisition to Mumbai’s Deputy Collector.

Next door, a Waste-to-Energy plant

What puts another question mark on the proposed housing project in Deonar is its proximity to two upcoming power plants: a Waste to Energy (WTE) plant the state had approved in 2018 and a bio-CNG plant cleared in 2023.

These projects are meant to process Deonar’s daily waste of 600-700 MT (that’s 10 per cent of the solid waste generated by Mumbai daily). In fact, BMC had cited these two plants to express its inability to hand over a larger parcel of land as demanded by NMDPL.

Records show that while the NMDPL had earlier asked for 305 acres for the project, the BMC said it couldn’t part with all this land since it required 74 acres for the operation and maintenance of the WTE plant as well as daily solid waste activities.

A December 4, 2023 letter, signed by BMC Deputy Municipal Commissioner, Solid Waste Management, and submitted to the SRA and the NMDPL, reads, “As the MoU (memorandum of understanding) is signed with Mahanagar Gas Limited (MGL) for the proposed bio-CNG plant at DDG, the transfer of land will attract legal and financial obligations…There is no alternate land available for setting up the WTE plant as well as the bio-CNG plant in Mumbai.”

BMC records show that the proposed WTE plant will be less than 50 metres from the DRP site while guidelines of the Union Ministry of Housing and Urban Affairs stipulate that such plants must be at least 300-500 m from residential zones — and located only in land zones dedicated to medium or heavy industry.

WTE plants are bigger and emit ash and smoke, thus affecting the air-quality of a locality, while bio-CNG plants are relatively cleaner.

To why people were being rehabilitated so close to the WTE and bio-CNG plants, Srinivas said, “These parameters will be considered once the EIA (Environment Impact Assessment) is carried out before the construction. The main issue is open dumping of solid waste. Landfills should be sanitary in nature, which means that all waste coming there should be treated scientifically. However, that is not happening at Deonar. The BMC needs to find a solution for that.”

No environment assessment

However, the EIA that Srinivas referred to is yet to be undertaken. According to replies from the Slum Rehabilitation Authority (SRA) and the Maharashtra Pollution Control Board (MPCB), no EIA has been done yet.

“No such (EIA) assessments have taken place so far,” said the response from the SRA.

The EIA is a mandatory self-assessment that NMDPL was required to do at the planning stage – it’s on the basis of this that the government grants an environment clearance.

To a question on the absence of an EIA, Srinivas said, “Before we start construction, we will apply for environmental clearance.”

The office of Deputy Chief Minister Eknath Shinde, who holds the Housing portfolio, too, said, “All necessary environmental clearances will be taken for construction in the Dharavi project.”

When asked why Dharavi residents were being relocated to a land which is so close to a WTE plant — a violation of the CPCB norms – the Adani Group declined to comment.

On the lack of green clearance so far, Avinash Dhakane, member-secretary of the MPCB, the consenting authority for establishments inside landfills, said the state pollution control board was “not consulted before sanctioning the land parcel for the said project”.

“The official guidelines state that carrying out any kind of development or infrastructure work that will require an area more than or equal to 20,000 square metres (49.4 acres) will require an environmental clearance, before they can go ahead with it,” he said.