The Draft Indian Space Policy 2022 is a welcome step in the right direction. Compared to the version of 2017, it is indeed a vast improvement. That said, at first reading it appears to be more of a statement of intent of Indian National Space Promotion & Authorization Center (IN-SPACe) vis-a-vis Non Governmental Entities (NGE) rather than a comprehensive Space Policy document.
A country’s Space Policy should be a guideline for all Indian entities who are involved or would like to get involved in space technology, applications and research and should also declare to the world the country’s aspirations, expectations, rules and regulations and the way foreign entities can get involved, if they wish to do so, in Indian space activities.
The preamble and Vision statements are excellent. The Policy Objectives are well stated but too inward looking. For example the statement “…to contribute to the key drivers for economic development of the nation and welfare of the citizens” is good but incomplete. As a policy document it should recognize the need for India to integrate into the world space activities – scientific, legislative, humanitarian and commercial. There are many Government Departments, Industries, Academia and agencies who have shown their capability in various areas of Space. As this is the country’s Space Policy, singling out just DOS limits the ambit of the policy.
The positioning of India as a global space power is missing in the policy objectives itself. International Collaborations, Global Marketing are addressed but these are in the form of statements tucked away in several sections. On the Regulatory issues apart from ITU there are no mentions about our involvement with UNCOPUOS and UNOOSA and our endorsement of the Outer Space Treaty, Moon Treaty, etc. Even UN GGIM and international NGOs like GEO and WGIC are not addressed, though their areas of operation are critical to our work in Earth Observations. Our policy for International efforts like Artemis, is not covered.
Section 4, which expands the Policy objective 1, is quite detailed as far as Satcom, EO, PVT (also known as PNT), launch services and Space environment are concerned. However, are NGEs and DOS the only players? There is no mention of Department of Telecommunications, Department of Science and Technology, Department of Information and Broadcasting and Ministry of Earth Sciences who are major players owning, operating and using space assets.
Many commercial organizations use space for their work. Other ministries like External Affairs, Commerce which play significant roles in interacting with international Space related government organizations, UN and its Agencies, international Commercial agencies, and international NGOs are not mentioned. Most importantly academic institutions in India and their collaboration with international institutes in matters of space is not covered.
The section 5 goes into great detail on the matter of encouraging, fostering and supporting NGEs. It talks of ease of doing business without detailing how the policy will implement it. This will require the active involvement of several Indian Government entities mentioned in the previous paragraph. It should be noted that NGEs still prefer to establish their companies outside India though their work is done in India. Secondly, while IN-SPACe will help Indian industry to achieve Global standards it does not talk of how Industry will be enabled to break into the Global market. This should have been a part of the policy.
The task of coordinating and supporting academia in advanced research as envisaged in section 6 is entrusted to DOS alone. This is again too restrictive. Academic institutes should be free to define their own programmes without being tied down to one department. Department of Science and Technology and Ministry of Earth Sciences have strong programmes in space research. Other premier organizations like TIFR as well as many NGOs are active in this field. International cooperation in this area is essential and should be covered by the policy.
Since there are mentions of International Treaties and International Collaborations it is important to spell out the mechanisms of operationalizing this. While ITU finds mention in several places, the all-important UN Committee on Peaceful Uses of Outer Space and its Treaties are not specifically referred though generally mentioned as “various international Treaties and Conventions”. Similarly the importance of UN bodies like the UN-GGIM do not find a reference even though their work is of significance in Earth Observations. There are other NGO bodies like Group on Earth Observations (GEO) which need to be taken into cognizance.
Section 7 deals with the regulatory framework. While IN-SPACe as a single window is a good step, the process of authorization will need the involvement of MEA, Ministry of Commerce and Ministry of Law. The policy is not clear on this. In particular, Section 7.8 suddenly goes into the nitty gritty of spatial resolution. This is out of place. The New Geospatial data policy has freed maps up to one meter resolution. A harmonization with this policy should have been a part of the Space Policy.
Section 8 is an expression of intent. Why should it only refer to DOS? Every institution in the government, in industry, in academia and NGOs should be involved. The Policy should spell out how. This is missing.
Section 9 is the most important and brief. Here again DOS is given sweeping powers without any mechanism of checks and balances. Perhaps an Empowered Committee with DOS as its chair and involving major stakeholders would be required.
All in all the Space Policy is work in progress. It is certainly an improvement over the previous effort of 2017. However, it still is far from an Indian Space Policy. At best it is an expression of intent of how DOS will work in the changed environment.
