On November 20, 2020, the Department of Space unveiled its Draft SpaceRS Policy-2020 and SpaceRS NGP-2020 documents and sought comments from the public. At first glance these are excellent documents which cover almost each and every wish list of geospatial professionals in India. So let us “begin at the beginning and and go on till we come to the end: then stop”. Well, not quite, as there are some suggestions to add. We always ‘want some more’!
The documents are interesting. The first document, Draft SpaceRS Policy-2020 is a short document of just over a page which sets down among others, interestingly, the role of the Department of Space in issuing guidelines and procedures which are contained in the following document, SpaceRS NGP-2020. This was not done for the earlier Remote Sensing Policies.
End to End Service
The Policy invites private industry to provide “end to end space based remote sensing services, that includes building and operating space assets, establishing ground stations, satellite data acquisition and dissemination, to compete as a provider of space based remote sensing capabilities within and outside India, on commercial basis”. To this end the document lays down some very bold and far reaching policies.
Unshackling the Data
The document, SpaceRS NGP-2020 does that with panache. All Indian Remote Sensing (IRS) satellite data with resolution 5m and coarser is now ‘free and open’. IRS thus joins Landsat and Copernicus systems in making data freely available worldwide. This will satisfy many end users, particularly the academia who are always short of funds, students and the public who can now see what remote sensing is all about first hand.
IRS data with resolution better than 5m and up to and including 50 cm data is also ‘open’ but priced as the Department feels that these types of data have a commercial value. These will be available form designated PSU/CPSE (read INSPACe).
Data with resolution finer than 50 cm is restricted. More on this later.
What is most interesting is the statement “All available archived satellite data and satellite derived thematic data shall be made available for further value addition, research and development purposes on ‘as is where is’ condition”. So will ALL archived data irrespective of the resolution be available now? Interesting thought.
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Opening up to Industry
The policy aims to “promote Indian Industries to carry out space based remote sensing activities within and outside India”. This recognition that Indian industry can also market remote sensing data globally is a major shift in policy. Earlier, IRS satellite data of the US and European regions were marketed respectively, by US and European partners of Antrix Corporation Limited (ACL). No attempt was made by ACL to set up its own subsidiaries abroad. As a result IRS data lost its identity and became one of many datasets marketed by the partners. What will this policy do to the revenue in terms of royalty that ACL was earning from its overseas partners? Will the partners also distribute the data freely?
Now that coarse IRS data upto 5 m is free it is unlikely that industry will be interested in marketing these except as value added commercial products and services. Perhaps, industry might be more interested in marketing open and commercial IRS data, value added data and services.
Notwithstanding this, by freeing up Indian industry, entrepreneurs like Pixxel Space who are developing a constellation of remote sensing satellites for global data acquisition, can enter this field, hopefully with INSPACe providing the support where needed.
Easy Access to Satellite Remote Sensing Data over India
Industry is now free to market remote sensing data and services originating from space based remote sensing systems operated by Indian companies to Indian users directly. A process of registration of the service provider is required so that the Government knows which are the space assets being used.
Read in conjunction with the data rules this clearly points to the group of commercial data with resolution better than 5 m and up to 50 cm. This is a huge change from the earlier policy which freed up data upto 1 m but the distribution was always through National Remote Sensing Centre (NRSC).
Form A is meant only for establishing space assets by Indian entities. Form B is for establishing the ground segment of tracking, telemetry, control and data reception of these assets in India. Form C will be needed to be filled by Indian entities who wish to disseminate the data from Indian and Foreign satellites to Indian users.
Foreign satellite data being marketed by their agents in India will have to apply for registration under Form C. Earlier such data was canalised through NRSC which caused a degree of heartburn among the users as it added to the delay in receiving the data. This will definitely ease the process and take NRSC out of the loop.
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Restrictions
As mentioned earlier, data finer than 50 cm is restricted but its distribution is not prohibited. Form D covers the distribution of such data. Additional authorisation will be needed for distribution of data of certain zones or regions notified by the Government of India. There is a call for shutter control. However, the policy implicitly recognises that with so many data providers such control will be difficult to implement and thus looks at the control on distribution.
It is not clear how this policy will prevent foreign satellite operators from distributing such data over India to foreign entities. There is a clause which declares it ‘illegal’ to distribute such data without authorisation. How will this be enforced?
Further, there is also an interesting clause which reads, “We hereby also agree to abide (by) non-disclosure obligations and keeping the confidentiality of such data dissemination”. Very interesting! Since the authorisation is for sensitive data over Indian territory what is the implication?
Government Areas of Work
While throwing open the area of civil remote sensing to industry, the Department of Space will continue to work on non-commercial areas like long term sustainable development initiatives, climate change studies, societal applications and disaster mitigation. It will provide continuity of service for these areas while also concentrating on “the development of remote sensing systems with newer technologies (that) needs to be taken up for realising innovative applications and R&D. Such remote sensing systems will be brought into operation for sustainability by the Government and shall be pursued by DOS”.
This does not preclude private industry from following the same goals but when it comes to strategic requirements the document draws the line. Development of such systems will use indigenous technology and will be directly under the control of the Government through DOS.
INSPACe the PSU under DOS
INSPACe will be the agency to provide the authorisations as per the Forms A through D. It will also be the agency to provide the state-of-the-art DOS facilities, which it will access at no/notional cost, to the industry on commercial terms.
All current and future civilian remote sensing systems and ground facilities and services like IRS will be transferred to and be operated by INSPACe on commercial terms. The responsibility of the continuity of IRS and other such space based assets and services will also be the responsibility of INSPACe. The interesting point is that INSPACe may use the state-of-the-art DOS facilities at no/notional cost to manufacture satellites and associated ground segment to assure continuity of service of IRS and other systems developed by ISRO.
All this indicates that as far as DOS personnel are concerned, status quo ante will remain. They will continue to work for the PSU (INSPACe) without the benefits due to a PSU employee. In this respect INSPACe appears to be a shell company like ACL.
Questions
Will the free and open data and all archived data and derives thematic data be distributed on Bhuvan? That will surely be a big dampener as Bhuvan is painfully slow. Why not these data sets be put on the Cloud for better access? Why not INSPACe operate this facility or outsource it to a NGPE?
Since INSPACe will use all state-of-the-art DOS facilities at no/notional cost why cannot these facilities along with staff be transferred to INSPACe? ISRO R&D could access these facilities at no/notional cost. INSPACe will be using DOS state-of-the-art facilities at no/notional cost and charging commercial rates for these facilities to industry. Who will benefit from the profits? Will it be ploughed back into the R&D efforts of ISRO or only to the Consolidated Fund of India?
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