A group of volunteers going by the name of Save the Internet (STI) published an open letter to Facebook CEO Mark Zuckerberg on the topic of Net Neutrality. I too favor Net Neutrality, and that's all I will say about that, but STI gets a lot of things wrong in its letter, and in doing so, may end up doing more harm than good by creating an environment where policy is made on erroneous popular sentiment rather than reasoned argument.

I have reprinted the letter in full below (in italics), so that nothing is taken out of context. Parts to which I refer are in bold face. I'm going to continue to refer to Facebook's zero-rating service as Internet.org. If you want, you may replace it with Free Basics.

We thank you for your recent visit and your continued interest in India. As a group of volunteers part of the Save the Internet Campaign, we have been engaging on the issue of Network Neutrality for much of the past year. It is a matter of distress that Facebook, through its internet.org platform and in its lobbying on regulatory consultations, has sought to undermine Net Neutrality in India and also increasingly questioned the motives of more than a million Indians who have participated in consultations organised by the Telecom Regulatory Authority of India (TRAI) as well as the Department of Telecom.

It's not clear how STI means it, but Internet.org is not just targeted at India. As such it is not a means to undermine net neutrality in India.

Yesterday, in your townhall address at IIT Delhi, you mentioned that “Those who don’t have access to the Internet cannot sign online petitions,” trying to make a case that those who oppose of your Net Neutrality violating Internet.org/Free Basics service are campaigning against those who do not have Internet access. Nothing could be further from the truth. Many of us have benefited from the Internet because of the openness, plurality and diversity it has to offer. We want more people to get access to the internet—the entire internet—and not primarily the filter for the web that you have set up with Internet.org/Free Basics.

This is the core of STI's stance, that it either has to be all or none. As such, they are indeed making a decision for those who do not currently have access to the Internet. Where this position goes wrong is that there is no force or compulsion on anyone to use Internet.org. Those who do not have the Internet now have at least three options: 1) do nothing and continue without access to the Internet; 2) Use Internet.org and access the Internet in whatever limited fashion it offers; 3) Pay for the full Internet access. Given that, why do those behind STI object? Let's read on and see.

We’d like to remind you that Tim Berners-Lee, one of the founding fathers of the Internet who strives for expanding its use by the entire web recently called Zero Rating “Economic Discrimination”, saying that “Economic discrimination is just as harmful as technical discrimination, so ISPs will still be able to pick winners and losers online.”

This is perhaps nitpicking, but you will see this again and again. Tim Berners Lee is the inventor of the World Wide Web, not the Internet. The Internet existed much before the Web and goes back to research backed by the US Department of Defense. The point being that if you want to champion access to the whole Internet, stop mis-attributing it's genesis to a person responsible for one aspect of it.

Beyond that, there are other objections to this argument. Why should Berners-Lee get a more prominent voice in this debate? Alexander Bell may have invented the telephone but he didn't get to dictate the course of telephony; Edison did not get a say in how future light bulbs should be used or manufactured.

There are many programs in the world that give poor people food, clothing, mobile phones, education, shelter. What they are offered is not high cuisine, new designer clothes, the latest high-end smartphones, entrance to prestigious schools or luxury housing. By Berners-Lee's standards, these are all forms of economic discrimination, and as such, should be stopped.

Even today, Internet.org has restrictions that those services which compete with telecom operator services will not be allowed on it.

STI makes this claim, but provides no link to any document that states this. I am not saying STI is wrong, here are the Internet.org participation guidelines, and they contain no such objection.

WhatsApp would have never emerged on this platform.

Perhaps not. Internet.org does not claim to be an incubator for new applications or services. This is not an argument.

You also reserve the right to reject services from Internet.org. We fail to understand why, if it is an open platform, someone even needs to apply, and conform to your pre-defined technical limitations, and has to go through unspecified checks determined by your organization.

Perhaps STI should stretch their collective minds and ask themselves why a platform with the aim of offering limited data usage services that can be accessed on feature phones and 2G networks may want to make sure that participating services conform to that goal.

STI can read the technical requirements here.

Internet.org is not an open platform, and all we are asking for, is for you to ensure that any such effort to bring access to the Internet ensure that users get access to the entire Internet, and not through a pre-determined menu or filter, which primarily benefits those who are selected for the platform.

Once again, STI asks for all or none. What STI is asking for shows a complete failure to understand the nature of Internet.org. It is a marketing venture between Facebook and a participating telecom company wherein an end user is getting free access to possibly stripped-down versions of some sites. Facebook has said that there is no monetary exchange in the arrangement. Therefore the telecom company is not getting any revenues from carrying the data. In that scenario, total access to the entire Internet, say to Netflix, makes no sense whatsoever. I don't mean to say that not everyone should have access to Netflix, but if they want it, they can pay for a regular Internet connection. The same goes for Spotify, YouTube, YouPorn, and all the rest of the Internet that STI refers to.

The preceding passage begins with the users in mind, but by the end, it loses focus. The primary beneficiaries are also those end users who get access to content on the Internet.

While we understand that there is currently no paid arrangement between Facebook, its partners and telecom operators, and you’ve suggested that this is a philanthropic endeavour, there is no undertaking from you that there won’t be any future arrangements for Facebook’s benefit.

So is this all about fear of the unknown? If Facebook makes such an undertaking, would that resolve the issue? Is that the ask, then?

Internet businesses like Facebook and Google have been built around the idea of offering services for free in the beginning, and then monetization through means such as advertising.

There is so much that is wrong in just this sentence. First, it is trying to dictate acceptable business models for Facebook and Google. Second, it is factually false. Facebook has tried many different business models, including charging for content. Third, what else does "means such as advertising" encompass? Advertising is a category in itself. Other categories include charging for content, and charging for services.

This is keeping in mind the choice of the “.com” URL for FreeBasics.com, as opposed to a “.org” for Internet.org.

The last I checked, there are absolutely no limits on the kind of economic activities carried out by a top-level-domain of .com or .org. If Facebook really did intend to be sneaky about monetizing Internet.org one day, it probably could have stuck to a .org domain.

You’ve also suggested that universal access is more important than Net Neutrality, and that there is a possibility of taking Net Neutrality “too far”. That is plausible if, and only if there aren’t any options available which provide universal access without violating Net Neutrality. Some examples, in case you haven’t heard of them:

The Mozilla Foundation runs a program with Grameenphone, where users get free data in exchange for watching an advertisement.

Aside from the press release, there's nothing more about this on Grameenphone's Web site. Is STI sure this is an actual current program? Mozilla also announced a program for India, but to date it hasn't launched. Asking Zuckerberg to consider nonexistent alternatives seems like a poor tactic.

The Mozilla Foundation also runs a program with Orange in Africa, where those who purchase a $37 handset get 500 MB of free data.

That was the press release story. In Cameroon it costs $41 (not a big diff) but only comes with 300MB/month for 3 months. The 3.5" screen phone runs Firefox OS, so the app store is limited and, therefore, users do not get the full Internet experience (no Skype or WhatsApp, for example).

There are data cashback schemes such as Gigato offer data for free, for surfing some sites. Airtel has launched night plans, which give data as a cashback upon usage of the Internet between midnight and 6am, helping bring cost of access down.

If Mark Zuckerberg claimed that Internet.org is the only available solution then he is indeed wrong. Otherwise, telling him that a telco has come up with its own marketing gimmick that may lower access cost a little bit doesn't make sense.

Therefore, one does not have to choose between Universal Access and Net Neutrality.

So STI is saying that there are alternatives to Internet.org. Is there anything preventing those alternatives from being implemented in India? Are the services indistinguishable to the end user? If so, let competition flourish, let Mozilla offer its product in India and let the market decide which service will last. Why does STI believe that advertising is a wholly preferable method to provide free services? Is it preferable to bombard children with advertising for sugar-laden products? The whole purpose of advertising is to influence consumer behavior, many times in ways that don't serve their best interests.

Qualitative research has found that less experienced, low income groups prefer access to an open and unrestricted Internet, and “some access is better than none”, but the trade-off they are willing to make is how much they use the internet, not necessarily how much of the internet they get to use. Therefore, the research indicates that users also don’t want that false choice between Net Neutrality and Access.

The research mentioned is based on interviews with "20 users, 11 mobile recharge shop retailers and marketing executives from 4 telecom operators." The second link leads to this statement by Helani Galpaya, who has been researching zero-rating plans in Myanmar: "We need a lot more research that is systematic and representative."

That said, if STI wants to go by the interview results, then they have already made the point for me: Users don't appear to want Internet.org. So what's with all the hue and cry? The currently unconnected will reject Internet.org and it will be relegated to the byte-heap of history.

It’s also a matter of concern that data for all the websites on Internet.org will be with Facebook, and restrictions are placed on them publicly disclosing usage of their sites and services by users on Internet.org.

The Internet.org guidelines state, "You may use tracking services, such as Google Analytics, Effective Measure, Chartbeat, etc. on your site." I cannot find any such restrictions there. Perhaps STI can share the link.

Apart from the fact that no open platform places such restrictions, this data and the learnings gained from it gives a competitive advantage to Facebook, because of the competitive advantage given to Internet.org by its telecom operator partners.

This makes no sense. Today telecom operators can gather data about all the mobile network usage habits of their subscribers. Google through Google Analytics collects data, and Comscore, StatCounter, Alexa are just a few of the better known ones. Ad networks also track Web users across their browsing history.

Lastly, we’d like to point out that Free Basics does nothing to help address India’s key problem—not one of getting more users online, given that the IAMAI has reported that we’ve added as many as 52 million Internet users in the last six months alone—but of improving access infrastructure so that users get seamless high speed connectivity.

Is STI asking Facebook to solve India's Internet infrastructure problems?

Since more people in the country do not have access to the Internet than those who do, is the key issue really the poor speeds experienced by those who have it? Some people, perhaps not STI, have called Internet access a human right, and likened it to utilities such as electricity or water. Let's use "water" instead of "Internet access" in the sentence above: "Free Basics does nothing to help address India’s key problem—not one of getting clean water to more people, given that the All India Jal Board (fictitious organization) has reported that we’ve added as many as 52 million water users in the last six months alone—but of improving access infrastructure so that water users get seamless high-pressure water delivery."

So those of you who don't have piped water, just hold on, it'll get to you someday. Those of us who do have it really would like to get it on a regular basis.

We need to focus on growing the pie, not splitting the pie. Our concern with Internet.org/Free Basics is that it will create a new digital divide: those who access Facebook and its partner services, and those who access the open Internet.

It would be great if STI could explain how Internet.org splits the pie or limits it from growing. How is it in Facebook's interest or the telecom operator's interest to limit users from accessing the entire Internet?

There are ways of providing Internet access in a manner that is open, so that everyone gets access to the whole of the Internet, without discrimination between web services, and without violating Net Neutrality.

Once again, Web and Internet are conflated. In addition to the Web, there are many other uses of the Internet: file sharing, music and video streaming, video conferencing, voice-over-IP, virtual private networks, email and much more. Yes, most of these are blocked on Internet.org, which is exactly the reason why people will move off Internet.org if they can.

The question is, what has prevented these other utopian ways of providing Internet access?

Don’t forget that Facebook benefited from this openness and neutrality.

Facebook came into existence when social networking sites were still very recent. People used it because it was much better than the horrorshow that was MySpace. At first, Facebook was only available at Harvard, then at other universities, so it was not operating in an open environment, even if by its own choice. Today, it would be very difficult to dislodge Facebook as the dominant social network. Just ask Google+. The point is that openness and neutrality aren't the most important factors for a service to succeed.

Facebook, along with its intentions to connection billions to the Internet, should support and advocate for Net Neutrality and permissionless innovation in India, the way it has done in the US.

What part of Internet.org places a burden on people to seek permission to innovate? The argument could be made that necessity is the mother of invention and as this is the land of jugaad, the limitations of Internet.org may spur some creative new solutions. That is just for the purpose of argument, but just as valid as the unbacked assertion that Internet.org will somehow stifle innovation.

As for the second part, Facebook has worked for the interest of Facebook, whether in the US or elsewhere. As a publicly-traded for-profit company, that's its mandate.

I have read some great discussions on Net Neutrality and zero rating. However, the arguments against Internet.org put forth by STI are all over the place, shifting and circular:

Internet.org violates net neutrality

Internet.org will destroy the Internet

People are wary of Internet.org

Internet.org doesn't bring new users online.

Nobody wants to use Internet.org

Internet.org violates net neutrality

Internet.org will destroy the Internet

The thing is that nobody actually knows whether Internet.org will bring online more people who are unconnected, or if it does, how many. Nobody really knows whether Internet.org will have a negative effect on the rest of the Internet, or what "negative effect" even means except for all the bad things that you could imagine. However, rather than taking a "let's try it for a limited time and see what happens" approach to the unknown, STI and many like-minded people just want to ban it.

I don't think that this article will change any minds, a lot of how people feel about Internet.org or other such programs depends on how they feel about risk and change. I think that the situation is similar to genetically modified food. However, I do think that we need to have solid arguments that withstand even a cursory scrutiny.

Further reading:

A paper on the economics of Zero Rating by Jeffrey A. Eisenach.

Internet.org myths-and-facts from Facebook.

A Facebook press release stating that Internet.org moves half of those who come online through Internet.org go on to become paying subscribers within 30 days.

An article that says free access to just Facebook alone led to more data subscribers in the Philippines.

An ex general counsel for Wikimedia shares his thoughts on Wikipedia Zero and zero-rating (he's for it).