Equal Rating

Access and Openness

At Mozilla, our mission is to ensure the Internet is a global public resource, open and accessible to all. Connecting the unconnected is one of the most difficult challenges in the realm of Internet policy. At the same time, we want all Internet users to have access to the full set of possibilities the Internet brings. Thus, as we put it in a letter to Prime Minister Modi of India: "Zero rating is not the right solution to connect the world's unconnected billions."

When we sent that letter, we didn't have all the answers to the questions of addressing access and openness challenges. We still don't. But an attitude of “just wait, eventually this will work out” is not acceptable. For the continued health of the Internet, and to help those who are not yet able to take advantage of its benefits, we are taking action to identify and realize the solutions we need.

As one part of our work in this space, we are pursuing an agenda around Equal Rating, our alternative framework under which subsidization and other models of reducing user-facing access charges are realized without limiting users' choice of content.

Mozilla workstreams

Mozilla’s equal rating work includes three core programs:

• Research – We are supporting field research and analysis to dig into deep questions about user behaviour and real-world effects of access models.
• Fostering innovation – We are sponsoring a public challenge to spur innovation into new ways to provide affordable access and cultivate digital literacy.
• Policy engagement – We are engaging with policymakers all around the world to offer guidance on these complex issues.

Research

The core of our work on Equal Rating is our research agenda. Over 2015-2016, we will support field research and analysis to dig into deep questions around user behavior and real-world impact of various subsidization plans, all targeting questions at the intersection of access and openness. Some of the questions we hope to drive insight into include:

• How do people use the Internet when their data are/are not subsidized? Do people actually move from subsidized limited plans to paid (full Internet) plans? Why do people use subsidized plans?
• What are scalable ways of cultivating digital literacy (capabilities)?
• What is the value of the open Internet from an economic perspective? Does increasing access to the open Internet provide more economic benefit than subsidizing a limited set of services?

Fostering innovation

We have launched the Equal Rating Innovation Challenge as a way to accelerate innovation in connecting the unconnected. Through the Challenge, we seek to grow the community of problem-solvers tackling these issues, and to support through funding and mentorship new ways to provide affordable access and cultivate digital literacy. We want to inject practical, action-oriented, new thinking into the current debate on how to connect the unconnected people of the world - and we’re going to support the proposals we receive through expert mentorship and a total of $250,000 in prizes.

Policy engagement

In two filings in India, we offered some deeper thoughts from a public policy / regulatory perspective on how to approach subsidization and the intersection of access and openness:

• June 2016: Filing: Comments by the Mozilla Corporation on the Telecom Regulatory Authority of India’s Consultation Paper on Free Data
• December 2015: Filing: Mozilla Comment on TRAI consultation paper on differential pricing

In a filing with the Body of European Regulators of Electronic Communications (BEREC), we elaborated on our Equal Rating principles in more depth, as follows:

To us, “equal-rating” describes a model of subsidisation of user-facing access charges that does not introduce the risks to innovation, competition, and user rights inherent in zero-rated models in the market today. Equal-rating practices meet the following criteria:

1. They are content-agnostic. Subsidisation should not be subject to any predetermined limits on the content, application, or service sought by the user, nor type of 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.
2. They are not subject to gatekeepers. In many systems, a human element is involved in the approval of content before it can be included in a subsidisation scheme. This element effectively establishes a gatekeeper. 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. Gatekeepers create barriers to entry for existing and new players, raising transaction costs of market entry; this would undermine the essence of the “innovation without permission” principle, where anyone, anywhere, can reach an audience without permission from anyone or any entity.
3. They do not allow pay-for-play. 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. Smaller providers are far less able to pay than large, resulting in harm to competition, innovation, and user choice.

Although somewhat distinct from the concept of “equal-rating” itself, good commercial practices should also follow two additional principles: They should be transparent, and should support user and content provider choice. The service provider should disclose details of the practice, including coverage limits as well as any tradeoffs the user will experience (e.g. for communications throughput or latency). Ideally, users should not be automatically added to a commercial practice that affects their experience, but should be required to opt in, after being presented with an opportunity to review technical disclosures regarding the practice. Finally, if there are any technical changes made to the content, application, or service as part of the practice (as with the U.S. case study Binge On, where total bandwidth was throttled among other changes), then content provider choice is fundamental as well, as content providers should be able to avoid the technical tradeoffs, even if a user chooses them, if in the provider’s mind they impact the desired end user experience.

• July 2016: Filing: Comments by the Mozilla Corporation on the Public Consultation on the Draft BEREC Guidelines on implementation by National Regulators of European net neutrality rules

Broader initiatives

We are engaged in several international initiatives that relate to the significant challenges of access and openness, as the problem is larger than what we alone can tackle. Two of these such programs are Global Connect and WEF's Internet for All.

Global Connect

Global Connect brings together high-profile US government and international actors. It is a useful gathering of leading thinkers and implementers working to connect the unconnected. Global Connect has focused in substantial part on getting finance ministries, development banks, and other development stakeholders to focus more on expanding access to the Internet. The forum brings together individuals and organizations that have the resources and connections to generate real world change.

World Economic Forum (WEF)

The World Economic Forum (WEF) Internet for All program intends to develop a scalable, replicable new model of public-private collaboration to accelerate Internet access and adoption for the billions not connected today. The first country program to be set up is for the Northern Corridor countries of Rwanda, Kenya, Uganda, and South Sudan. Additional country programs (up to three in total) in other regions of the world (Asia, Latin America) will be scoped in 2016.