The Great Housing Paradox - A Superimposition of Mumbai’s Political Economy

The Great Housing Paradox
A Superimposition of Mumbai’s Political Economy
by Amruta Mahakalkar 938094
Contemporary City: Descriptions and Projects
Prof. Eliana Barbosa
T.A. Elena Batunova
T.A. Marco Vedoà
Politecnico di Milano
School of Architecture
Master of Science in Urban Planning and Policy Design
Academic Year 2019/2020

Abstract
In the last few decades, the global south has developed several
megalopolises. These vast horizontal stretches of urbanscape are
lands of contradictions, where diverse actors come together in a
melting pot and yet exist with stark disparities. The city Mumbai also
demonstrates many of these paradoxes, the most shocking one being
its real estate and housing situation.
Today Mumbai is witnessing a head-on collision between a top-down
process of speculative real-estate investments and a bottom-up
decentralized network of informal housing. There are a range of reasons
for this problem - from its industrial foundation, obsolete zoning laws,
and stringent regulations, to the recent neoliberal interferences, and
an alternate governance led by slumlords and the local political party -
all have played crucial role in defining and distorting the character of
this city region.
This exercise is an attempt to understand these invisible layers, map
them in a timelime, stack them, and observe how they have
transformed individually, complemented and contradicted one
another, and ultimately impacted the physical and social realities of
Mumbai and its people.
ऐ िदल है मुल जीना यहाँ
ज़रा हट के , ज़रा बच के
ये है बॉे मेरी जान।
...
कहीं िबंग कहीं ट ामे कहीं मोटर कहीं िमल
िमलाता है यहाँ सब कु छ इक िमलता नहीं िदल
इंसां का नहीं कहीं नामोिनशाँ
ज़रा हट के , ज़रा बच के
ये है बॉे मेरी जान।
O heart, it's tough to live here
Move a little, be careful
This is Bombay, my dear.
...
Here you will find buildings and trams
Here you will find motor cars and mills
Here you will find everything except
You will not find one heart.
Here there is no sign of humans,
Be careful, be cautious
This is Bombay my love.
- Mohammed Rafi, CID (1956)
The analysis of every layer is
supported by excerpts from the widely
acclaimed non-fiction Maximum City:
Bombay Lost and Found written by
author Suketu Mehta in 2004, in order
to offer a narrative of how these
policies and legislations have impacted
the everyday life of Mumbaikars.
Image by Abhay Singh, Unsplash
1

Contents
Mumbai Introduced
The Great Housing Paradox
1. Rent Control’s Unintended Consequences
Bombay Rent Control Act, 1947
2. Cotton Mills and the Land Ceiled
Decline of Cotton Mills, Urban Land Ceiling Act, 1976 and the FSI Conundrum
3. Say Yes to Sprawls
Metropolitan Regional Plans
4.a Slums - Bulldozed but not Built Back
Slum Clearance and Improvement Act, 1956 and Land Acquisition Act, 1894
4.b Slums Solved - Conditions Applied
Slum Redevelopment Scheme 1991 and Neoliberalism
5. Shiv Sena - An Alternate Governance
Conclusion
Image by Tony Shostak, Unsplash
2

Greater
Mumbai
मुंबई
Mumbai
Metropolitan
Region
Area
Mumbai Metropolitan Region (MMR)– 4,253 km 2
Greater Mumbai Island City – 440 km 2 (10% of total MMR )
Population (2011)
Mumbai Metropolitan Region (MMR) – 12.44 million
Greater Mumbai Island City – 3.085 million (25 % of total MMR)
Prior
Seven
Fishing
Islands
1800 1900 1970 2020
Industrial
Bombay
Mumbai
Metropolitan
Region
Mumbai Introduced
Mumbai (renamed from Bombay in 1996) is one of the most significant cities of India
and Global South. Today, the financial, commercial, and entertainment capital of the
country, it was originally a collection of seven fishing islands. After being reclaimed
into a solid land from the sea only in 1845 by the British, Bombay witnessed an
immense industrial growth till the late 20th century, attracting great influx of
migrants around the nation.
The second most populous city in India, it is amongst the densest megacities on the
planet. Over the last century, with its exploding population, the city, despite its
geographical constraints have sprawls outwards and today covers the vast Mumbai
Metropolitan Region (MMR) of 4,250 km 2 .
With its linear growth along the coast in the beginning, the city can be divided into
the main Greater Mumbai Island City and its suburbs on the north-east that gradually
mushroomed in the last decades. The island city though covering 10% of MMR, houses
a fourth of its population.
Apart from the issues of a typical megacity, Mumbai faces a peculiar problem of
housing. It is not just the problem of space but a complex nexus of political, policy
and legislative decisions that has produced this mammoth challenge of housing
disparity in this city.
70
60
50
40
30
20
10
0
-10
% GROWTH
Population Density
Mumbai Metropolitan Region – 5,360 persons/km 2
Greater Mumbai Island City – 28,425 persons/km 2
San Francisco
Mumbai
Los Angeles
% Growth in housing
Singapore
Auckland
“Can I rent a flat at a
price I can afford?”
“No.”
Coming from New
York, I am a pauper in
Bombay.
Kuala Lumpur
Part 1, The Country of the No
(Maximum City, Suketu Mehta)
Dublin
Bangkok
Vancouver
% Growth in income Income to housing ration
RATIO
Housing vs. Income growth , 2018
Source: URBAN FUTURES - Edition 1, Knight Frank 2019
3
2
1
0
-1
-2
-3
-4
-5
3

The Great Housing Paradox
Total number of census houses in MMR - 8,763,300
Total number of slum census houses - 1,953,000 – 27% of MMR
Slum houses in Greater Mumbai Island City - 1,101,655 – 80% of total slum houses
Estimated formal housing need in MMR - 3.6 million by 2020
% of population living in slum 52.5%
Total Slum Area in Greater Mumbai 8.75%
Land Area Reserved for Housing in Greater Mumbai as per Master Plan 21.17%
Two or three
rooms
Four or more rooms
No Exclusive or
a single room
Girish’s shanty is a room. There are all
manner of implicit understandings about
how the family members will divide up
their time in the room. There isn’t
enough space for everybody to be there
at once, except when they’re all sleeping,
when body movements are kept to a
minimum. It’s the only way they can be
stacked, when they’re sleeping or dead.
Home, in the slum, is a time-share.
Part 3, Girish: A Tourist in His City
The housing situation of Mumbai is appalling at best. Presently, a third of its households live in slums. The
island city is even worse with 80% of its houses supplied informally. Mumbai contains Dharavi, Asia's
largest slums, among its 2400 other clusters. But these slums, due to their immense density cover just
over 8.5% area of the island city. Also, 55% of the families live in a single room.
In addition, due to a range of factors, the cost of land here is skyrocketing, making formal housing
absolutely unaffordable for most of its citizens. An estimated three-quarters of urban space is owned by
only 6 % of its households, and just 91 people control the majority of all vacant land in Mumbai.
Meanwhile, over 250,000 houses mainly constructed for higher and middle-income groups are lying unsold
or vacant in Mumbai. Many of them are simply locked up to evade Mumbai’s unreasonable housing laws.
These staggering contradictions are a result of a number of policy decisions and legislations, some
obsolete yet existing and many evolving in the emerging atmosphere of neoliberalism.
Slums in Mumbai , 2011
Source: P K Das and Associates Mumbai 2011
4

I ask how Girish sleeps with his family in the room. He looks at me, then
takes out a pen. “See, we are seven people. Me and my older brother on
the cot,” and he sketches two circles on a rectangle. “Then my two
younger brothers on the floor.” Two more balloons below the rectangle.
“My parents in the kitchen,” only notionally separated from the front
half of the room. Then he draws a line, writes on it TABLE.
“My sister under the table.” After this explanation, he takes the paper
napkin, folds it once, folds it over again, scrunches it into a ball, presses
it very hard in his fingers, presses it with all his might, and when it has
become small, so small that it is insignificant, he throws it away. Then he
looks up and smiles at me.
Part 3, Girish: A Tourist in His City
5

“The housing market in the city best represents the political economy of
Mumbai, with its base in creating wealth by any means, resulting in vast
structural inequalities in the system” (Sharma 2007).
Mumbai’s social and physical fabric today is a result of complex layers of macro and micro policies,
legislations and politics continuing to weave and entangle for over seven decades since India's
independence in 1947. Five such major layers of its political economy are identified and discussed next.
Image by Vinay Darekar, Unsplash
6

1. Rent Control’s Unintended Consequences
Independent India
Economic Liberalization
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Bombay Rents, Hotel, and
Lodging House Rates
Control Act, 1947
Amendment to the Rent
Control Act, 1999
Proposal for a dual
system Rent Control
Act, 2019
Proportion of total
rent-controlled
residential carpet area*
The reason Bombay is choking is the Rent Act. It was an
institutionalized expropriation of private property.
Democracies have a weakness: If a bad law has enough
money or people behind it, it stays on the books. In Bombay
I can walk into a flat I’ve rented for a year and stay there
for the rest of my life, pass it on to my sons after me, and
defy the lawful proprietor’s efforts to get my ass off his
property... I have the law behind me.
No Data
0%-20%
20%-40%
40%-60%
60%-80%
80%-100%
Part 1 - Power, Mumbai
Image by Prerna Rajkumar, Unsplash
Monthly
Rent =
5kg of
Rice!
Bombay Rent Control Act, 1947
The Bombay Rents, Hotel and Lodging House Rates Control Act, 1947 was one of the most
controversial piece of legislation impacting the built form of the city. It was passed as a
reform to protect the tenants from inflation and evictions after WWII and froze the rents of
properties in the island city for next fifty years, only to be slightly amended in 1999.
Over time, the real rent paid to the landlord tends toward zero. As a consequence tenants
never move out. While landlords still have the right to sell entire buildings under rent control,
they seldom do it for an obvious lack of demand. Therefore, the older and the more decrepit
a building is, the less likely it is to be sold, rebuilt or maintained. This lack of incentive and
obstruction to private property market has led to a significant portion of housing stock
unmaintained, deteriorated and underused on such valuable land with virtually no addition
to the rental housing, especially for low-income group, for decades (S Patel, 2005).
Rent Act has become a sensitive and untouchable issue, backed by the large tenant lobby,
a valuable vote bank that has stopped it from appropriate reforms. Reluctantly in 1999, the
act was amended which has led to a gradual increase in private housing investment but
mostly for high-value residential properties only.
* Map Source: UTandel, V., Patel, S., Gandhi, S., Pethe, A., & Agarwal, K. (2016). Decline of rental housing in India: the case of Mumbai
7

2. Cotton Mills and the Lands Ceiled
Independent India
Economic Liberalization
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Decline of Cotton
Mills 1980s
Redevelopment of
mill lands 2001
Urban Land (Ceiling and
Regulation) Act - ULCRA, 1976
ULCRA repealed
2007
FSI frozen to 1.33 FSI and TDR incentives 2008
Locations of former textile
cotton mills*
9
New York
8
Maximum Residential FSI
7
6
5
4
3
2
1
0
Singapore
Seoul
Vancouver
Mumbai
Dharavi Slum
Distance from city centre (in km) #
Centre 4 8 12 16 20 24 28 32
FSI (Floor Space
Index) Regulations #
4
1.5
1.33
1
0.75
0.50
Mumbai -
1.24 m 2 /person
WHO Standards for Open
Space - 9 m 2 /person
Decline of Cotton Mills, Urban Land Ceiling Act, 1976 and the FSI Conundrum
The once thriving cotton textile industry in Mumbai reached its thresholds and declined in 1980s. This left about 2.5 km 2 of under and
unused land right in the heart of the city. However, the Urban Land (Ceiling and Holding) Act ULCRA - 1976 and Floor Space Index (FSI)
restrictions under the city’s Development Control Regulations (DCR) made redevelopment of these land parcels impossible, causing an
artificial scarcity of land. Mill land owners could not sell their lands without surrendering a large portion of land for public uses due to
ULCRA 1976 that limited private ownership of land upto just 2000 m 2 . Instead of bringing the lands in the market, the Act locked them
into legal disputes on state acquisition and compensation.
Additionally, the landuse and FSI restriction under the Zoning Laws made it impossible to convert the land use or build a new construction
with higher density. In comparison to other global megacities, Mumbai still has an unreasonably low FSI limit of 1.33 in the island city area.
The Regional Plan of 1970 instead of optimally utilizing the available vacant land in the city centre for social housing and public spaces,
pushed the development in the periphery.
Only in 1991, after the revision of the DCRs, redevelopment of these land parcels was specifically permitted, with the condition of
reserving a third of land for open spaces, one third for social housing and rest one third for private development. But again the mill owners,
not satisfied with the amount of land for profit protested for more land for luxury apartments and commercial use. The court judgment
went in favor of the mill workers, but ultimately further reduced the possibility of new affordable housing in the island city.
Map / Chart Sources: * Report of the Study Group on Cotton Textile Mills in Mumbai by Government of Maharashtra Urban Development Department, 1996
#
Mumbai FAR/FSI Conundrum: The perfect storm: the four factors restricting the construction of new floor space in Mumbai, A. Bertaud, 2011
8

3. Say Yes to Sprawls - Metropolitan Regional Plans
Independent India
Economic Liberalization
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Mumbai Metropolitan Plan
1970-1991
1996-2011 2016-2036
FSI frozen to 1.33 FSI and TDR incentives 2008
Greater
Mumbai
Proposed
poly-nucleated
regional structure
Urban Growth
Centre
Industrial
Nodes
FSI (Floor Space
Index) Regulations
4
1.5
1.33
1
0.75
0.50
Vasai
Virar Industry
Kharbao
New
Mumbai
Khopta Industry
Angaon Industry
Amba
Industry
Nilje
Sape Industry
Taloja Industry
Shedung
Khalapar
Industry
As a response to the growing air pollution, land use polarization and
congestion, Mumbai Metropolitan Regional Development Authority (MMRDA)
formulated the first Regional Plan in 1970 and proposed some well-intentioned
strategies and regulations that eventually turned counterproductive.
Instead of redeveloping the existing underused and vacant land parcels on the
island such as the Mills’ land, the plan imposed complete restriction on new
developments, freezing the FSI to 1.33, and adopted a strategy to guide the
city outwards to decentralize its growth. As a result, new counter-magnets like
Navi Mumbai and Bandra – Kurla complex were constructed attracting
middle-income housing and slum redevelopment projects to these locations.
However, this draconian land use policy, coupled with ULCRA 1976 and Rent
Control Act 1947, made new investments and developments almost impossible
on the island city and artificially escalated the market value of land, further
gentrifying the middle class and poor outward or into slums.
Only after 1991, the FSI restrictions were eased through the practice of Trading
of Development Rights (TDR). But this was never a deliberate spatial policy to
improve the land use efficiency and was given only to a few individual plots in
exchange of financial resources from the developer (A Bertaud, 2011).
The city’s regressive land use policies over five decades have only created the
conditions of a zero sum game for the consumption of floor space, and
continues to do so.
The progress of the Thakkar family is the story
of the growth of Bombay. They moved from
Fort (village), where Girish’s father lived in a
large house with his extended family, to the
Jogeshwari shanty and now to the Mira Road
flat (suburb). Girish wants to move on to
America, the peak of that trajectory.
Part 3, Girish: A Tourist in His City
9
Image by Nazish Mirekar, Unsplash

4.a Slums - Bulldozed but not Built Back
Independent India
Economic Liberalization
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Slum Clearance
and Improvement
Act 1956
Slum
Improvement
Programme
(SIP) 1970
Vacant
Lands Act
1975
Slum up-gradation
program (SUP) &
Low Income Group
Shelter Programme
(LISP) 1985
Land Acquisition
Act 1894
Land Acquisition Act
Amendment 1964
Land Acquisition, Rehabilitation and
Resettlement Act, 2013
Slum Clearance and Improvement Act, 1956 and Land Acquisition Act, 1894
Prior to liberalization in 1990s, the Bombay Municipal Corporation (BMC), like the rest of the socialist government,
identified itself as a controller, provider and facilitator. It majorly approached the problem of slums by carrying out
improvement ‘schemes’ involving new housing construction on public lands, and by targeting slum areas without
providing alternative accommodation to evicted dwellers. Various programmes and policies pertaining to slums have been
periodized as phases of negation (1950s and 1960s), tolerance (1970s) and acceptance (1980s) (Indorewala, 2018).
Armed with another draconian law, the Land Acquisition Act of 1894, the BMC would undertake comprehensive renewal
schemes under Slum Clearance and Improvement Act 1956 and other Slum Improvement Programmes in large areas of the
city, evict slum dwellers on short or no notice without compensation and “resettle” them to distant locations far away
from their places of employment.
The quality and quantity of social housing provided to urban poor was
also questionable. In the last century, BMC demolished more houses
than it built, further contributing to the rapidly increasing housing
shortage. The slum improvement and upgradation schemes ironically
avoided incremental housing or their in-situ redevlopment, and rather
adopted complete demolition and reconstruction of new public
housing apartments in other parts of the city. These public housing,
mostly built in the city’s suburbs today can qualify as formal yet
verticle slums.
India’s Planning Commission in 1983 declared that “there is
overwhelming evidence to show that efforts to produce affordable
housing for the poor by government bodies have failed.”
The squad is supposed to give a seven-day
legal notice asking for documentation that
the structure is legal. If the license isn’t
provided, the demolition is supposed to go
ahead. But “the staff is under great fear.”
And there is the money; “if the notice is
issued, the entire file will be sold for a lakh
or two to the party concerned.” An employee
can make more in bribes on a single building
than the amount he earns in his entire
career in the municipal corporation.
Part 1 - Powertoni, Elections 1998
10

How does he like the footpath life?
I ask him. “I like it very much. I have
no problems. I don’t want a home; I
am more free on the footpath.. The
footpath is the friend of the poor.
How many people it accommodates to
sleep on!”
– Babanji, poet, homeless immigrant,
17 years old
Part 3, Babbanji: Runaway Poet
Image by BIND Collective, NEXT CITY 2016
11

4.b Slums Solved - Conditions Applied
Independent India
Economic Liberalization
Image - Google Earth 2019
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Slum
Redevelopment
Scheme (SRS)
1991
Slum
Rehabilitation
Authority (SRA)
1995
State
Housing
Policy
2007
Rajiv
Awas
Yojana
2009
Pradhan
Mantri Awas
Yojana (PMAY)
2015
Land Acquisition
Act 1894
Land Acquisition Act
Amendment 1964
Land Acquisition, Rehabilitation and
Resettlement Act, 2013
Slum Redevelopment Scheme 1991 and Neoliberalism
With the emergence of neoliberal structural adjustment
from 1980s onwards, the nature of government shifted
from a provider to just a facilitator for the private actors
to generate housing for both rich and poor. The new
national and state housing policies and Slum
Rehabilitation Programmes such as Slum Redevelopment
Scheme 1991, Rajiv Awas Yojana 2009 and Pradhan
Mantri Awas Yojana 2015 adopted an ‘enabling markets’
strategy under this framework.
This can easily be observed through the pattern of policy
evolution that has moved from a welfare-state based
public housing provision to an in-situ centric slum
rehabilitation approach which encourages home owners
to incrementally improve their housing through financial
assistance, and incentivise private developers to build
affordable housing for the poor. To achieve this, policy
instruments such as cross-subsidy development on slum
land and home loans at subsidized rates have been
adopted. However, they still remain unsuccessful in
improving housing affordability or calming down the
sky-high land values on the island city.
The housing is now being reconceived as an economic and
not a public good. The new political and cultural dream of
Mumbai as a World Class city with the likes of Shanghai
and New York has ultimately pathologized and
criminalized the city’s slums. This dream descended upon
the city’s informal settlers with shocking brutality.
This vision has invited international level large
infrastructure projects of Mass Transit and
Transportation that prioritized the movement and
convenience of the elite over the shelter of the poor.
Between 2004-05 itself, the Government bulldozed over
100,000 homes across the island in the name of
development for public purpose and encroachment in the
No Development Zone (Indorewala, 2018).
Although these new measures do not anymore advocate
evictions and relocation, they are still veiled in the
aggressive neoliberal agenda of privatization and state
deregulation at the reckless cost of shelter for the
commoners.
Relocated Mahul Township under Slum
Rehabilitation Authority's PAP scheme -
next to refineries and chemical factories,
also known as "Mumbai’s Gas Chamber"
912

5. Shiv Sena - An Alternate Governance
Independent India
Economic Liberalization
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Shiv Sena established
1966
1985-90 1995-99 Alliance with the
majority party
2014-19
Incumbent 2019
Mumbai’s housing situation is also peculiarly shaped by the role of its regional
political party Shiv Sena, a right-wing Hindu Nationalist Party. Established in
1966 and periodically in power, this party has advocated for Right to the City,
but only for its vote bank - the Marathi manus (citizen). Marathis are the native
and majority demographics of Mumbai but also happen to be less effluent than
the immigrants. The party has developed a robust grassroot network of
volunteers and local service delivery penetrating to every end of the city,
especially in slums.
It has been functioning as an alternative form of local governance body ensuring
housing, formally when in power and informally anyway. The slum dwellers, mostly
Hindu and Marathi, largely rely on Shiv Sena and its decentralized Shakhas
(branches) for basic services and alternate administration (Saunders, 2012).
While its assistance alleviates their struggle of housing to a degree, it fails the
larger picture of citizens demanding formal and proper housing to the actual
concerned authority.
“That’s his property. “We have captured the land.”
Currently, it is occupied by laborers to whom Sunil
has given the huts for free, so that tenure may be
established over the land. They have been demolished
twice by the Railways. Each time, they have been
reconstructed… The cost of the material, which
Sunil gets from Goregaon: INR 1,500. The time it takes
to rebuild the shack after a demolition: an hour or
two… If they are demolished a third time, he is
determined to build them again, and this time he
says he will erect brick structures.”
“The right of the slum dwellers to
live here is protected by Sunil and
his friends. “We are the Bhais
—the Dons— of the area. So
nobody will trouble them.”
Part 1 - Powertoni, Elections 1998
Part 1 - Powertoni, Elections 1998
Image by REUTERS/Shailesh Andrade 2017
12

Conclusion
Decline of Cotton
Mills 1980s
Redevelopment of
mill lands 2001
Urban Land (Ceiling and
Regulation) Act - ULCRA, 1976
ULCRA repealed
2007
Shiv Sena established
1966 1985-90 1995-99
Alliance with
2014-19 Incumbent 2019
Slum Clearance
and Improvement
Act 1956
Slum
Improvement
Programme
(SIP) 1970
Vacant
Lands Act
1975
Slum
Redevelopment
Scheme (SRS)
1991
Slum up-gradation
program & Low Income
Group Shelter
Programme 1985
Slum
Rehabilitation
Authority (SRA)
1995
State
Housing
Policy
2007
Rajiv
Awas
Yojana
2009
Pradhan
Mantri Awas
Yojana (PMAY)
2015
FSI frozen to 1.33 FSI and TDR incentives 2008
Mumbai Metropolitan Plan 1970-1991
1996-2011 2016-2036
On plotting the chronology of Mumbai’s
political economy in the form of its
legislation, policies and politics, one can
conclude that a city’s physical form is not
merely a product of its municipal land use
plan and regional strategies, but a very
intricate synthesis of decisions made by a
range of actors over space and time. Made
with specific objective, one can really not
comprehend what the ripple effect of these
decisions and events could be.
m
ipsu
ore
or
Lo
In case of Mumbai, the housing crisis
continues to worsen as older decisions,
though made with good intentions but
ended up causing immense damage, are
still not acknowledged and revised, while
newer forces emerge, further adding to the
complexities.
L
r m
Bombay Rents, Hotel, and Lodging
House Rates Control Act, 1947
Amendment to the Rent
Control Act, 1999
Proposal for a dual system
Rent Control Act, 2019
Land Acquisition
Act 1894
Land Acquisition Act
Amendment 1964
Land Acquisition, Rehabilitation and
Resettlement Act, 2013
1930 1940 1947 1955 1960 1965 1970 1975 1980 1985 1991 1995 2000 2005 2010 2015 2020
Independent India
Economic Liberalization
13

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Politecnico di Milano
School of Architecture
Master of Science in Urban Planning and Policy Design
Academic Year 2019/2020