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Mozilla to TRAI: “toll free API and rewards-based incentives model threaten the open Internet”

net-neutrality

The Mozilla Foundation said in its submission that the models proposed by the Indian telecom regulator’s to giving cheap Internet may undermine its own decision of banning differential pricing. The filing was in response to the consultation paper that the the Telecom Regulatory Authority of India (TRAI) released in May 2016 discussing ways to provide cheap Internet access in India.

The regulator discussed three models of providing subsidised Internet access to users in that paper:

Data-cashback model: A telco agnostic platform that rewards consumers with recharge for data usage or voice usage
Toll-free model or like Airtel Zero: This makes access to some websites free
The FreeBasics Model or the direct money transfer model: Users are reimbursed by a telco agnostic platform that tracks their real time data consumption and tariff

The last two models are especially harmful and violate the principals of net neutrality as we have pointed out before.

The foundation said that it doesn’t support the argument that providing limited access to a small number of websites to those who have not used Internet before offsets the harmful effects of discriminatory pricing.

It is difficult to see how some of the models described in this consultation comport with the equal-rating principles or with TRAI’s previous regulatory guidance in the Data Services regulation. More specifically, we are concerned that the toll free API and rewards-based incentives model threaten the open Internet and would ultimately undermine TRAI goals of protecting Indian users.

What Mozilla said

Telco agnostic platforms don’t solve the problem: The foundation said there may still be a threat to the openness of the Internet and the risks posed by differential pricing will be left unattended even if a telecom operator agnostic platform rewards users with recharge for data. In this case, the platform effectively becoming the gatekeeper, performing the role of a telecom operator.

A TSP that charges different rates for data services depending on the content would directly undermine openness and user choice. Similarly, when a content platform is subsidizing the costs of the data of users to access their service, the end user’s experience is the same as if a TSP was involved: a user can access some content on the Internet for free or at a lower cost while having to pay for other content.

Toll-free model is bad: Mozilla argued that such a system will erode the benefits of level playing field that the Internet provides and will influence user choice.

…The toll free model is not content- agnostic and is a form of pay-per-play. It would lead to favoured content in the Internet ecosystem, the outcome that TRAI’s prohibition on differential pricing sought to eliminate.

It added that any business that rewards consumers for using certain websites or applications should be treated as a form of price discrimination, adding that such a system will favour the big companies, who have with the wherewithal to provide subsidies.

Direct money transfer model could work: The foundation found this one to be an acceptable alternative to provide subsidised Internet access without violating net neutrality — but only under certain conditions.

…A direct money transfer would be acceptable if it subsidized access to the full diversity of the open Internet without discrimination on the basis of content, application, or service sought by the user, nor type of content, application, or service.

However, it also raised two red flags regarding this model: the threat of user privacy getting compromised and a scenario in which the users get cash from content providers for using specific sites or applications, resulting in price discrimination.

What’s Mozilla solution

The foundation proposed equal rating which should have the following characteristics:

Content agnostic: The service provider should not subsidise the user based on the type content, application or service.

This does not mean that a service provider cannot limit the user to predetermined amounts of subsidisation – merely that the provider cannot control that decision on the basis of content, application, or service sought by the user, nor type of content, application, or service.

No gatekeepers: No one should be in a position to decide which services will be included in a subsidisation scheme and which ones should be left out.  

Even if the criteria applied are facially neutral, the process creates the possibility of subjective decision-making that introduces a risk of content-specific bias into the system.

No pay-for-play: The foundation said such systems will favour the big companies over the smaller ones and carry the same risk that arise with discriminatory practices.

Allowing content providers to buy their own subsidisation injects the same types of harms as paid prioritisation in the context of traditional network neutrality analyses.

Related:

Please see our filing here
Out net neutrality coverage here

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