Hojjatul Islam Ahmad Hossein Falahi, the representative of the people of Hamadan and Faminin in the parliament, in a letter addressed to the Minister of Roads and Urban Development, requested to remove the ambiguities and deficiencies in the proposed master plan of Hamedan city, the text of which is as follows.
Honorable Minister of Roads and Urban Development
Greetings
Following the meeting held between me and Ms. Engineer Sadegh Malvajard, the honorable deputy of urban planning and architecture of the Ministry of Roads and Urban Development and the honorable secretary of the Supreme Council of Urban Planning and Architecture of Iran on 11/11/99 regarding the surrounding issues of the "Hamadan City Comprehensive Urban Plan", the general results of the review of the studies under preparation of the "Hamadan City Comprehensive Urban Plan" by the respected members of the Comprehensive Plan Committee of the Technical Working Group of Injanb's office, which consists of Experts in urban planning, urban development, architecture, passive defense, traffic, etc … are- Based on the approvals of the Supreme Council of Urban Planning and Architecture of Iran, centered on the approval of the "Guidelines for Identifying the Basis of the Master Plan of the City" in the aforementioned meeting, relevant suggestions were made to continue the work, which will be mentioned in the following lines.
As you know, the Hamadan City Master Plan contract dated 12/28/1395 between Hamedan Provincial Road and Urban Development Department and Naqshjehan Pars Consulting Engineers with the vision of "Hamadan 1410" with special axes such as a green city for citizens and an attractive environment for tourists on a national and international scale, a safe city that is resistant to damage and hazards, a cohesive and integrated city from a social point of view and free from Discrimination and prejudice and … has been concluded.
Despite the fact that according to Article 21 of the "Regulations on how to review and approve local, regional, regional and national development and construction plans and the country's urban planning and architecture regulations approved by the Council of Ministers in the meeting dated 10/12/1378 and amended based on the Supreme Council's resolution dated 19/02/1384", the Secretariat of the Urban Planning and Architecture Council of the province is obliged to carry out comprehensive urban and regional plans at various stages. and bring the urban complexes to the knowledge of the members once every three months through the producers of the said plans in the Provincial Urban Planning and Architecture Council and provide the necessary coordination in the field of exchanging information, programs and obtaining opinions in the process of preparing the plan and after the approval of the said plans and closely monitoring their implementation, report the executive progress plan of the work to the Provincial Council in 6 months and seek solutions to solve the implementation problems and send a copy of the said report and the decisions made to the secretariat send the Supreme Council; But unfortunately, the existence of fundamental problems in the current process of the "Hamadan City Comprehensive Urban Plan" brings to mind the question, why until now this council has not fulfilled its duties properly in finding solutions to solve the problems of the plan and has brought the work to a point where after 3 years of the beginning of the plan, enough basic problems have remained in force?
It is clear that if there is no review of the following cases and the cases that I will raise in the near future, the considered strategies, including loading the population in the city areas in accordance with the capacities and environmental capabilities, organizing the system of heights and building density of the city, developing housing support programs for the low and middle income classes, active intervention to prevent the continuation of the social division and class gap in the geography of the city and the active protection of the gardens within the boundaries, They will not work properly.
The results presented in the meeting 11/9/11 are as follows
۱- In line with the implementation of Clause 2 of Article A of the Resolution of the Supreme Council of Urban Planning and Architecture of Iran entitled "Instructions for Identifying the Basis of the Master Plan of the City" as well as the serious issues in the field of water resources, it is necessary to determine the population capacity of Hamadan city and, accordingly, the final development limit of the city, and to prevent any population loading and activity beyond the population capacity of Hamadan city. However, such a part is not seen in the conducted studies.
۲- With regard to the resolution of the Supreme Council of Urban Planning and Architecture of Iran entitled "Regulations to Prevent the Increase of the Area of Cities" approved on 10/08/1378, the non-realization of the densities predicted in the plans and the city's population capacity until years beyond the horizon of the plan, expanding the area of the cities even after the end of their ten-year implementation period is not logical, and the result is nothing but the intensification of the destruction of agricultural lands and gardens around the cities, imposing exorbitant costs on the institutions responsible for providing urban services, and as a result, urban management becomes more difficult, lack of providing desirable and appropriate services to citizens, and finally, dispersal and ugliness of the appearance and landscape of cities.. One of the most important indicators affecting the expansion of the urban area is the population index. Due to the unsuccessful experiences in population estimation and the non-realization of the predicted population and its significant difference with the actual population of the city in the comprehensive urban plan of "Mojda" and the detailed plan of "Design and Development" (That is, with the estimated population of 620,000 people in the horizon of the 2014 plan; However, according to the general population and housing census of 2015, the population of Hamadan city is 554,405 people.)The approval of the Supreme Council of Urban Planning and Architecture of Iran regarding the "Hamadan Urban Complex Comprehensive Plan" approved on 07/22/2018, as well as the emphasis of the consultant of the comprehensive plan under preparation, on the decreasing trend of the population growth rate in recent years, the need for a fundamental revision in determining the "growth rate" in order to estimate the population of Hamedan city in a 10-year horizon, in line with not increasing the horizon of the nearly 30-year plan of the Mojda Urban Comprehensive Plan, and the irreparable consequences caused by It shows the urban developments and the lack of providing strategies appropriate to these changes.
۳- Based on the description of urban master plan services based on brigade 12 and also urban master plan with a strategic approach- Structurally, the consultant is responsible for gathering information about the current state of the city (It means the year 1996) especially in the physical field; This is despite the fact that in the studies related to this project, physical information provided in the general population and housing census of 2013 was used, which is important, especially regarding the information related to the number of floors due to the changes made. (Increasing the number of floors) Resulting from paragraph 1 of the meeting minutes dated 02/13/91 of the detailed plan commission (Article five) And its relationship with various issues such as population acceptance rate is important.
۴- In recent years, the description of urban comprehensive plans services, due to the failure of urban comprehensive plans with a strategic approach- A structure has been developed for various reasons, including the lack of supporting laws and platforms required for the preparation and implementation of these plans based on the 12th brigade.. According to the resolution of the Supreme Council of Urban Planning and Architecture of Iran dated 28/03/98, up to five cities of Isfahan, Sanandaj, Kerman, Natanz and Yazd were introduced as pilots for the preparation of urban development plans with a new approach, and in the resolution of the Supreme Council of Urban Planning and Architecture of Iran dated 02/04/99, this issue was re-emphasized and the city of Hamadan was not mentioned. This is despite the fact that the structure presented in the comprehensive plan studies of Hamedan city has a fundamental contradiction with the above-mentioned approvals.. Despite the discrepancy in the service description of this project and the emphasis on the strategic approach- Structurally, the zoning provided is based on 4 basic and distinct zones of residence, activity, mixed and protection (green and open) It has not been and only two residential and mixed zones have been defined for it.
۵- Despite the fact that the priority of the strategy should be in line with endogenous development, taking into account the existing capacities and the limits of horizontal development; But the current plan tends to increase the city area, emphasizing horizontal development. In this regard, it is necessary to use the capacities hidden in the worn-out tissues of the city in order to prevent the excessive horizontal expansion of the city, in order to avoid the wastage of the material capital of the city due to the unreasonable development of the infrastructure.
۶- One of the requirements for determining the direction of expansion of the urban area by the consultant is to conduct detailed expert studies, such an approach is not seen in the presented plan; Therefore, sometimes the boundaries of the city were extended in one direction and at another time in other directions.
۷- According to the resolution of the Supreme Council of Urban Planning and Architecture on "Hamadan Urban Complex Master Plan" approved on 07/22/98, the cities of Hamedan, Merianj, Laljin, Saleh Abad, Jurqan, Howrah and Bahar have been introduced as urban points of the urban complex.. Considering that this plan is beyond reach, the annexation of any of these urban points to the city of Hamadan is contrary to this plan; This is despite the fact that for months, there has been insistence for the annexation of some of the mentioned cities, including Merianj, to the limits of Hamedan city, which has resulted in wasting time and prolonging the process of studying and reviewing the master plan..
With regard to paragraph 1-5 of the resolution of the Supreme Council of Urban Planning and Architecture of Iran regarding the "Hamadan Urban Complex Master Plan", it is necessary to provide a map of the boundaries and limits of the cities located within the urban complex, and in order to resolve the interferences in the limits and boundaries of the cities of the complex, including the cities of Merianj, Jorqan and Hamedan, appropriate proposals should be presented for the future actions of the legal authorities.. The amendments emphasized in this meeting minutes have not been submitted to the Secretariat of the Supreme Council of Urban Planning and Architecture of Iran within the specified period.. It is necessary to pursue this issue as soon as possible so that it does not end up in the unsuccessful fate of the "South Hamedan District Master Plan" and the waste of the capital of the province.. It is worth mentioning that on 08/99/05, the "Master Plan of South Hamedan District" was canceled by the Supreme Council of Urban Planning and Architecture of Iran due to the lack of assignment by the province, thus, the opportunities and costs incurred for it were wasted.
۸- Unfortunately, in the proposed land use map of "Hamadan City Master Plan", some of the uses of the garden located in the urban area and within the context have been changed to residential use.. It is necessary to use all the gardens in the city limits, stabilize and change this use based on the resolution of the Supreme Council of Urban Planning and Architecture of Iran entitled "Instructions on how to determine the thresholds of fundamental differences in development and urban development plans" dated 06/30/94 as a change in the basis of the master plan.
۹- It seems that the annexation of the upper part of Faqireh village to the city limits, due to the topographical conditions of the region and the lack of access to infrastructure, can be considered and needs a more comprehensive investigation.
۱۰- According to the approvals of the Supreme Council of Urban Planning and Architecture of Iran, it is necessary that the area of the proposed boundary of Hamedan city should be determined up to 5 times the area of the city.. Therefore, it is necessary to consider this important in the final plan.
۱۱- Despite the emphasis made on environmental assessments(EIA) According to the approval of the Supreme Council of Urban Planning and Architecture of Iran regarding "Approved Tourism Plans", despite the uniqueness of the area of "Northern Domain of Alvand", no environmental assessment has been carried out in the studies related to it.
۱۲- The report related to the necessity of constructing tall buildings along with the located areas and the document of the rules for the establishment of tall buildings in the city based on the resolution of the Supreme Council of Urban Planning and Architecture of Iran with the subject of "Amendment of the General Rules for the Establishment of Tall Buildings in Iranian Cities" dated 21/08/99, (Notified on 17/09/99) It has not been prepared and compiled and therefore cannot be accepted; It is worth mentioning in paragraph 3 of this decree that the consulting engineers preparing "Regulations for the establishment of high-rise buildings in every city" are obliged to prepare the said document in accordance with the principles of development based on public transportation. (TOD) compile; However, such an approach is not observed in the relevant report.
۱۳- It is necessary to provide a table of the proposed city levels and per capita based on the actual amount of land allocation to each zone and sub-zone; However, in the proposed plan, this issue is presented in general.
۱۴- The proposed uses have not been determined exactly according to the resolution of the Supreme Council of Urban Planning and Architecture of Iran entitled "Checking the definitions and concepts of urban uses and determining their per capita" approved on 10/03/98.
۱۵- In the map of proposed uses, a use with the title "requiring a special plan" has been proposed, which has not provided a clear plan and plan regarding the type of use and activity of these levels.
۱۶- Considering the lack of transparency regarding the examples of citizens' acquired rights and the problems and dissatisfactions caused by the previous "development and urban development" projects of Hamadan city, it is necessary to follow this issue seriously in order to crystallize it in the comprehensive plan of the city.
۱۷- Respecting the acquired rights of the beneficiaries in changing some uses has not been respected; It is clear, the change of residential uses to educational use due to the establishment of educational activities (non-profit) In the current situation, it is against the acquired rights of the citizens of Hamadan city.
۱۸- In order to maintain order and chaos resulting from the dispersion of administrative uses in Hamedan city, it seems necessary to locate and position the administrative town in order to establish administrative uses at the level of "important centers".
۱۹- Threshold of fundamental discrepancies determined in the detailed plan needs serious revision.
۲۰- The rules and criteria of passive defense presented in the comprehensive plan studies of Hamedan city, should be reviewed based on the approval of the Supreme Council of Urban Planning and Architecture of Iran regarding the "Instructions for Requirements and Considerations of Defense and Passive Defense" dated 02/11/96 in the two dimensions of the boundaries and boundaries of the city in the form of all 22 clauses and in a practical, operational, local way and with the presentation of a map, and the topics of desirable development directions, Vulnerability intensity zoning based on morphology, vulnerability intensity zoning based on population density, vulnerability intensity zoning based on building classes, impermeable and irregular urban tissues, should be specially investigated.
Since the passive defense comprehensive plan of Hamedan city is currently being compiled, it seems that the use of the outputs of that plan can eliminate some of the shortcomings of the passive defense annex of the comprehensive plan of Hamedan city being compiled.
۲۱- Regarding the traffic study report of Hamedan City Master Plan, the following points are relevant:
۲۱-۱- It is unclear how to use models of comprehensive studies of transportation and city traffic in future estimates. It is not known what details were used in those models? Have all the four stages of demand estimation using the macro model been used in the evaluation of the proposed proposals or not? Has the estimation accuracy of the 2017 models been evaluated for the current situation or not?
۲۱-۲- The statistics conducted at the selected gates and arches of the road network inside the city have not been properly used.. These statistics are generally collected to modify the trip matrix and to estimate and update them; However, this issue is either neglected in these studies or is not clearly presented in the reports. In addition to that, flaws in time (season and day) Statistics and its results can also be seen. For example, in the volume statistics presented, the volume of traffic in the morning rush hour was lower than in the evening, which seems unreasonable.
۲۱-۳- It is necessary to provide all kinds of proposed plans such as tunnels and uneven intersections with economic justification and accurate traffic models; However, such an approach is not seen in the current studies.
۲۱-۴- The used traffic allocation model is chosen from the shortest path type, which can only be applied in cities with very light traffic, and its results in Hamadan city are not correct at all.. For allocation in networks with traffic congestion, balancing methods that consider the actual behavior of passengers in choosing the route should be used.
۲۱-۵- It is necessary to see the effect of changing the uses recommended in the master plan on the traffic balance and traffic volumes in the city. In other words, to solve the existing and future traffic problems of the city, it is possible to use the change of uses in major centers to attract and create traffic.
۲۱-۶- The results of traffic allocation in the study horizon do not seem real. To trust the results, as it was said in the first case, the accuracy of estimation of 2007 models for the current situation should be evaluated.
It is worth mentioning that considering that currently, the traffic master plan of Hamedan city is being reviewed; Certainly, the use of more realistic data compared to 2007 - which is currently being used in the traffic appendix of the proposed comprehensive plan of Hamedan city - will bring valuable results and prevent the revised traffic comprehensive plan from being useless in the future.
In the end, I, on behalf of the noble people of Hamadan, in line with the supervisory aspect of my representational duties, strongly request to remove the ambiguities and deficiencies in the proposed comprehensive plan of Hamedan city so that in the future we will have a city worthy of the citizens of Hamadan. I believe that ignoring this issue will lead to irreparable damages for my clients. In this regard, it is suggested that due to the many problems in the studies of the proposed comprehensive plan of Hamadan city - which can sometimes be caused by the consultant becoming passive due to the lack of independence in decision-making - while removing the possible obstacles to the independence of the plan consultant, it is suggested to avoid rushing to finalize this plan in 2019 and to use the opinions of another consultant in addition to the current consultant in order to monitor and fix the existing problems.. It is obvious that the supplementary consultant should have the qualification of consulting in various fields of urban planning, traffic, passive defense and so on …, has more comprehensiveness than the current consultant.
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