SRINAGAR: The proposed Rs 104.02-crore Plug-and-Play Industrial Park at Nowgam has come under intensified environmental and planning scrutiny, with two environmental groups questioning its compatibility with the Srinagar Master Plan-035 and a State Administrative Council decision that explicitly restricted construction along the Pantha Chowk=Nowgam corridor because it forms part of a flood-absorption basin.
The Environmental Policy Group (EPG) has called for immediate judicial and statutory scrutiny of the proposed 50-acre industrial park, while the Peoples’ Environment Council (PEC), in association with the Nigeen Lake Conservation Organisation (NLCO), has sought a multidisciplinary review of the proposed location before any final decision is taken.
The two groups have stressed that their objections are not to the industrial park as an investment or employment-generating initiative, but to its proposed location in a landscape that Government’s own planning and post-flood assessments have identified as hydrologically sensitive.
The proposed project, being developed under the Government of India’s BHAVYA programme, envisages industrial plots, roads, utilities, warehouses, factory sheds, worker facilities and associated infrastructure.
EPG has said such intensive development could convert permeable and low-lying land into a built-up environment and alter the flood-storage, flood-conveyance and drainage functions of the wider Pantha Chowk–Nowgam landscape.
“Flood basins are not vacant land. They are natural public infrastructure, and their storage capacity cannot be treated as surplus land available for urbanisation,” EPG said.
PEC has similarly said its concern is with what it describes as an apparent policy and planning inconsistency: the proposed location of a major, long-term public investment within a landscape that Government itself has identified as highly flood-sensitive and closely associated with the functioning of the Jhelum floodplain.
In a rapid assessment prepared by its expert members, PEC said the location warrants scrutiny from environmental and hydrological perspectives because the Jhelum and its associated wetlands, flood channels, drainage networks and floodplain areas form an interconnected system for regulating floodwaters.
The central issue identified by both organisations is a specific modification made by the State Administrative Council while approving the Srinagar Master Plan–2035.
The Draft Master Plan Srinagar and the recommendations of the committee constituted for its examination were placed before the SAC under Section 9 of the J&K Development Act, 1970. The Master Plan–2035 was approved through SAC Decision No. 40/5/2019 at a meeting held at Raj Bhavan, Jammu, on February 13, 2019.
However, the SAC did not accept the recommendation concerning development along the NH Bypass between Pantha Chowk and Nowgam. Instead, it approved the departmental proposal with a specific modification stating: “NO DEVELOPMENT/CONSTRUCTION ACTIVITY BE PERMITTED ALONG THE NH BYPASS FROM PANTHA CHOWK TO NOWGAM WHICH FORMS A PART OF FLOOD ABSORPTION BASIN.”
PEC said the decision is significant because it demonstrates that the Government, after the devastating September 2014 floods, had expressly recognised the flood-absorption function of the Pantha Chowk–Nowgam landscape and considered it sufficiently important to warrant a specific restriction on development.
The group has sought clarification on the precise spatial relationship between the proposed 50-acre industrial park and the area covered by the SAC decision.
“The question is not simply whether the proposed site is shown under a particular colour or land-use category on a planning map,” PEC said. “The more fundamental issue is whether the proposed site falls within, overlaps, adjoins, drains into, or otherwise forms part of the flood-absorption basin that the SAC intended to protect.”
EPG has made a similar argument, saying the immediate question is not whether engineering mitigation can be designed for the industrial park, but whether the proposed site falls within the area to which the SAC-imposed restriction applies and, if so, under what lawful authority development can now be contemplated.
PEC has also drawn attention to the Government’s post-2014 flood assessments under the World Bank-supported Jhelum Tawi Flood Recovery Project (JTFRP).
It said the Environmental and Social Impact Assessment for Storm Water Drainage in the Bonpora–Padshahi Bagh area recorded that Bonpora, Nowgam, Padshahi Bagh and adjoining areas were completely inundated for several days during the September 2014 floods and that the wider area has a recurrent history of waterlogging because of its low-lying character.
The assessment, according to PEC, recorded flood levels of approximately 2–5 metres in parts of the Bonpora–Padshahi Bagh area during the 2014 event and described the area as having a frequent history of flooding because it functions as a detention basin and floodplain of the Jhelum.
The same assessment recognised that land-use change, urbanisation of floodplains and the loss or degradation of wetlands and low-lying areas had reduced the landscape’s ability to absorb and temporarily retain floodwaters, PEC said.
The group said the relevance of those findings was again demonstrated during the September 2025 flood episode, when breaches along the Jhelum system threatened or affected several low-lying areas on Srinagar’s southern outskirts, including the wider Nowgam–Lasjan–Soiteng–Summerbugh landscape.
Taken together, PEC said, Government’s planning documents, flood-recovery assessments and subsequent flood events point to a consistent understanding of the southern Srinagar landscape as performing an important flood-storage, detention and drainage function.
The environmental groups have therefore questioned whether the proposed industrial park is being evaluated merely as an individual parcel rather than as part of a larger hydrological system.
PEC has asked the Government to disclose the precise cadastral boundaries, khasra numbers, coordinates, existing ground elevations and present land-use and revenue classifications of the proposed site.
It has also sought the official map or technical basis if the Government considers the site to fall outside the area covered by the SAC restriction.
Even if the proposed parcel does not physically abut the NH Bypass, PEC said, the Government should establish whether it forms part of the same hydrological flood-absorption or detention landscape.
“Floodplains and detention basins are hydrological systems and do not necessarily follow road alignments, cadastral boundaries or administrative parcels,” it said.
Another question raised by PEC is whether there has been any subsequent formal review, modification or supersession of the 2019 SAC decision.
If Government now considers development in any part of the protected landscape appropriate, the group has asked when the decision was reviewed, which competent authority reviewed it, what new hydrological or planning evidence justified the change and whether public and interdepartmental consultations were undertaken.
The groups have also called for a comprehensive GIS exercise in which the complete project footprint is overlaid with Master Plan–2035 zoning, the SAC-protected Pantha Chowk–Nowgam corridor, September 2014 inundation data, flood-basin areas, Nowgam Jheel, the Jhelum floodplain, natural drainage channels and wetland areas.
EPG has demanded an independent hydrological and hydraulic assessment covering historical inundation, existing flood-storage volume, natural overland flow paths, the relationship with Nowgam Jheel and adjoining wetlands, connections with the Jhelum flood-spill system, existing drainage channels, pre- and post-development runoff and possible obstruction or diversion of flood flows.
PEC has gone further by asking the Government to establish the existing ground levels and proposed finished levels, the average depth and total quantity of filling and the existing flood-storage or detention volume of the site.
The crucial question, it said, is where water that currently occupies or passes through the site during extreme events would be accommodated once the land is filled and raised.
The groups have also called for modelling of the project’s possible effects on flood depths, duration, flow paths, water velocities, local drainage and pumping requirements in Nowgam, Bonpora, Padshahi Bagh, Lasjan and adjoining settlements.
PEC has warned that the cumulative impact of development in the southern floodplain cannot be assessed through isolated parcel-level studies.
It wants the Government to assess the combined consequences of filling low-lying land, expansion of built-up areas, road and railway embankments, industrial and commercial development and drainage infrastructure across the wider Pantha Chowk–Nowgam–Lasjan–Padshahi Bagh landscape.
The group has also asked whether alternative locations were examined on the basis of flood exposure, elevation, environmental sensitivity, accessibility, infrastructure requirements, lifecycle costs and long-term climate resilience.
This, it said, is particularly important because the reported Rs 104-crore project cost represents only the initial investment. A proper public-investment appraisal should also consider the costs of filling and ground raising, flood protection, storm-water drainage, pumping, maintenance, insurance, possible flood damage, business interruption, emergency access, rehabilitation and flood-risk costs transferred to neighbouring communities.
The relevant comparison, PEC said, should be between the whole-life, climate-adjusted cost of the Nowgam location and that of alternative sites.
EPG has proposed a “No Net Loss of Flood Storage” principle, under which no development should be permitted if it results in a net reduction in flood-storage or flood-conveyance capacity.
Where development is otherwise found to be legally permissible, compensatory storage should be demonstrated on the basis of hydraulic equivalence rather than merely equivalent land area, it said.
Both groups have called for the status quo to be maintained at the proposed site until its conformity with Master Plan-2035 and the SAC decision is established.
PEC has requested that a multidisciplinary, multi-stakeholder review be undertaken before the project location is finalised, involving experts in urban planning, hydrology, flood-risk management, ecology, disaster management and public-investment economics.
The group said such a review would not obstruct industrial development but would help ensure that an investment intended to generate employment and economic activity is located where it can function safely for decades without compromising Srinagar’s natural flood-management infrastructure or increasing risks to surrounding communities.
The controversy also raises a wider question about policy coherence in the Jhelum basin, PEC said.
The Government is simultaneously investing in flood protection, Jhelum flood recovery, storm-water drainage, disaster-risk reduction, wetland conservation and climate adaptation, while promoting urban and industrial expansion.
“These policies should be mutually reinforcing,” PEC said, arguing that it would be counterproductive if public money were being spent on increasing Srinagar’s flood resilience while other interventions were converting land that Government itself has identified as contributing to flood absorption and detention.
EPG has called for the issue to be subjected to immediate judicial and statutory scrutiny and for disclosure of the legal basis, if any, under which development is being contemplated in an area subject to the SAC-approved restriction.
If the proposed site is confirmed to fall within the protected flood-absorption area, EPG said the Government should examine an alternative, hydrologically safer location rather than attempting to engineer away the landscape’s natural flood function.
PEC has similarly said that if the site is demonstrably outside the flood-absorption basin and its development will have no material effect on the basin’s functioning, the Government should establish this transparently through maps and hydrological evidence.
“If, however, the site falls within or materially contributes to the same flood-storage and detention system, PEC believes that the location warrants reconsideration before irreversible filling or construction proceeds,” it said.
The groups have argued that the lessons of the 2014 floods, the Government’s own post-flood assessments, the 2019 SAC decision and the renewed flood experience of 2025 collectively warrant a precautionary approach.
EPG said the principle should be simple: “Development must follow hydrology—not hydrology be engineered to accommodate development.”
PEC, meanwhile, said its intervention should not be interpreted as opposition to industrialisation, investment or employment generation in Jammu and Kashmir.
Its concern, it said, was “policy coherence, institutional consistency and responsible public investment”.
The Nowgam proposal, the groups said, therefore presents a test of whether the Government’s flood-resilience, environmental and development policies can operate consistently within the same landscape.
Until the precise spatial and hydrological relationship between the proposed industrial park and the protected flood-absorption basin is established through transparent technical assessment, PEC has urged that no irreversible site filling or construction be permitted.
