Our support of net neutrality is grounded in our belief that we all must fight to maintain an open, global, and growing Internet. Because of the scale and potential of the Internet, it must be an international effort. We see a growing focus on net neutrality around the world and believe that this focus is positive and necessary for the continued health of this valuable global asset.

In India, for example, the focus on net neutrality and the impacts of zero-rating have reached an important inflection point. This week, we sent a letter to the Prime Minister of India supporting net neutrality, in response to an open consultation by the Telecom Regulatory Authority of India on Internet services. The Indian Internet community, including many Mozillians, has spoken out expressing concerns with zero-rating and its impacts on an open Internet. Not surprisingly, we too are concerned, and Mozilla’s Executive Chairwoman Mitchell Baker posted to her blog to identify what those concerns are. The bottom line is that zero-rating may actually NOT connect the world’s unconnected billions to the Internet, in India or elsewhere.

Zero-rating does not at first pass invoke the prototypical net neutrality harms of throttling, blocking, or paid prioritization, all of which involve technical differentiation in traffic management. Instead, zero-rating makes some Internet content and services “free” by excluding them from data caps that apply to other uses of traffic (which can result in “blocking” of sorts if a user has no available data left in a billing period).

The impact of zero-rating may result in the same harms as throttling, blocking, or paid prioritization. By giving one company (or a handful) the ability to reach users at no cost to them, zero-rating could limit rather than expand a user’s access to the Internet and ultimately chill competition and innovation. The promise of the Internet as a driver of innovation is that anyone can make anything and share it with anyone. Without a level playing field, the world won’t benefit from the next Facebook, Google or Twitter.

There are many things we still don’t know about zero-rating. It’s a relatively new business model and there is not a lot of data about its benefits or its harms, so we don’t know with certainty what the long-term effects will be. We don’t have data on substitutability – how many users will reduce or even stop their open Internet use because they have to pay, while walled garden offerings are free to them. But we do have data indicating that a significant percentage of people confuse “the Internet” and “Facebook,” – in part because of Facebook’s Internet.org initiative – notably including a global survey by Quartz where over half of respondents agreed with a statement equating Facebook with the entire Internet.

There’s also missing data on the other side of the equation. There may be markets where affordability hurdles to access remain so significant that mobile networks can’t reach economies of scale to keep prices down. It may be possible that access to zero- rated services will help to give previously unconnected users a “taste” of the Internet leading them to demand access to the open Internet itself. The truth is we don’t know.

Still, prohibition through legislation or regulation, a path some governments have taken or are considering, may not be the right answer. Taken to an extreme regulation could chill some innovation and could result in industry not taking collective action. Even worse, regulation could allow governments to determine which content could/should be zero-rated – and the benefit of net neutrality is that no entity should get to decide which content a user has access to. Different markets and political environments require individual analysis. In some contexts, such as Netflix’s abandoned zero-rating plans in Australia, resolution may occur as a result of public pressure, without formal action.

We understand the temptation to say “some content is better than no content,” choosing a lesser degree of inclusion over openness and equality of opportunity. But it shouldn’t be a binary choice; technology and innovation can create a better way, even though these new models may take some time to develop. Furthermore, choosing limited inclusion today, even though it offers short-term benefits, poses significant risk to the emergence of an open, competitive platform that will ultimately stifle inclusion and economic development.

There are alternative approaches that could serve as solutions to the challenges that zero-rating seeks to address. For example, Mozilla has sought to create such an alternative within the Firefox OS ecosystem. Our partnership with Grameenphone (owned by Telenor Group) in Bangladesh allows users to receive 20 MB of data usage for free each day, in exchange for viewing an advertisement. Our partnership with Orange will allow residents of multiple African countries to purchase $40 Firefox OS smartphones that come packaged with 6 free months of voice, text, and up to 500 MB per month of data. Scaling up arrangements like these could represent a long-term solution to the key underlying problems of digital inclusion and equality.

Likely, the solution will be found in some combination of: new approaches and business models; potential increases in philanthropic engagement as Mitchell’s post suggests; and technology and business innovations to reduce the costs of connectivity. But whatever the mix is, preserving the level playing field that drives innovation and competition on the Internet must be the baseline.

We’ve tried to outline here some of the positive and negative issues associated with zero-rating. More education about these issues, and affordability and accessibility challenges, will be part of working out the right solutions. Multi-stakeholder roundtables and incubation challenges around alternative solutions to affordability problems are also likely fruitful pathways. Or maybe solutions will come from academia and think tanks, through research driven white papers. Mozilla will be exploring these options further in the months to come.

We look forward to working with the Mozilla community, others in industry, civil society, governments and other actors to think through how best to provide everyone with access to the full diversity of the open Web. We hope you’ll join us in these conversations.

Denelle Dixon-Thayer, SVP, Business and Legal Affairs

Chris Riley, Head of Public Policy

Jochai Ben-Avie, Internet Policy Manager