Indian Aerial Photography Policy – A Critique

Indian Aerial Photography Policy – A Critique


Many geospatial professionals are looking expectantly at the issue of the new UAV policy which, they hope, will open up the market for their use in remote sensing imaging using sensors like digital cameras, Lidar and SAR. The fact is that the UAV policy under discussion will only empower the DGCA to issue permission for flying the platform over a particular region. It does not cover permission for the devices and sensors that are proposed to be mounted on the platform. That is covered in another Policy issued by MoD entitled “Instructions for Conduct and Clearance of Aerial Photographic Survey/Aircraft borne Remote Sensing data and imageries, acquisition, classifications, storage and issue” dated May 1, 2006.

The order covers “aerial Photography/Air Borne Remote Sensing Data and Imageries  (sic)(ABRSD&I) through Analogue Metric Camera (AMC), Air Borne Laser Terrain Mapping (ALTM), Synthetic Aperture Radar (SAR), Hyper Spectral Scanner (HSS), Geophysical Sensor, Electromagnetic Sensor, Digital Camera or other approved techniques of aerial survey.” The order also differentiates between ‘aerial commercial photography for live news’ and aerial photography for scientific and technical uses. Live aerial photography for news should be ‘covered by the DGCA in accordance with the MoD guidelines’. It also differentiates the use of aerial photography by Survey of India and NRSA (now NRSC) from aerial photography by other agencies ‘for aerial photography of smaller areas’. This assumes that bigger areas are covered only by government agencies.

The procedure involves multiple agencies. All applications for aerial photography/ABRSD&I are required to be made to the Director General of Civil Aviation (seven copies) at least 6 weeks before the date on which the photography is desired to be carried out. The application must clearly indicate inter alia the purpose for which aerial photography/ABRSD&I is required and details about the flying agency to be engaged for the tasks. “The Director General of Civil Aviation (DGCA) will make references to the three Service Intelligence Agencies, Intelligence Bureau (IB) and AHQ/GSGS simultaneously along with Ministry of Defence/D(GS-III) depicting the area to be photographed. After obtaining the requisite clearance/comments from all concerned, Ministry of Defence/ D (GS-III) will issue security clearance for such aerial photography incorporating such condition(s) as deemed necessary”, says the order.

The DGCA security clearance “shall incorporate all the conditions/restrictions as imposed by the Ministry of Defence in their clearance as enumerated above in the flight permit to be issued by them”. The security clearance is valid for 12 months. The concession to SoI and NRSC is that they can directly approach the other agencies mentioned above with copies to DGCA. Another concession is for aerial photography of disaster hit areas. Here the flying can be done under intimation to MOD and IB/MHA but the data will have to be cleared for use by a Core group comprised of security agencies with a mandate to clear the data expeditiously. There are elaborate instructions for the clearance of the data for storage, issue, use and periodic verification. Further, a Security officer from the armed forces or the Administration must be on board the aircraft for whom a Life Insurance of Rs 20 lac has to be obtained by the client agency.

This procedure is cumbersome and fraught with possibilities of delay. Due to the detailed rules with several concessions and exceptions the application itself is a laborious exercise. Further, the involvement of multiple government departments, each with their own rules and priorities and without any time limit for the processing, makes the process vulnerable to delays. The multiple stages of permission, data acquisition and data vetting include permission from MoD for area to be surveyed, permission from DGCA and local authorities for flying, appointment and availability of the Security Officer and Security Vetting of data for VAs, VPs for giving permission/clearances. All this leads to delay, arbitrary actions, cost escalations, etc.

While the order does recognise the use of sensors other than aerial photographic cameras the subsequent paragraphs exhibit the bias towards film cameras and manned aircraft. The sections on ‘Storage and Issue’ and ‘Custody and Handling of Aerial Photographs/Data’ reveal this bias. It seems that by adding ‘/Data’ everywhere that ‘Aerial Photograph’ is mentioned, marginal cognisance is given to modern data sources. Even for 2006 the instructions are too dated and in 2018 they are just not up to scratch. Considering the fact that the release of the UAV Policy is likely to create a huge demand for imaging applications, it is necessary that the Aerial Survey Policy be revised.

While DGCA is treated as a single window but the involvement of so many agencies with so many caveats makes the single window ineffective. The first step is to digitise the entire process and do away with the seven copies of the application. While disaster situations need to be handles uniquely, the separation of government and other agencies is artificial, particularly since the demand for UAV surveys will come from many agencies, government, academic and private. A well designed IT based system is required which can register the request online, alert the concerned agencies, set automatic deadlines and issue reminders till the application is authorised with or without caveats or rejected with reasons for the rejection.

Secondly, while the application must be made at least six weeks in advance there is no guarantee that the involved process can be completed well in advance of the actual survey. This requires some time management. Each step must be time barred and failure to keep to the schedule must be flagged and appropriate action taken. Thirdly, the need for a Security Officer to fly is no longer required as modern aerial data acquisition systems are completely digital and automatic. The parameters of the survey are set well before the actual flight as per the clearances received from the authorities and survey requirements. The security officer can do a pre-flight check and a post flight check to ensure that all instructions have been followed.

Similarly, the need for post flight data review can also be automated using the quicklook data generated by the data acquisition systems. The data can be vetted with online digital  data on VA, VPs and other no-fly zones using software and the data cleared as soon as the survey is completed. This will speed up further down the line utilisation. Data storage, issue and safety are all amenable to digital solutions without ‘strong rooms’ because the data is digital and used on digital systems like image processing systems, GIS, Visualisation and Analytics software. Only the final results may be printed if required in a project report, scientific report or conference paper.

These suggestions are made to initiate a relook at a policy which is 12 years old, bring it up to date and make it efficient taking into account modern needs and modern data acquisition, storage and supply systems.