Consultation on 'National Geospatial Policy' - Notes and Submission

National Geospatial Policy - Pre-Drafting Consultation Meeting

Keeping in mind the importance of geospatial data in the context of national development, the Department of Science and Technology, Government of India, has constituted a National Expert Committee for developing a draft National Geospatial Policy (NGP). The Committee is Chaired by Major General Dr. R Siva Kumar, former Head of Natural Resources Data Management System (NRDMS) and CEO of National Spatial Data Infrastructure (NSDI), and Dr. Bhoop Singh, Head of NRDMS and NSDI Division at Department of Science and Technology, as Member Secretary. The Policy aims at providing appropriate guidelines for collection, analysis, use, and distribution of geospatial information across India, and to assure data availability, accessibility and quality.

A pre-drafting consultation meeting for the NGP was organised in Delhi by Dr. Valli Manickam, Professor at the Academic Staff College of India, on February 03, 2016, and CIS was invited to take part in it as the only participant from the civil society. The other participants included representatives from the geospatial industry and industry associations (like FICCI and CII), and Ms. Ranjana Kaul, Partner at Dua Associates. Among the drafting committee members, Major General Dr. R Siva Kumar, Dr. Bhoop Singh, Dr. Sandeep Tripathi (IFS), and Wing Commander Satyam Kushwaha were present.

National Geospatial Policy - Concept Note

The purpose of the meeting was to hear the stakeholders' response to a Concept Note on the NGP, circulated prior to the meeting [1]. The Note sets out the principles and concerns of the proposed policy, which plans to guarantee geospatial data availability, accessibility, quality and in consonance with the imperatives of national security and intellectual property rights. The applicability of the policy is aimed at:

all geospatial data created, generated and collected using public funds provided by Central and State Governments and International donor organizations, directly or through authorized agencies.

The note suggests establishment of an "empowered body" to ensure proper creation, updates, management, dissemination, and sharing of the data, and management of an online portal for the same. The institutional mechanism to implement the policy will be composed of an Appellate authority / National High Power Implementation Committee, the NGP Implementation Committee, and the NGP Steering Committee.

Notes from the Meeting

The Welcome Address was delivered by Dr. Bhoop Singh (Head of NRDMS and NSDI Division, DST) who informed the participants that the Expert Committee had already met National Security Council and heard their concerns on the policy. The principles on which the proposed policy is to be based were also shared. The policy resulted from an exercise started two years ago to fix quality and accuracy of geospatial data, which was when it was realised that there were significant gaps that need urgent redressal. It was also identified that in previous initiatives to manage geospatial data at the national level, some data-generating organisations had been left behind. The chief concerns for the Expert Committee are 1) tailoring a policy suited to India's unique security issues, 2) avoiding a blanket open policy that may lead to misuse of low resolution data, 3) heeding restrictions on mapping, considering that 43% of landmass was not represented on maps presently (a probable solution was to do feature based mapping), and 4) clarifying government regulation of drone-based mapping. Security concerns were raised frequently throughout the meeting. The Committee also recognised that for development, data sharing should be made more open. The Committee was keen to have the private industry as a partner in generation of geospatial data.

Private industry representatives agreed with the objectives of the policy and were willing to contribute to geospatial data generation. The Expert Committee mulled over the possibility of creating a Public Private Partnership to cater to data generation. The private industry complained about the lack of efforts in popularising geospatial technologies and making the process of tenders more transparent.

There were suggestions to examine the policies of other jurisdictions facing similar internal security threats as India, and delineating the types of data that could be openly shared (for instance, geospatial data from border regions versus non-border regions). Segregation of restricted and open geospatial data can also be done on the basis of its end-application, such as for military and engineering purposes. Participants also requested the creation of a clear Do's and Don'ts guideline. CIS presented a written submission that raised seven key concerns. These are listed in the section below.

On the question of making an open data policy, it was suggested that the committee needs to decide the fundamental approach of the policy first - whether the policy should be based on prohibition and restriction, or focus on identifying and regulating open and free geospatial. The UN General Assembly document on Principles relating to remote sensing of the Earth from space provides an appropriate international point of reference [2].

After listening to the concerns and comments of the stakeholders, the core committee made the following concluding remarks:

• Existing policies of government and defence should be mapped out to avoid conflict or overlap with the proposed NGP policy
• The sharing of data vests with government agencies and other organisations recommended by them – there needs to be a transparent mechanism for such recommendation based sharing
• Industry should come up with self-regulatory mechanisms, do's and don'ts, and code of conduct
• Develop a secure mechanism for providing data on sensitive areas (in terms of national security;
• Even the defence agencies sometimes cannot access maps due to policies of the National Remote Sensing Centre and other agencies – such inconsistencies need to be fixed

It was announced that the next consultation will occur in a couple of months, and will be open to the public at large, including representatives of industry, defence, and civil society.

Key Concerns about the NGP Concept Note

1. Complete lack of availability of open geospatial data from Indian government agencies: No government agency in India publish open geospatial data. While maps are often sold, both in printed and in digital form, they are not provided in a machine-readable open format and under an open license. The concept note towards NGP has made strong commitments towards changing this situation. There is an immediate need to participate in the NGP drafting process, with coordination among various civil society actors interested in open geospatial data, to ensure that these principles are carried into and operationalised in the actual NGP document.

2. Need for explicit and comprehensive set of criteria to determine if a set of geospatial data is sensitive for national security reasons: In formal and informal conversations with various agencies collecting and creating geospatial data in India, the role played by security agencies in blocking proactive and reactive public disclosure of geospatial data, and even intra-governmental sharing of such data, has been highlighted. Addressing this issue requires development of an explicit and comprehensive list of criteria that will establish a clear and rule-based system for identifying if a specific geospatial data set is to be categorised as “shareable” or “non-shareable.”

3. No clarity regarding legal status of citizen/crowd-sourced geospatial data, and initiatives to generate them: Open user-contributed geospatial data, especially through the OpenStreetMap platform, has emerged as a key driver of the global geospatial services industry. There is a legal ambiguity created by the National Mapping Policy regarding generation of such data in India, which came into focus when Survey of India filed a case against Google for organising a Mapathon contest, which invited Indian users to add metadata about physical and built features through Google Maps platform.1 The NGP needs to expressly provide legal sanction (and perhaps framework) for citizen/crowd-sourcing of geospatial data.

4. Fragmented institutional structure for collection, management, and distribution of different kinds of geospatial data: Survey of India, Indian Institute of Remote Sensing, and Indian Space Research Organisation are all key government agencies involved in creating and managing geospatial data. Further, Election Commission of India is involved in preparing geospatial data about electoral units and their boundaries. The National Spatial Data Infrastructure was conceptualised to harmonise and centralise the geospatial data management processes, but is yet to be implemented with the backing of a policy or an Act. The NSDI can be institutionalised via the NGP as the national archive, aggregator, and distributor of open geospatial data, being originally collected and created by a range of government agencies.

5. Integration of National Geospatial Policy with National Data Sharing and Accessibility Policy (NDSAP): The proactive disclosure of “shareable” geospatial data using open geospatial standards and under open licenses must be carried out under the purview of the NDSAP, and through the open government data platform established through NDSAP. The decisions regarding licensing of open government data, as being discussed by the a committee set up under NDSAP, must also be applicable to open geospatial data that will be published following the instructions of the NGP. Further, instead of multiple online sources of open geospatial data collected by various Indian government agencies, must be identified as the primary and necessary source for publication of open geospatial data.

6. Integration of National Geospatial Policy with Right to Information (RTI) Act: Geospatial data must be treated as a special category of information under the RTI Act, which necessitates that if an Indian citizen requests for geospatial data from a government agency under the purview of RTI Act, the agency must provide the data in a human-readable and machine-readable open geospatial standard, and not only in the printed format, as key qualities of digital geospatial data can be substantially lost when printed in paper.

7. Need for special infrastructure for management and publication of real-time geospatial (big) data, and governance of the same: With increasing number of government assets being geo-referenced for the purpose of more effective and real-time management, especially in the transportation sector, the corresponding agencies (which are often not mapping agencies) are acquiring a vast amount of high-velocity geospatial data, which needs to be analysed and (sometimes) published in the real-time. The need for special infrastructure for such data, as well as its governance, has not been discussed in the concept note for NGP, which is a major omission.

Endnotes

[1] See: https://github.com/cis-india/website/raw/master/docs/DST_National-Geospatial-Policy_Concept-Note_2016.01.21.pdf.

[2] UNGA 41/65. Principles Relating to Remote Sensing of the Earth from Space: http://www.unoosa.org/pdf/gares/ARES_41_65E.pdf.