I have been somewhat aware of the Alliance for an Affordable Internet (A4AI) since it’s much hyped beginnings in 2013 I didn’t pay a lot of attention given its sponsorship by USAID and a passel of corporates and NGO’s who regularly lend their names to a variety of do-gooding Internet initiatives around the Internet which never seem to go anywhere beyond launches and photo ops, and as well recognizing that improving “Internet Access” is a bit of a flavour of the day for various “benevolent” parties.
I must say that I read A4AI’s recent annual (Affordability) report and then their earlier reports and the associated discussion with a rising sense of astonishment and unease. The reports were interesting in their extended discussion on the attributes, indicators, barriers and policy responses to a lack of “affordable Internet access”. But as I was digging through the A4AI documentation I was struck by the fact that the overall initiative didn’t seem to be about obtaining “affordable access”, rather the emphasis seemed to be about influencing the Internet policy of Less Developed Countries (LDC’s).
Of course, there is a strong connection between the public policy issues and a desired outcome such as “affordable Internet access”, but if one’s real objective is affordable access surely there are other routes that one can follow apart from influencing public policy—as for example, influencing the pricing policies of those private sector companies which are the ultimate providers of Internet access in virtually all instances.; and more significantly there are other public policy routes to achieving broad-based Internet access apart from the one which those looking to participate in the initiative are required to accept.
The true direction for this initiative became strikingly clear when I came across the “A4AI Policy and Regulatory Best Practices” described as follows:
… A4AI has produced an outline of policy and regulatory best practices demonstrated to drive down the cost of Internet access. All of our members endorse these practices, and they form the backbone of our advocacy work.
with the following “guiding principles” on which I have provided some commentary:
• Internet freedom and the fundamental rights of expression, assembly, and association online must be protected
This of course is a quite fundamental requirement for democracy and civic life and it would be churlish to argue against this except. However, it is nowhere indicated why, given that we are here concerned with “affordable Internet access” this should be at the top of the list of policy principles. Certainly these are important as the US State Department, Google and all associated are at pains to repeatedly point out through their various “Internet Freedom” campaigns, but precisely what this principle has to do with achieving “affordable” Internet access rather escapes me. That these “rights” are completely consistent with the US’ Intellectual Property rights regime and other of US commercial interests in the Internet sphere is of course purely coincidental.
• Access to the Internet is a significant enabler of economic growth and human development
Again hard to disagree with this although presented in this way one would feel rather more comfortable if there were some references included indicating precisely what type of economic growth and human development is being pointed to. A case could be made that the manner in which the Internet has been implemented (and presumably the manner in which A4AI is promoting that it be implemented in the future) has rather enabled significant “economic growth” for the few and contributed significantly to the rapidly growing patterns of economic inequality both within and between countries. Equally with “human development”, where arguably the prime beneficiaries of the Internet have been those who already have the skills and human capacities which support success – literacy, numeracy, interpersonal fluency. While there may be ways (and examples) of the Internet contributing to more broadly based human development this most certainly cannot be taken as a given.
• Open and competitive markets are the most effective way to drive reduced delivery costs, affordable consumer pricing, and new innovations
Hmmm… this statement for market fundamentalism is straight out of the now somewhat shop worn neo-liberal ideological playbook … whether it is true or not that “Open and competitive markets are the most effective way to drive reduced delivery costs, affordable consumer pricing, and new innovations” is of course another question. However, it is presented as an unalterable statement of fact without argument or example. Of course it may be true, but an increasingly questionable artifact of the rapidly crumbling Washington Consensus is hardly something upon which one would want to launch a global movement for Internet Access without research, analysis or argument unless one had policy (and ideological) goals rather broader than those immediately apparent.
The document then goes into detail concerning the policy and regulatory recommendations that follow from these principles. It is worth looking in some detail at these as well, as this will ensure that the real significance of the A4AI initiative becomes blindingly clear.
But first let me toss out a principle of my own. The Internet is becoming the platform underlying all aspects of modern life—economic, social, political. The rules that govern how the Internet operates – how and under what conditions it is implemented, how is managed, how it is regulated; ultimately become the fundamental rules of governance—the regulatory and management framework of modern life—economic, social and ultimately political.
Thus the rules and policies which structure and determine how the Internet is to be made available to the 60% of humanity who do not as yet have access will be a determining element in how they (and we) are governed, managed and regulated into the future. The A4AI “Best Practices” are a clear attempt to superimpose a neo-liberal market fundamentalism on what would otherwise be a well-meaning attempt to reduce the cost of Internet access for the next billions of users.
Below I will review in detail certain of the proposed “Best Practices”.
1. LIBERALIZED MARKET WITH AN OPEN, COMPETITIVE ENVIRONMENT
A. Nurture healthy market competition
• Streamlined licensing process with no legal barriers to market entry
This seems on the face of it non–controversial but what is the link between this and an “Affordable Internet”. The connection would appear to be that the only means to an affordable internet is through pure market competitiveness but as noted above this is taken as a statement of principle not as something for empirical assessment and analysis. So in order to achieve pure market competitiveness any and all possible barriers to this competitiveness must be removed meanwhile there may be multiple reasons why a country might want to restrict entry to the Internet marketplace for, for example foreign service providers, service providers with a history of exploitative behaviour, or service providers who are unwilling to enter into certain service covenants (as for example to provide low cost service in unprofitable areas).
• Ensure a competitive market structure, with limited or no national government ownership of end user service providers
This market fundamentalism is discredited even in the US where the service providers have been attempting to ensure that municipal governments would be forbidden from providing Internet service even when such could be provided at equal quality and at a cheaper price. Equally it would restrict governments from providing service in rural and remote areas where private sector providers would be very unlikely to go because of the lack of opportunity to obtain a profit.
B. Regulator established as an effective and independent expert agency
• Effective regulation of anti-competitive behavior when necessary
It is not clear why the regulatory authority and regulation should only be concerned with “anti-competitive” behaviour. There is a wide range of other behaviours which one would want the regulator to be concerned with as for example support for Human Rights, ensuring social equity of access, non-discrimination among end users, and so on. To restrict regulation solely to managing competition is again to force the compliant governments into the maelstrom of neo-liberal economic fundamentalism.
• Advocate for consumer interests including both immediate service and sustainability
As above regulators need to be concerned not simply with end users as “consumers” but also as social and economic actors where there is a significant possibility of discrimination or inequality as between these in the context of Internet provision and regulation. The overall role of the regulator is to act in the broad public interest which of course goes beyond simply upholding the interests of end users as consumers.
C. Promote evidence-based policymaking and regulatory processes that include meaningful public participation
Evidence based policy including meaningful public participation is of course a desirable path to take. The difficulty is in determining the underlying principles or questions which the policy and regulatory process is to represent. If, they are as indicated above, solely determined by a neo-liberal fixation on unmanaged competition and an elimination of the social support and intervention role of the state then the outcomes of such a process will be highly pre-determined and will inevitably support the input principles. The over-arching principle for policy making and regulation has to be the broadest public interest as manifest in democratic processes.
2. POLICIES AND PRACTICES TO ENCOURAGE LOWER COST STRUCTURE FOR INDUSTRY
A. Streamlined processes for infrastructure deployment and sharing
• Target public infrastructure investment to market failures, through consultation with market players and other stakeholders. Ensure that subsidized infrastructure is competitively and transparently procured and offers access or capacity to all market players in a non-discriminatory way, so as to achieve end user affordability.
Why should public infrastructure only be concerned with “market failures”. There a number of public policy concerns in support of the public interest where public infrastructure could and should be publicly owned as for example to ensure broad based and universal access including in remote and rural regions or where it is evident that privately owned infrastructure will operate as a monopoly or oligopoly against the public interest. As well the issue of access to public infrastructure may be determined by other public interest concerns in addition to “end user affordability although of course this should remain a criteria.
E. Effective Universal Service Fund (USF) administration (if a USF exists)
• Non-discrimination (fair collection and distribution of funds, including non-carriers)
Now we are getting to the bottom line of the motivation for many of those involved to participate in this initiative. Many Developing Countries, having, at the insistence of the World Bank, and following the cookie cutter formulations and legislation of the WB’s hired legal mercenaries created Universal Service Funds designed so as to ensure that they would continue to be under the control of the private service providers. Many of these funds having been designed to the WB’s specifications are very poorly adapted to local conditions and have remained largely unspent and now are extremely large—in some cases representing several hundreds of millions or even billions of dollars. Clearly the private sector sponsors of the A4AI initiative and their Developed Country and NGO enablers want to get unrestricted access to those funds to support their local initiatives, in this case under the guise of ensuring ”affordable access”…or in the words of the proposed policy “best practice”—“non-discrimination… (in the) distribution of funds including non-carriers” (the latter clause presumably because so many of the private sector A4AI sponsors are hardware and even content suppliers rather than carriers.
• Transparent and consultative processes, incorporating stakeholder inputs and priorities
While “transparent and consultative processes” are certainly desirable and would be strengthened by stakeholder inputs it isn’t clear why stakeholder “priorities” should prevail or take priority over public policy concerns and processes which are meant to protect and promote the public interest rather than the sectional self-interest of “stakeholders”.
• Clear target goals and monitoring of effectiveness and impact of USF programs and projects
Again “clear target goals and monitoring” are desirable even necessary processes but it is important that the target goals and criteria for monitoring and determining effectiveness and impact of USF programs are specified and determined as supportive of the broad public interest rather than the private for profit interests of the private sector stakeholders.
• Prioritize one-time infrastructure and other expenditures to enable access
While expenditures in support of infrastructure (from Universal Service Funds) as earlier noted are certainly desirable no evidence is presented or arguments made why infrastructure expenditures should be prioritized over for example content creation, development of content in local languages, service development or development of local management capacity for the use of USF’s. That those who benefit directly or indirectly from infrastructure investment are co-sponsors of the initiative perhaps explains this priority but why it should be acceded to by those with presumably less-self-interested perspectives in unexplained.
• Target any ongoing subsidies to individuals rather than providers
The significance of this “best practice” is slightly less obvious. What seems to be promoted here is subsidy support for consumers who presumably would then have an opportunity to provide that subsidy to private sector suppliers through their purchases. However, a policy such as this would deny governments one of the major tools (and funding) which they could have available to intervene to ensure that the public interest is being served as for example ensuring service in rural and remote areas, providing service to the urban poor through public access facilities and so on. This transformation of the public interest in Internet access into private individual interests is a deeply insidious way of preventing the actions of the state to operate in the public interest to ensure and enable broad-based Internet access.
Providing Internet access at an affordable price is a desirable goal. Whether that goal should be the number one funding and policy priority of Less Developed Countries as is being so actively promoted by A4AI is not clear. Nor where it should rest within the array of other possible priorities such as ensuring that the Internet is usable and meaningful to current non-users with applications that contribute to overall individual and family well-being are equally on offer is not clear.
What is clear however, is that there is very considerable Developed Country and private sector as well as NGO pressure being applied to ensure that this is the top priority.
When we look even slightly below the surface of this initiative we see what appear to be motivations that are rather less selfless than is being presented. As is very clear from the “Best Practices” which those joining the initiative must sign on to, an underlying motivation would appear to be to impose on LDC’s an ideological position for its Internet policy and regulation which conforms to and supports the fundamentalist free market anti-regulatory regime promoted by the USG and certain of its governmental and corporate allies .
In parallel with this is the clear attempt at a significant financial resource grab by a variety of (mostly US based) Internet hardware and software suppliers to gain access via this initiative to the significant pools of funds available in many LDC’s through their Universal Service Funds—these funds having been identified and secured to support the needs of under-served populations in these countries.
I must say what I find most disappointing and saddening in all of this is the range of civil society organizations who have signed on to the A4AI. The conclusion one must draw is that either these organizations have decided to fully endorse the neo-liberal ideological approach to Internet governance in LDC’s or they have agreed to participation without looking in any detail at the “fine print”. One sincerely hopes that it is the latter and that these organizations will reconsider their participation in this enterprise and reconnect with their traditional roots as advocates for social equity and social justice.