To
Shri Ajay Seth I.A.S
Principal Secretary,
Primary and Secondary education,
Room no-641,6th floor,
M.S Building, Bangalore-560001

Shri Mahindra Jain, I.A.S
Addition Chief Secretary to Government
Urban Development Department,
Room No-436, Vikasa Soudha,
Bangalore

Sri V Ponnuraj I.A.S
Secretary to Government (M & UDA)
Urban Development department
Room no 434, Vikasa Soudha \,
Bangalore

Sri K Venkatesh
Chairman
T. Chowdiah road,
Kumara Park West,
Bangalore-560020

Dr. Raj Kumar Khatri
Chairman
T. Chowdiah road,
Kumara Park West,
Bangalore-560020

N Manjunath Prasad I.A.S
Commissioner
Bhruhat Bengaluru Mahanagara Palike
Neat Unity building, NR square
Ashwathnagar HBR layout
Bangalore-560002

Dear Sirs / Madame,

This representation is being issued by:

1. Indian Montessori Centre [Address: C/O Hymamshu Jyothi Kala Peeta, 74,4th main, Malleswaram, Bangalore-560055 | Represented by Secretary General- Mr. B S Sujay ]
2. Federation of Montessori Schools India [Address: 164, 'Shantha Nilaya', 4th Cross, Dollars Colony, J P Nagar, 4th Phase, Near Kalyani Magnum, Bangalore – 560078 | Represented by President – Mrs. Amitha Prashanth]
3. Karnataka Council of Pre-Schools [Address:1854,2nd floor, Akhand avenue, 39th cross,11tha main, 4th T block, Jayanagar, Bangalore | Represented by Secretary- Mr. Pruthvi Banwasi ]

We humbly submit as follows:

The organizations referred to in serial numbers 1 and 2 above are organizations whose members own or operate play homes, kindergartens, Montessori and day care centers (together referred to as “Child Care Centers”). The organizations listed in Annexure 2 are owners / operators of Child Care Centers. As per our estimate, there are over 5,000 Child Care Centers operating in Bangalore catering to over 5,00,000 children.

Background about Child Care Centers:
(a) Child Care Centers cater to children below Standard 1. The youngest children will be 18 months old. Most children remain with Child Care Centers for a year or two and then join regular schools. Some children continue till they are able to join Class 1 in a regular school.

(b) Some Child Care Centers have children with disabilities. There are also Child Care Centers that cater exclusively to children with disabilities.

(c) Child Care Centers are not affiliated with schools or other educational institutions. They are stand-alone organizations.

(d) Child Care Centers are almost always owned, operated and managed by women. The teachers / attenders are also almost always women. Our estimate is that there are about 50,000 women working in Child Care Centers in Bangalore.

(e) Childcare Centers provide a valuable service of nurturing small children.

(f) Apart from the small class-room settings, the Child Care Centers need good open play areas. Children need to be able to play in open air. They cannot be in closed areas all the time. Residential buildings give comfort to these tiny-tots as this the first learning center they visit. Open gardens also teach and encourage children to take care of their environment.

(g) Child Care Centers can only function in stand-alone buildings; there are security issues including concerns around injury, kidnapping, molestation etc., if they share facilities with other business / operations. These children cannot take care of themselves and need to be under constant adult supervision. It would be impossible to guarantee this supervision in shared facilities.

(h) In view of the above, most Child Care Centers (over 90%) run in small plots; using constructed area ranging from 1000 square to 5000 square feet; and use facilities that are exclusively designed and created for them and inaccessible to all others.

There seems to be a recent approach to treat Child Care Centers as commercial establishments for the purposes of zoning regulations. In this regard, we present this petition for your due consideration. Firstly, our submission is that Child Care Centers do not fall under any of the categories listed in the CDP 2007. Child Care Centers are not schools or nurseries in the technical sense or the legal sense. They are really civic amenities that need to be available to children in all areas to close to their homes.

Assuming, for a moment that it is commercial activity that cannot be carried on in a residential area freely; we set forth below the consequences of treating Child Care Centers as commercial activities that can only operate in commercial buildings on roads designated for commercial purposes.

(a) Treating Child Care Centers as commercial activities is really dangerous for children. Since Child Care Centers can only run in small stand-alone properties, the building will not have the facility to allow vans / cars / two-wheelers to enter the facility. The children will be dropped off on the main roads by parents; This results in (i) risk to the children because they are dropped on the main roads. Given the number of children being dropped in each Child Care Centre, there is a risk to the children. The thought of 18-month old children being dropped and picked up in public spaces itself will be scary to parents; and (ii) Traffic issues arising on account two wheelers, cars and mini-vans stopping on the main roads to drop children.

(b) Child Care Centers are small operations and are sometimes run in the homes by the residents.1 These Child Care Centers will be unviable if they have to move into commercial buildings.

(c) As can be seen, in densely populated areas of the city, Child Care Centers cannot operate at all, if they have to be in commercial zones. The children in these areas will need to go far away, which again is not viable for small children.

(d) Commercial areas have more noise and more pollution. This is not good for the children.

(e) As pointed out it is unsafe for the small children in many ways.

It must also be noted that most Child Care Centers operate between 9 am and 2 pm. They do not operate during holidays and outside of working hours. Except when children are being dropped or picked up, there are no significant visitors causing nuisance to the residents.

While, there is sound logic to prevent residential areas from being used for business and commercial purposes, greater good of society will be served by permitting Child Care Centers to operate in residential areas. Children need a safe and healthy atmosphere to grow in. In the case of Child Care Centers, this can be provided only in the safety of small sized properties in residential areas.

The concept of centralization of commercial and retail zones and separation from residential zones works well in relation to core commercial activities like software companies, restaurants, etc. It is our humble submission that this does not work well in relation to civic amenities such as Child Care Centers. We cannot imagine running or operating Child Care Centers in areas such as Jayanagar IV Block, Gandhi Bazaar, 5th Main Malleswaram and any other similar areas.
In view of the above, we humbly request you to clarify that Child Care Centers can be operated in residential areas. There will be considerable difficult and hardship for small children if this clarification is not issued.

We are happy to provide any further information and material as may be needed.