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date: 2017-12-29T15:32:58+00:00
title: Contributions to ARCEP work on terminal devices and public consultation
authors: Paul Kocialkowski
tags: Institutional, Paul Kocialkowski
---
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>
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