The Smart Cities India Foundation made a submission to the Joint Secretary (Internal Security-I) on the draft Geospatial Information Regulation Bill, 2016 (the Bill). The Bill proposes restrictions on how geospatial information can be acquired, produced and used. In our response, we acknowledge that geospatial information is an important consideration for national security, while identifying how the Bill’s proposed regulatory regime is burdensome and has the potential to stymie collaboration and innovation in Indian cities. The Smart Cities India Foundation’s position and input is outlined below.

We acknowledge the intention of the Bill to regulate the use of geospatial information in India for national security purposes. While our foundation supports the general intention of the Bill, we have several concerns with its wording and the potential for it to stymie collaboration and innovation in Indian cities and urban centers.

In the Bill’s current form, it is not clear who will be affected by the proposed regulation. The all-encompassing definition of Geospatial Information in Chapter I Part 2 makes it seem as if any entity that creates, contributes or uses geospatial information will need a license to do so. A clear distinction needs to be made about who is a ‘producer’ of geospatial information that falls under the regulation and who is a mere ‘user’ of geospatial information.

Similarly, there should be further clarity around what forms of acquiring geospatial information come under the regulation of the Bill. The addition of ‘… any means whatsoever’ at the conclusion of Chapter II Part 3 §1 suggests permission from the Security Vetting Authority is required for the acquisition of any geospatial information. By your definition of geospatial information, this would include a person taking a photo of a damaged footpath and denoting its position on a map – a common action undertaken by citizens in sharing knowledge about the mobility and accessibility of their cities.

The broad definition of geospatial information and the regulatory restrictions placed on acquiring geospatial information raise concerns about the compliance regime of this Bill. Based on its current wording, everyone that uses or contributes to a crowd-sourced map or geospatial based application would be required to obtain a license from the Security Vetting Authority. This burdensome compliance regime is not realistic. The state funds required for compliance would not be proportionate to the societal benefits gained.

Finally, another important consideration is the reach of this Bill and the impact it will have on diplomatic relations with neighbouring nations that share disputed territory with India. While the intention of this Bill is to protect the Indian state and its citizens from national security threats, the impact of this Bill may incite potential threats.

We would like to express our support for the recently released National Geospatial Policy (NGP), which seeks to empower Indian citizens and businesses through Geospatial Data, Products, Services and Solutions (GDPSS). Revisions to the Bill should align with the sentiments outlined in the NGP.

Our foundation opposes slow, costly and burdensome regulation that disempowers businesses and everyday people to innovate and develop geospatial tools that improve the quality of life of urban citizens. We note that map makers and contributors, and the process of crowd sourcing will play an integral role in supporting the migration of 400 million Indians to urban centres by 2050. As Indian cities grow at a rapid pace, maps quickly become outdated without crowd sourced contributors. Urban citizens, and new migrants in particular, rely on crowd sourced maps to understand their ever changing cities, answering daily questions pertaining to location and navigation. Restricting the ability to do so would widen the geospatial information gap of cities, where city boundaries are ever expanding, new physical features continuously emerge, and maps quickly become outdated.

Additionally, it should be noted that crowd sourced maps play a vital role in smart crisis management during natural disasters. Crowd sourced contributions to open source maps inform citizens of new geographical features as they emerge. Examples of this were witnessed during the recent floods in Chennai, and the 2015 earthquake in Katmandu.

One way to balance the national security concerns highlighted in the Bill with the NGP’s sentiments of innovation and empowerment would be to substitute the Bill’s proposed licensing system with a simple registration based system. Producers of geospatial information would be required to register and supply a copy of their data to the Security Vetting Authority, which in turn would screen data and conduct audits in their own time. A registration based system would be more timely and impose on less regulatory burden.

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