Wednesday 15 April 2015

DEFENCE MAKE POLICY
















INFRASTRUCTURE & DEFENCE ENTREPRENEURS’ ASSOCIATION

KULDEEP KUMAR KOHLI
PRESIDENT
         

15.4.2015

Maj. Gen. Bhuwan Chandra Khanduri, AVSM (Retd),
Member of Parliament & Chairman,
Standing Committee on Defence,
7 K Kamraj Lane,
New Delhi – 110011

REQUEST FOR A PRESENTATION BEFORE THE STANDING COMMITTEE ON DEFENCE ON IMPORTANT ISSUES CONCERNING “MAKE PROGRAMME” OF THE MINISTRY OF DEFENCE

Dear Sir,

We shall be extremely grateful for an opportunity to give a presentation to the Respected Chairman and the Members of the Standing Committee on Defence during the next meeting on some of the major issues of concern to the Industry / MSMEs.

Infrastructure and Defence Entrepreneurs Association (IDEA) is an association of Indian businesses which works closely with the Government on policy issues, interfacing aspiration of the industry with the decision makers and in the process enhancing efficiency in speedy resolution of the industry’s issues.  We are associated with more than 1500 industries in the country.

“Transparent and swift decisions"  have always been the speciality of your Government and your Government has been kind in making announcements on the policy reforms to be brought into the Defence sector for providing necessary boost to the ‘MAKE” programme of the Ministry of Defence,  to encourage the growth of private Defence industry in India.

There is no second thought to the fact that the Ministry of Defence is looking to increase “MAKE” opportunities.  We have also been given to understand that the MoD is expected to finalize the “MAKE” category of the Defence procurement procedure very shortly to make the option more attractive to the domestic industry. 

We are also aware of the fact that the focus of the Ministry of Defence is to ensure participation of more indigenous manufacturers in the Defence industry of India and hence it is your endeavour to dilute the current policy a little and make it easier to understand and more attractive for Indian vendors who are investing in the high risk areas.

We have been given few representations by the members of the Defence industry in the country requesting us to pursue for the following changes in the “MAKE” Defence Procurement Policy

1.   DILUTING THE CONDITION OF MINIMUM CRISIL/ICRA CREDIT RATING FROM “A” TO “B++”

2.   REMOVING THE NETWORTH CONDITION/ REDUCING THE “POSITIVE NET WORTH” OF 5% OF THE PROJECT VALUE WITH A MAXIMUM NETWORTH NOT EXCEEDING RS. 750 CRORES.  

One of the major issues of concern to the industry is the company credit rating equivalent to “A”.  This needs to be diluted to “B ++”.

Similarly, the “POSITIVE NET WORTH” criteria of 5% of the project value with a maximum “NET WORTH” not exceeding RS. 1250 Crores need to be reduced to maximum of Rs. 750 CRORES.  

Sir, the earlier policy of the Ministry of Defence required the following three conditions:

  1. Asset base of Rs 100 Crore
  2. Turnover of Rs 1000 Crore for last three years
  3. CRISIL/ ICRA rating of “A”
We are unable to understand why; it is now proposed to make the requirement of net worth to 5 % of the project cost with a maximum “Net Worth” of Rs 1250 Crore, without specifying any reason. If at all it is necessary to impose the condition of the maximum “Net Worth”, it should be limited to Rs. 750 Crores.

If the companies could bid for large ‘Make’ projects like BMS and TCS without the “Net Worth” criteria in earlier conditions, we do not think there is any need to add the same now, as this would not serve any national interest.

3.   TIMELY SHARING OF GSQR AND

4.   TIMELY SHARING OF QUANTITIES REQUIRED BY MINISTRY OF DEFENCE

It may be appreciated that in the absence of the following, the industry is handicapped for time to scout for foreign tie-ups or to establish the necessary manufacturing facilities:

  1. Firm requirements of the armed forces made known to the private sector sufficiently in advance and
  2. Timely sharing of GSQR, either during formulation in consultation with the industry or immediately after the formulation.

We shall be extremely grateful for your personal indulgence in getting the above suggestions implemented on priority which would help the defence industry in ensuring success to the “MAKE” programme of the Ministry of Defence.

We do appreciate that the matters concerning security have to be given overwhelming consideration while formulating macro policies, it devolves on the government to strike a fine balance between aspirations of the industry and security concerns of the country.

Sir, “The Technology Perspective and Capability Roadmap” (TPCR) does provide necessary guidance to the Indian defence industry to an extent but the same in the present shape is very broad based and generic in nature.

  1. THE FLEXIBILITY TO ADD AND OR AMEND THE INDIAN OFFSET PARTNER (IOP)

  1. THE FLEXIBILITY TO WORK THE PACKAGE WITH RETROSPECTIVE EFFECT I.E. APPLICATION TO ALL CONTRACTS INCLUDING PREVIOUS UNDER EXECUTION

We shall be extremely grateful if the Offset” Policy of 2012 is amended to accommodate the OEM on the following issues.

  1. OEM is permitted to choose his IOP and the work package as he so desires.  This would give the OEM all the flexibility.

  1. The amendment so permitted to be effective on all contracts under execution which means it would have retrospective application and will be governed under a amended 2012 policy/procedure.

7.   KEEPING THE NET WORTH CRITERIA OPEN IN THE MAIN POLICY
Sir the proposed policy incorporates that in case the “Net Worth” criteria is considered too high or too low for the purposes of adequate EOI responses, the Feasibility Study will bring out an alternate specific recommendations for consideration of the DAC/DPB/SCAPCHC at the time of AON

This may not be a good option as keeping the criteria open in the main policy is not considered to be a transparent policy and would, therefore, be vulnerable to last minute influences to serve individual goals.


  1. NO NET WORTH CRITERIA FOR SMES

 This definitely is a very Welcome move.

We shall be extremely grateful if these important issues are looked into and the necessary changes as suggested are incorporated in the new “MAKE” criteria under finalization which would help the private industry unleash the full potential.


Warm Regards

Yours Sincerely 


(Kuldeep Kumar Kohli)

===========================================================
Correspondence Address | V 3/11, PHASE III, DLF CITY,  Gurgaon - 122001.
M +91 8860332404  F +91 124 6139105 Mail: idea.defense.policy@gmail.com


DEFENCE MAKE POLICY


INFRASTRUCTURE & DEFENCE ENTREPRENEURS’ ASSOCIATION

KULDEEP KUMAR KOHLI
PRESIDENT



15th April, 2015


Shri Manohar Parrikar,
Honourable Minister for Defence,
Ministry of Defence,
Government of India,
South Block, New Delhi

Flexibility to add/or amend the Indian Offset Partner (IOP) and the work package with retrospective effect i.e. application to all contracts under execution.

Sir,

As you are aware, IDEA is an association of Indian Defence and Infrastructure businesses which works closely with the Government on policy issues.

One of the major issues of concern to the industry is:

1.    The Flexibility to add and or amend the Indian Offset Partner (IOP)

2.    The flexibility to work the package with retrospective effect i.e. application to all contracts under execution.

We shall be extremely grateful if the Offset” Policy of 2012 is amended to accommodate the OEM on the following issues.

1.    OEM be permitted to choose his IOP and the work package as he so desires.  This would give the OEM all the flexibility.

2.    The amendment so permitted to be effective on all contracts under execution which means it would have retrospective application and will be governed under a amended 2012 policy/procedure.


Warm Regards

Yours Sincerely 


(Kuldeep Kumar Kohli)

===========================================================
Correspondence Address | V 3/11, PHASE III, DLF CITY,  Gurgaon - 122001.
M +91 8860332404  F +91 124 6139105 Mail: idea.defense.policy@gmail.com



Friday 10 April 2015

DEFENCE MAKE POLICY



INFRASTRUCTURE & DEFENCE ENTREPRENEURS’ ASSOCIATION

KULDEEP KUMAR KOHLI
PRESIDENT



08 April, 2015


Shri Manohar Parrikar,
Honourable Minister for Defence,
Ministry of Defence,
Government of India,
South Block, New Delhi


Respected Sir,

DILUTING THE CONDITION OF MINIMUM CRISIL/ICRA CREDIT RATING FROM “A” TO “B++” AND “POSITIVE NET WORTH” OF 5% OF THE PROJECT VALUE WITH A MAXIMUM NETWORTH NOT EXCEEDING RS. 750 CRORES.  

“Transparent and swift decisions"  have always been your speciality and you have been kind in making announcements on the policy reforms to be brought into the Defence sector for providing necessary boost to the ‘MAKE” programme of the Ministry of Defence,  to encourage the growth of private Defence industry in India.

There is no second thought to the fact that the Ministry of Defence is looking to increase “MAKE” opportunities.  We have also been given to understand that the MoD is expected to finalize the “MAKE” category of the Defence procurement procedure very shortly to make the option more attractive to the domestic industry. 

We are also aware of the fact that the focus of the Ministry of Defence is to ensure participation of more indigenous manufacturers in the Defence industry of India and hence it is your endeavor to dilute the current policy a little and make it easier to understand and more attractive for Indian vendors who are investing in the high risk areas.

We have been given few representations by the members of the Defence industry in the country requesting us to pursue for the following changes in the “MAKE” Defence Procurement Policy. Though a detailed list of the changes requested is enclosed at Annexure “A”, but one of the major issues of concern to the industry is the company credit rating equivalent to “A”.  This needs to be diluted to “B ++”.
Similarly, the “POSIIVE NET WORTH” criteria of 5%  of the project value with a maximum “NETWORTH” not exceeding RS. 1250 Crores need to be reduced to maximum of Rs. 750 CRORES  

Sir, the earlier policy of the Ministry of Defence required the following three conditions:

1.   Asset base of Rs 100 Crore
2.   Turnover of Rs 1000 Crore for last three years
3.   CRISIL/ ICRA rating of “A”

We are unable to understand why; it is now proposed to make the requirement of net worth to 5 % of the project cost with a maximum “Net Worth” of Rs 1250 Crore, without specifying any reason. If at all it is necessary to impose the condition of the maximum “Net Worth”, it should be limited to Rs. 750 Crores.

If the companies could bid for large ‘Make’ projects like BMS and TCS without the “Net Worth” criteria in earlier conditions, we do not think there is any need to add the same now, as this would not serve any national interest.


We shall be extremely grateful if this important issue is looked into and the necessary changes as suggested in the enclosed sheet are incorporated in the new “MAKE” criteria under finalization which would help the private industry unleash the full potential.


Thanking You






Kuldeep Kumar Kohli
PRESIDENT



DEFENCE MAKE POLICY




INFRASTRUCTURE & DEFENCE ENTREPRENEURS’ ASSOCIATION

KULDEEP KUMAR KOHLI
PRESIDENT



09th April, 2015

Shri Manohar Parrikar,
Honourable Minister for Defence,
Ministry of Defence,
Government of India,
South Block,
New Delhi


SUBJECT: TIMELY SHARING OF GSQR AND QUANTITIES REQUIRED FOR MINISTRY OF DEFENCE


Dear Sir,

Infrastructure and Defence Entrepreneurs Association (IDEA) is an association of Indian businesses which works closely with the Government on policy issues, interfacing aspiration of the industry with the decision makers and in the process enhancing efficiency in speedy resolution of the industry’s issues.  We are associated with more than 1500 industries in the country.

We wish to highlight three critical issues of import that resonate amongst the existing members, as also with the new entrants who are on the threshold of joining the Defence industry, which require your kind attention, for the growth of the Defence Industry in India under the MAKE programme and to make the MAKE IN INDIA ambition of the respected Prime Minister a great success.  The issues of concern are dilated below.

1.  Does the Indian manufacturer has a right to manufacture good for supplies to defence based on its own QR Quality Requirements (specifications)

The answer is no because the specifications have to be provided by the ministry of defence. The government wishes to keep the same confidential in the interest of the national security till the time the RFP is issued.

2.  Does the Indian manufacturer know the second QR ie. Quantity required by the ministry of defence for him to get geared and prepared for manufacturing the same well in advance.

The answer again is no because the ministry of defence again wishes to keep this information confidential in the national interest till the time the RFP is issued.

3.  Do the above two informations remain confidential

The answer again is no because in view of the fact that from the stage of the RFP till the time the delivery of the goods starts,  it takes almost four to eight years and hence the entire information is in the public domain from the day the RFP is issued till next four to eight years.

We do appreciate that the matters concerning security have to be given overwhelming consideration while formulating macro policies, it devolves on the government to strike a fine balance between aspirations of the industry and security concerns of the country.

Sir, “The Technology Perspective and Capability Roadmap” (TPCR) does provide necessary guidance to the Indian defence industry to an extent but the same in the present shape is very broad based and generic in nature.

It may be appreciated that in the absence of the following, the industry is handicapped for time to scout for foreign tie-ups or to establish the necessary manufacturing facilities:

a.  Firm requirements of the armed forces made known to the private sector sufficiently in advance and

b.  Timely sharing of GSQR, either during formulation in consultation with the industry or immediately after the formulation.

We shall be extremely grateful for your personal indulgence in getting the above suggestions implemented on priority which would help the defence industry in ensuring success to the “MAKE” programme of the Ministry of Defence.

Warm Regards
Yours sincerely

(KULDEEP KUMAR KOHLI)