In Kashmir, where the memory of the devastating floods of 2014 remains embedded in the landscape and public consciousness, the most consequential question about a proposed industrial park at Nowgam may not be how many factories it can accommodate, but how much water the land can still hold when the next major flood arrives.
The Environmental Policy Group, or EPG, has asked for judicial and statutory scrutiny of a proposed 104.02-crore-rupee Plug-and-Play Industrial Park, arguing that the project could conflict with a specific safeguard incorporated into Srinagar’s approved Master Plan-2035.
The proposed park would occupy roughly 50 acres and include industrial plots, roads, utilities, warehouses, factory sheds, worker facilities and associated infrastructure. EPG says the development could transform permeable, low-lying terrain into built-up land in the Pantha Chowk-Nowgam landscape – an area whose ability to absorb, store and convey floodwater, it argues, is not incidental but fundamental to Srinagar’s safety.
“Flood basins are not vacant land. They are natural public infrastructure,” the group said.
That framing places the Nowgam proposal within a larger and increasingly urgent question confronting fast-growing cities: What happens when land that appears available for development performs a function that is invisible until disaster strikes?
For EPG, the answer begins with the statutory planning record.
The group says the Draft Master Plan for Srinagar and the recommendations of a committee examining it were submitted to the State Administrative Council for approval under Section 9 of the Jammu and Kashmir Development Act, 1970. The Master Plan-2035 was subsequently approved by the council through Decision No 40/5/2019 at a meeting held on February 13, 2019, at Raj Bhavan in Jammu.
But there was an important exception.
According to EPG, the council accepted the committee’s recommendations except for the recommendation concerning development along the Pantha Chowk-Nowgam National Highway Bypass. Instead, the council approved a departmental proposal with a specific modification: development or construction activity was not to be permitted along the bypass from Pantha Chowk to Nowgam because the corridor formed part of a flood-absorption basin.
That decision, EPG argues, changes the nature of the current debate.
The question is not simply whether engineers can design drains large enough to carry away additional runoff, or whether a proposed industrial estate can obtain an environmental or hydrological clearance. The threshold question, the group says, is whether the land falls within an area that the statutory planning framework has already identified as requiring protection.
If it does, the government must explain the legal authority under which construction could proceed, EPG says.
The distinction is significant. A drainage system can be enlarged. A culvert can be widened. A channel can be redirected. But a flood basin is valuable precisely because water can spread across it when rivers, streams and drainage systems are overwhelmed.
The 2014 floods provided Kashmir with a stark demonstration of that principle. In September that year, exceptional rainfall and swelling rivers inundated large parts of the Valley, exposing the vulnerability of Srinagar’s low-lying areas and highlighting the role played by wetlands, floodplains, lakes and open drainage corridors in managing excess water.
EPG is now asking authorities to determine whether the proposed Nowgam park would diminish some of those natural protections.
It has called for the entire project footprint, cadastral boundaries and geographic coordinates to be placed on a single geographic information system, or GIS, platform and compared with the zoning provisions of Master Plan-2035 and the protected Pantha Chowk-Nowgam corridor.
The mapping, it says, should also include September 2014 inundation data, notified or proposed flood-basin areas, Nowgam Jheel, the Jhelum floodplain, natural drainage channels and wetlands.
The purpose would be to establish, with geographic precision, what the land is and what it does.
EPG has also called for an independent hydrological and hydraulic assessment. Such a study, in its view, should not be limited to the question of whether rainwater can be drained from the proposed industrial site. It should examine historical inundation, existing flood-storage capacity and natural overland flow paths, as well as the relationship between the site and Nowgam Jheel and adjoining wetlands.
It should assess connections with the Jhelum and the wider flood-spill system, existing drainage channels and changes in runoff before and after construction.
The assessment should also calculate whether development would obstruct or divert flood flows and examine the cumulative effects of construction already taking place in the surrounding landscape.
And it should account for something that older planning systems often struggled to incorporate: extreme rainfall under a changing climate.
For EPG, the governing principle should be simple: no net loss of flood storage.
If construction is permitted, the group says, developers should be required to demonstrate compensatory storage through hydraulic equivalence – not merely by setting aside an equivalent number of acres somewhere else.
The distinction matters because a hectare of land is not necessarily interchangeable with another hectare. A piece of terrain may have a particular elevation, slope, permeability and connection to surrounding waterways that gives it a unique role during a flood. Replacing its area without replacing its hydraulic function, EPG argues, would be little more than an accounting exercise.
The group has therefore urged the government to maintain the status quo at the proposed site until compliance with Master Plan-2035 and the 2019 State Administrative Council decision has been established.
It has also asked authorities to disclose the legal basis, if one exists, for proposing development in an area covered by the council’s restriction.
If the site is ultimately found to lie within the protected flood-absorption area, EPG says the more prudent response would be to relocate the industrial park to a hydrologically safer site rather than attempt to engineer around a landscape whose natural function is to absorb floodwater.
That argument carries implications beyond Nowgam.
Srinagar has expanded into a landscape historically shaped by water. Wetlands, lakes, marshes, agricultural fields, drainage channels and floodplains have long formed a network through which excess water could move and disperse. Urban growth has progressively altered that network, turning some open land into roads, buildings and other permanent structures.
The environmental group says the Nowgam dispute should therefore be treated as part of a larger planning problem rather than as an isolated controversy over one industrial project.
It has called for statutory floodplain zoning throughout the Jhelum basin, protection of flood-storage areas from filling and permanent construction, mandatory flood-risk assessments for major projects and integrated storm-water and drainage planning before urban expansion or major infrastructure is approved.
It has also urged authorities to incorporate floodplain, wetland and drainage layers directly into master plans, zoning regulations, building bylaws and online building-permission systems.
The idea is to make hydrology part of the basic architecture of urban planning rather than an afterthought that appears during the environmental-clearance stage.
“Development must follow hydrology – not hydrology be engineered to accommodate development,” EPG said.
The group says it had approached then-Governor Satya Pal Malik during the final stages of the Master Plan-2035 process to ensure that the flood-absorption restriction was included.
That history is central to its present argument. If the restriction was deliberately incorporated into an approved planning document after concerns about the flood function of the corridor, EPG contends, it should not be treated as an advisory environmental preference that can simply be overridden by a subsequent project proposal.
The dispute also raises a broader question about the meaning of infrastructure in a city increasingly shaped by development pressure.
Factories, roads and drainage systems are visible forms of infrastructure. Flood basins are not. Their value becomes apparent only when water arrives faster than conventional infrastructure can handle it.
That makes them unusually vulnerable to a familiar logic of urban expansion: land that looks empty is assumed to be unused.
But the emptiness may itself be the service.
In a flood-prone basin, an open field can function as storage. A wetland can slow water. A drainage channel can provide a route for runoff. A low-lying tract can prevent water from accumulating somewhere more densely populated.
Building over such places can therefore create a paradox: infrastructure designed to promote economic growth may simultaneously weaken the landscape’s capacity to protect the city from the consequences of extreme weather.
The proposed Nowgam industrial park has become a test of which principle will prevail.
EPG is not arguing that industrial development should stop in Srinagar, nor that economic activity and environmental protection are inherently incompatible. Its argument is narrower and more consequential: before construction begins, authorities should establish what legal protections apply to the land and what role the land plays in the flood system.
If the site is outside the protected area and hydrologically suitable, the project can be assessed on its merits.
If it lies inside a protected flood-absorption basin, however, the burden shifts. The question becomes not how development can be fitted into the basin, but whether development belongs there at all.
That is a question whose consequences extend well beyond a 50-acre industrial estate.
For a city built along a river and surrounded by a complex network of water bodies, the boundaries between development land and flood infrastructure are not always visible on the ground. They have to be established through maps, law and hydrology – and, ultimately, through the willingness of planners to preserve land whose greatest public value may be realized only during the worst possible day.
The Nowgam proposal is thus more than a dispute over an industrial park. It is a test of whether Srinagar’s planning system will treat flood protection as an essential component of urban infrastructure, or as a constraint to be negotiated whenever development arrives.
EPG’s position is unequivocal: where natural flood-storage capacity exists, it should be protected as public infrastructure.
And if that means moving a project rather than moving the water, the group says, the project should move.
About the Author
Wajahat Iqbal Kashtwari is a filmmaker and multimedia professional with a keen interest in environment, ecology, and climate change.
