Hm weird. I would have expected at least a rw open on the block device should 
fail, let alone a ro (since fsck probably wants to modify the fs). Though I'd 
need to check exactly what access mode mount -oro uses (maybe its some ro 
exclusive). Actually it is not really a read-only open on the block device 
(that much I know) because this still will cause changes to the superblock 
(mount time and so on) if that is possible and the block device itself is not 
read-only.
Beside that you could restrict the devices touched by looking at 
/sys/block/?/device/type which is 5 (cdrom) only for cd type devices.
The other option would be, if there is an event that mountall emits as the 
final one (done with automounting), that would be a safer time to start with 
the cloud-init, wouldn't it?

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https://bugs.launchpad.net/bugs/898373

Title:
  fsck.ext3: Device or resource busy while trying to open /dev/xvda2

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