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+tags: Institutional, Paul Kocialkowski
+date: 2017-12-29 16:32
+title: Contributions to ARCEP work on terminal devices and public consultation
+---
+While Replicant is mainly backed by Wolfgang in terms of technical
+contributions nowadays, Denis and Paul are still active in the project, in
+other ways.
+
+Over the past few months, we have been working with [ARCEP][1], the
+independent French governmental agency in charge of regulating
+telecommunications. The agency is working on evaluating [the influence of
+terminal devices in achieving an open Internet][2], with a particular focus on
+mobile device. A [first report][3] on this topic was issued at the end of may
+2017, based on consultations with various members of the industry as well as
+non-profits such as [FFDN][4], the federation of non-profit ISPs. This first
+document presents ARCEP’s approach to the application of [EU regulation
+2015/2120][5], that gives users specific rights regarding their choice of
+terminal devices. It provides an analysis of the various actors involved with
+terminal devices, making clear distinctions between the hardware, operating
+system, applications and services.
+
+The EU regulation is however less specific and the articles related to
+terminals can be interpreted with different scopes:
+
+> When accessing the internet, end-users should be free to choose between
+> various types of terminal equipment […].
+
+> End-users shall have the right to access and distribute information and
+> content, use and provide applications and services, and use terminal
+> equipment of their choice […].
+
+A narrow understanding would associate the choice of the terminal witch
+choices made available from the industry, while a broader understanding, that
+ARCEP is pursuing, also takes in account all the actors involved at every
+level, including actors from the free software community such as Replicant.
+This lead the authority to get in touch with us, after members of FFDN kindly
+put-in a word of recommendation for Replicant.
+
+We attended an initial meeting in Paris in September, where we explained our
+action at Replicant, the problems we are facing and key elements to shape
+their understanding. We mentioned that not only the operating system should be
+considered separately in terms of choice, but also other software components
+such as the boot software, the privileged execution environment and the modem
+system, that are also crucial parts of a terminal device that can (and often
+do) restrict the user.
+
+In November, we attended a workshop with members of the industry, that
+included Microsoft and Qualcomm among others. We took the occasion to directly
+question them regarding deliberate choices that are detrimental to users in
+terms of freedom. It seemed agreed and understood that the ability to load an
+alternative operating system is a necessity for users and that mistakes were
+made in the past in that area. However, many of the perspectives presented by
+the industry were not satisfactory in terms of freedom and privacy/security
+for end users, especially when it comes to IoT and ISP-provided routers that
+keep embedding more functionalities. We did not always get answers to our
+questions, as the representatives that were sitting at the table did not share
+our technical background and thus sometimes did not fully grasp the reality of
+the situations at hand.
+
+ARCEP is now organizing a [public consultation][6] on the influence of
+terminal devices on an open Internet, that is presented in a [dedicated
+document][7]. Anyone is welcome to submit a contribution, to share their
+understanding of what the free choice of terminal devices should entail,
+either in French or in English. This is an opportunity to send a strong
+message in favor of free software at all the levels involved in mobile
+devices: boot software, privileged execution environment (often called
+TrustZone), operating system, applications and modem system. ARCEP is now
+organizing a [public consultation][6] on the influence of terminal devices on
+an open Internet, that is presented in a [dedicated document][7]. Anyone is
+welcome to submit a contribution, to share their understanding of what the
+free choice of terminal devices should entail, either in French or in English.
+This is an opportunity to send a strong message in favor of free software at
+all the levels involved in mobile devices: boot software, privileged execution
+environment (often called TrustZone), operating system, applications and modem
+system. Replicant will also submit a contribution in this direction, that will
+be published on the Replicant blog soon.
+
+The consultation is open until the **10th of January 2018** and submissions
+can be sent to: [terminaux@arcep.fr][8].
+
+ [1]: <https://www.arcep.fr/?L=1>
+
+ [2]: <https://www.arcep.fr/?id=13713&L=1>
+
+ [3]: <https://www.arcep.fr/uploads/tx_gspublication/study-end-user-devices-
+internet-openness-may2017.pdf>
+
+ [4]: <https://www.ffdn.org/>
+
+ [5]: <http://eur-lex.europa.eu/eli/reg/2015/2120/oj>
+
+ [6]: <https://www.arcep.fr/index.php?id=13142&L=1>
+
+ [7]: <https://www.arcep.fr/uploads/tx_gspublication/consult-terminaux-
+internet-ouvert-dec2017-ENG.pdf>
+
+ [8]: <mailto:terminaux@arcep.fr>
+
+