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ISP Dual Queue Networking Deployment Recommendations
draft-livingood-low-latency-deployment-09

Document Type Active Internet-Draft (individual)
Author Jason Livingood
Last updated 2025-04-25 (Latest revision 2025-04-24)
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draft-livingood-low-latency-deployment-09
Independent Stream                                          J. Livingood
Internet-Draft                                                   Comcast
Intended status: Informational                             24 April 2025
Expires: 26 October 2025

          ISP Dual Queue Networking Deployment Recommendations
               draft-livingood-low-latency-deployment-09

Abstract

   The IETF's Transport and Services Working Group (TSVWG) has finalized
   experimental RFCs for Low Latency, Low Loss, Scalable Throughput
   (L4S) and new Non-Queue-Building (NQB) per hop behavior.  These
   documents describe a new architecture and protocol for deploying low
   latency networking.  Since deployment decisions are left to
   implementers, this document explores the potential implications of
   those decisions and makes recommendations that can help drive
   adoption and acceptance of L4S and NQB.

Status of This Memo

   This Internet-Draft is submitted in full conformance with the
   provisions of BCP 78 and BCP 79.

   Internet-Drafts are working documents of the Internet Engineering
   Task Force (IETF).  Note that other groups may also distribute
   working documents as Internet-Drafts.  The list of current Internet-
   Drafts is at https://datatracker.ietf.org/drafts/current/.

   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
   time.  It is inappropriate to use Internet-Drafts as reference
   material or to cite them other than as "work in progress."

   This Internet-Draft will expire on 26 October 2025.

Copyright Notice

   Copyright (c) 2025 IETF Trust and the persons identified as the
   document authors.  All rights reserved.

   This document is subject to BCP 78 and the IETF Trust's Legal
   Provisions Relating to IETF Documents (https://trustee.ietf.org/
   license-info) in effect on the date of publication of this document.
   Please review these documents carefully, as they describe your rights
   and restrictions with respect to this document.

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Table of Contents

   1.  Introduction  . . . . . . . . . . . . . . . . . . . . . . . .   2
     1.1.  A Different Understanding of Application Needs  . . . . .   3
     1.2.  New Thinking on Low Latency Packet Processing . . . . . .   4
   2.  Key Low Latency Networking Concepts . . . . . . . . . . . . .   4
     2.1.  Best Effort Priority  . . . . . . . . . . . . . . . . . .   4
     2.2.  Shared Throughput . . . . . . . . . . . . . . . . . . . .   5
     2.3.  Access-Agnostic . . . . . . . . . . . . . . . . . . . . .   5
   3.  Application Developer Recommendations . . . . . . . . . . . .   5
     3.1.  Delivery Infrastructure for L4S . . . . . . . . . . . . .   5
     3.2.  Delivery Infrastructure for NQB . . . . . . . . . . . . .   6
     3.3.  Only Mark Delay-Sensitive Traffic for L4S or NQB  . . . .   6
     3.4.  Consider Application Needs in Choosing L4S vs. NQB  . . .   6
   4.  ISP Recommendations . . . . . . . . . . . . . . . . . . . . .   6
     4.1.  Allow ECN Across Network Boundaries . . . . . . . . . . .   7
     4.2.  Allow DSCP-45 Across Network Boundaries . . . . . . . . .   7
     4.3.  Last Mile Network (Access Network)  . . . . . . . . . . .   7
     4.4.  Customer Premise Equipment (Customer Edge)  . . . . . . .   8
     4.5.  Inside the Home - Customer Local Area Network (LAN) . . .   8
       4.5.1.  802.11 WiFi Queuing . . . . . . . . . . . . . . . . .   8
       4.5.2.  Use Permissive Upstream NQB Queue Admission . . . . .   9
     4.6.  Do Not Use Middleboxes  . . . . . . . . . . . . . . . . .   9
   5.  Acknowledgements  . . . . . . . . . . . . . . . . . . . . . .  11
   6.  IANA Considerations . . . . . . . . . . . . . . . . . . . . .  11
   7.  Security Considerations . . . . . . . . . . . . . . . . . . .  11
   8.  Network Neutrality Considerations . . . . . . . . . . . . . .  11
   9.  Revision History  . . . . . . . . . . . . . . . . . . . . . .  12
   10. Open Issues . . . . . . . . . . . . . . . . . . . . . . . . .  12
   11. Informative References  . . . . . . . . . . . . . . . . . . .  13
   Author's Address  . . . . . . . . . . . . . . . . . . . . . . . .  16

1.  Introduction

   The IETF's Transport and Services Working Group (TSVWG) has finalized
   RFCs for Low Latency, Low Loss, Scalable Throughput (L4S) and Non-
   Queue-Building (NQB) per hop behavior [RFC9330] [RFC9331] [RFC9332]
   [RFC9435] [I-D.ietf-tsvwg-l4sops] [I-D.ietf-tsvwg-nqb].  These
   documents do a good job of describing a new architecture and protocol
   for deploying low latency networking.  But as is normal for many such
   standards, especially new or experimental ones, certain deployment
   decisions are ultimately left to implementers.

   This document explores the potential implications of key deployment
   decisions and makes recommendations for those decisions that may help
   drive adoption by network operators and application developers.  That
   is a key issue for low latency networking, because the more
   applications developers and edge platforms that adopt new packet

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   marking for low latency traffic, then the greater the value to end
   users, so ensuring it is received well is key to driving strong
   initial adoption.

   It is worth stating though that these decisions are not embedded in
   or inherent to L4S and NQB per se, but are decisions that can change
   depending upon differing technical, regulatory, business or other
   requirements.  Even two network operators with the same type of
   access technology and in the same market area may choose to implement
   in different ways.  Nevertheless, this document suggests that certain
   specific deployment decisions can help maximize the value of low
   latency networking to end users, network operators, and application
   developers.

   In addition, the design of the protocols also make clear that
   applications developers are best positioned to understand the needs
   of their applications and to, by extension, express any such low
   latency needs via appropriate L4S or NQB packet marking.

   For additional background on latency and why latency matters to the
   Internet, please read [BITAG].

1.1.  A Different Understanding of Application Needs

   In the course of working to improve the responsiveness of network
   protocols, the IETF concluded with their L4S and NQB work that there
   were two main types of traffic and that these two traffic types could
   benefit from having separate network processing queues in order to
   improve the way the performance of delay-sensitive and/or interactive
   applications.  In addition, introducing a new queue better supports
   incremental development of a new standard rather than changing
   existing congestion control algorithms - which would be complex.

   One of the two major traffic types is mostly file download or upload,
   such as downloading an operating system update or uploading files to
   a cloud backup.  This type of traffic tends not to be particularly
   delay-sensitive, at least on a millisecond level basis.  The other
   type of traffic is real-time, interactive traffic that is typically
   latency-sensitive, such as video conferencing and gaming.

   The value of dual queue networking (simply "low latency networking"
   hereafter) seems potentially good, and at least one major ISP has
   deployed it [Comcast].  It seems possible that this new capability
   might enable entirely new classes of applications to become possible,
   driving a wave of new Internet innovation, while also improving the
   latency-sensitive applications that people use today.

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1.2.  New Thinking on Low Latency Packet Processing

   L4S does *not* provide low latency in the same way as previous
   technologies like DiffServ Quality of Service (QoS).  That prior QoS
   approach used packet prioritization, where it was possible to assign
   a higher relative priority to certain application traffic, such as
   Voice over IP (VoIP) telephony.  This approach could provide
   consistent and relatively low latency by assigning high priority to a
   partition of the capacity of a link, and then policing the rate of
   packets using that partition.  This traditional approach to QoS is
   hierarchical in nature.

   That QoS approach is to some extent predicated on the idea that
   network capacity is very limited and that links are often highly
   utilized.  But on today's Internet, many users have experienced poor
   application performance, such as video conferencing, despite having
   sufficient bandwidth.  In many of these scenarios, prioritization
   will not improve a flow.  But finding a way to reduce latency has
   proven beneficial.  This new low latency networking approach is not
   based on hierarchical QoS prioritization.  Rather, it is built upon
   conditional priority scheduling between two queues that operate at
   best effort QoS priority.

2.  Key Low Latency Networking Concepts

   In the past, many thought that the only way to improve application
   quality was via more bandwidth or by using QoS priority.  The advent
   of low latency networking enables a re-examination of those
   approaches.

2.1.  Best Effort Priority

   Low latency traffic to is not prioritized over other (best effort
   priority) "classic" Internet traffic.  That is the case over the ISP
   network and the broader internet, though it may not not necessarily
   be the case for a user's in-home Wi-Fi network due to the particulars
   of how the IEEE 802.11 wireless protocol [IEEE] functions at the
   current time - see [RFC8325]).  In addition, some user access points
   may prioritize certain traffic (such as gaming) and some traffic such
   as NQB may use the AC_VI Wi-Fi link layer queue [I-D.ietf-tsvwg-nqb].
   This best effort approach stands in contrast to prior differential
   quality of service (QoS) approaches or to what has been discussed for
   5G network slicing [CDT-NN] [van-Schewick-1A] [van-Schewick-1B]
   [van-Schewick-2] [van-Schewick-3].

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2.2.  Shared Throughput

   Low latency networking flows do not get access to greater throughput
   than "classic" flows.  Thus, a user's total provisioned or permitted
   throughput on an ISP access network link is shared between both
   classic and low latency queues.

2.3.  Access-Agnostic

   Low latency networking can be implemented in a variety of network
   technologies.  For example in access network technologies this could
   be implemented in DOCSIS [LLD], 5G [Ericsson], PON [CTI], and many
   other types of networks.

3.  Application Developer Recommendations

   Application developers need to add L4S or NQB packet marking to their
   application, which will often depend upon the capabilities of a
   device's operation system (OS) or a software development kit (SDK)
   [Apple] that the OS developer makes available.  In addition, the
   application server will also need to support the appropriate marking
   and, when L4S is used, to implement a responsive congestion
   controller.

3.1.  Delivery Infrastructure for L4S

   Since L4S uses the Explicit Congestion Notification (ECN) field of
   the packet header, to ensure ECN works end-to-end, application
   developers need to be certain that their servers, datacenter routers,
   and any transit, cloud provider, or content delivery network (CDN)
   server involved in their application IS NOT altering or bleaching the
   ECN field.  For an application to use the L4S queue, they must mark
   their packets with the ECT(1) code point to signal L4S-capability or
   with the Congestion Experienced (CE) code point when appropriate.
   Coupled with client marking, if an application client or server
   detects CE marks, it should respond accordingly (e.g., by reducing
   the send rate), which typically means that the server must be running
   a "responsive" congestion controller (i.e., is able to adjust rate
   based the presence or absence of CE marks for L4S traffic - such as
   DCTCP, TCP Prague, SCReAM, and BBRv2).  See Section 4.3 of [RFC9330]
   and Section 4.3 of [RFC9331] for more information about this.

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3.2.  Delivery Infrastructure for NQB

   Since NQB uses the DSCP-45 code point in the DiffServ part of the
   packet header, to ensure NQB works end-to-end, application developers
   need to be certain that their servers, datacenter routers, and any
   transit, cloud provider, or content delivery network (CDN) server
   involved in their application IS NOT altering or bleaching a DSCP-45
   mark.  The server DOES NOT need to run a special responsive
   congestion controller.  However, it is common for networks to bleach
   or modify DSCP marks on ingress today, so networks will need to
   change that policy for NQB to work end-to-end (in contrast, ECN is
   rarely bleached).

3.3.  Only Mark Delay-Sensitive Traffic for L4S or NQB

   It may seem tempting to mark all traffic for L4S or NQB handling, but
   it may not help in all cases.  For example, a video gaming service
   may benefit from using L4S or NQB for real-time controller inputs and
   gameplay, while major game software updates would best be left in the
   classic queue.

3.4.  Consider Application Needs in Choosing L4S vs. NQB

   Determine whether your application needs "sparse" flows or
   "congestion-controlled" (higher capacity) flows.  Sparse flows that
   are latency senstive should be marked as NQB (thus DSCP-45).  This
   may be things like DNS queries or VoIP media flows, where maximizing
   the bandwidth of the flow is not necesary.

   Latency-sensitive flows that need more bandwidth are congestion
   controlled, and identified via ECN marking.  These types of
   applications are less limited by the application protocol itself
   (i.e., a small DNS query), which means the application quality can
   improve as more bandwidth is available - such as shifting a video
   stream or a video conference session from Standard Definition (SD) to
   4K quality.

4.  ISP Recommendations

   Like any network or system, good deployment design decisions matter.
   In the context of deploying low latency networking in an ISP network,
   these recommendations should help ensure that a deployment is
   resilient, well-accepted, and creates the environment for generating
   strong network effects.

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4.1.  Allow ECN Across Network Boundaries

   Traffic sent TO a peer network marked with ECT(1) or CE in the ECN
   header MUST pass to that peer without altering or removing the ECT(1)
   or CE marking (see exception below).  Traffic FROM peers marked with
   ECT(1) or CE in the ECN header MUST be allowed to enter the network
   without altering or removing the ECT(1) or CE marking (see exception
   below).  The only exception would be when a network element is CE-
   aware and able to add a CE mark to signal that it is experiencing
   congestion at that hop.

   This part - allowing unmodified ECN across the network - is likely to
   be easier than DSCP-45 for NQB (see next section), since it appears
   rare that networks modify the ECN header of packet flows.

4.2.  Allow DSCP-45 Across Network Boundaries

   Traffic sent TO a peer network marked with DSCP value 45 MUST pass to
   that peer without altering or removing the DSCP 45 marking (see
   exception below).  Traffic FROM peers marked with DSCP value 45 MUST
   be allowed to enter the network without altering or removing the DSCP
   45 marking (see exception below).

   However, some networks may use DSCP 45 for internal purposes other
   than NQB within their network.  In these cases, the peer using DSCP
   45 for other purposes is responsible for remarking as appropriate.
   If possible, for operational simplicity, a network should try to
   maintain the use of DSCP 45 on an end-to-end basis without remarking
   in their interior network hops.

4.3.  Last Mile Network (Access Network)

   There are two hops of interest in the last mile access network.  One
   will be a point of user aggregation, such as a Cable Modem
   Termination System (CMTS) or Optical Line Terminal (OLT).  The second
   is at the user location, such as a Cable Modem (CM) or Optical
   Network Unit (ONU), both of which are example of CPE.

   In theses two queues, ISPs should consider using the optional Queue
   Protection function [I-D.ietf-tsvwg-nqb]
   [I-D.briscoe-docsis-q-protection].  This can potentially detect
   mismarking and take corrective action as needed.

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4.4.  Customer Premise Equipment (Customer Edge)

   In most residential Internet services, there are typically two
   equipment modes.  One is very simple CPE that hands off from the
   ISP's access network (i.e., DSL, 5G, DOCSIS, PON) and provides the
   customer with an Ethernet interface and IP address(es).  The customer
   then connects their own router and wireless access point (often
   integrated into the router, typically referred to as a "wireless
   gateway" or "wireless router").  The other model is more typical,
   which is that the CPE integrates a link layer termination function
   (i.e., Cable Modem, 5G radio, or Optical Network Unit) as well as a
   wireless gateway.

   Not all ISP networks support both of these models; sometimes only a
   wireless gateway is available.  Even in this case, some users "double
   NAT" and install their own router and wireless access point(s) to get
   whatever functionality and control over their home network that they
   desire.  The cases explored below are commonplace but may not apply
   to all networks.

   In some cases, dual queue networking and associated packet marking is
   supported up to the ISP's demarcation point - such as in a cable
   modem.  It is recommended that packet markings should pass from such
   a demarcation point to any attached customer-administered CPE, such
   as a router or wireless access point.  That enables a customer-
   administered router to implement dual queue networking, rather that
   it only being possible with ISP-administered CPE.

4.5.  Inside the Home - Customer Local Area Network (LAN)

   As noted above with the mention of an integrated wireless gateway,
   the CPE and router/wireless network gear is integrated into a single
   CPE device.  Even though these are functionally in one piece of
   hardware, we can think of the wide area network interface and local
   area network as functionally separate for purposes of this analysis.

4.5.1.  802.11 WiFi Queuing

   As noted above with respect to prioritization of packets in the ISP
   network, all packets should be handled with the same best effort
   priority in the ISP access network and on the internet.  However, in
   a user's home Wi-Fi (wireless) local area network (WLAN), this is
   more complicated, because there is not a precise mapping between IETF
   packet marking and IEEE 802.11 marking, explored in [RFC8325].  In
   short, today's 802.11 specifications enable a Wi-Fi network to have
   multiple queues, using different "User Priority" and "Access
   Category" values.  At the current time, these queues are AC_BK
   (Background), AC_BE (Best Effort), AC_VI (Video), and AC_VO (Voice).

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   As explored in [I-D.ietf-tsvwg-nqb], packets in the low latency queue
   may be expected to be marked for the best effort (AC_BE) or video
   (AC_VI) wireless queue.  For additional context, please refer to
   Section 8.1 of [I-D.ietf-tsvwg-nqb].  In some situations, such as a
   user-owned wireless access point or CPE, it may not be possible for
   the user to select which wireless queue is used.  In cases where the
   CPE is ISP-administered, selecting a specific wireless queue may be
   possible - though it is not yet clear what the best practice may be
   for this selection until ISPs and application developers have more
   experience with low latency networking.  As of the writing of this
   document, it appears that the AC_VI queue may be used for the low
   latency queue in some networks - and that many latency-sensitive
   applications are already marking their upstream wireless traffic for
   AC_VI and AC_VO.

4.5.2.  Use Permissive Upstream NQB Queue Admission

   Since the IETF's NQB specification is only recently completed, many
   applications that have been using other DSCP marks for their latency-
   sensitive flows have not yet shifted to adopt DSCP-45.  One example
   is the Microsoft Xbox platform [Microsoft], which is using DSCP-46.
   So in the relatively short-term, ISPs may find it beneficial to their
   customers to use a more permissive upstream NQB admission policy,
   allowing DSCP-40, 45, 46, and 56 admission into the low latency
   queue.  It may take a year or more after the NQB DSCP assignment is
   made by IANA for developers to shift to DSCP-45, given other items in
   their development backlog and their software release schedule.

4.6.  Do Not Use Middleboxes

   As noted in [Tussle] there has always been a tension in the end-to-
   end model between how much intelligence and processing takes place
   along the end-to-end path inside of a network and how much takes
   place at the end of the network in servers and/or end user client
   devices and software.  In this new approach to low latency
   networking, entry into a low latency queue depends upon marks in the
   packet header of a particular application flow.  In practice, this
   marking is best left to the application edge of the network, rather
   than it being a function of a so-called middlebox in the ISP network.
   As explored below, this is the most efficient, least prone to mis-
   classification, and is most acceptable from the standpoint of network
   neutrality.

   The best approach is for applications to mark traffic to indicate
   their preference for the low latency queue, not the network making
   such a decision on its own.  This is for several reasons:

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   *  According to the end-to-end principle, this function is best
      delegated to the edge of the network as an architectural best
      practice (the edge being the application in this case).

   *  Application marking maintains the loose coupling between the
      application and network layers, eliminating the need for close
      coordination between networks and application developers.

   *  Application developers know best whether their application is
      compatible with low latency networking and which aspects of their
      traffic flows will or will not benefit.

   *  Only the application (not the network) knows whether a scalable
      congestion control algorithm congestion control is being used on
      the application server.  Thus, only the developer and server
      administrator know if they are correctly responding to Congestion
      Experienced (CE) markings for L4S (see Section 4.1 of [RFC9331]).

   *  Application traffic is almost entirely encrypted, which makes it
      very difficult for networks to accurately determine application
      protocols and to further infer which flows will benefit from low
      latency and which flows may be harmed because they need to build a
      queue.  It is likely that false positives [Lotus] and false
      negatives will occur if network-based inference is used; all of
      which can be avoided simply by relying solely on application
      marking.

   *  The pace of innovation and iteration is necessarily faster-moving
      in the application edge at layer 7, rather than in the network at
      layer 3 (and below) - where there is greater standards stability
      and a lower rate of major changes.  As a result, the application
      layer is best suited to rapid experimentation and iteration.
      Network operators and equipment vendors trying to infer
      application needs will in comparison always be in a reactive mode,
      one step behind changes made in applications.

   *  This avoids issues arising from mis-classification of application
      flows [Lotus].

   *  Any application provider should be able to mark their traffic for
      the low latency queue, with no restrictions other than standards
      compliance or other reasonable and openly documented technical
      guidelines.  This maintains the loose cross-layer coupling that is
      a key tenet of the Internet's architecture by eliminating the need
      for application providers and networks to coordinate and creates
      an environment of so-called "permissionless innovation".

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5.  Acknowledgements

   Thanks to Bob Briscoe, Gorry Fairhust, Mat Ford, Vidhi Goel, Mirja
   Kuhlewind, Eliot Lear, Sebastian Moeller, Sebnem Ozer, Jim Rampley,
   Dan Rice, Greg Skinner, Joe Touch, Greg White, and Yiannis Yiakoumis
   for their review and feedback on this document.

6.  IANA Considerations

   RFC Editor: Please remove this section before publication.

   This memo includes no requests to or actions for IANA.

7.  Security Considerations

   The key security consideration pertains to Queue Protection.  As the
   current time, it is recommended that implementers utilize Queue
   Protection, to ensure that any traffic that is incorrectly marked for
   low latency can be detected and remarked for the classic queue.  The
   necessity of Queue Protection remains something of a debate, with
   some firmly believing it is necessary but others believing that it is
   not needed.  The latter view is that application developers have a
   natural incentive to correctly mark their traffic, because to do
   otherwise would worsen the quality of experience (QoE) for their
   users.  In that line of thinking, if a developer mismarks, they and/
   or their users will notice and they will fix that error.  However, it
   is also conceivable that malicious software could be operating on a
   user's device or home network and that malicious software could try
   to send some much traffic to the low latency queue that the queue or
   both queues become unusable.  This is quite similar to other
   "traditional" denial of servce (DoS) attacks, so it does not
   necessarily seems unique to low latency networking.  But due to the
   possibility of this occuring, and low latency networking being such a
   new approach, it seems prudent to implement Queue Protection.

8.  Network Neutrality Considerations

   Network Neutrality (a.k.a. Net Neutrality) can mean a variety of
   things within a country, as well as between different countries,
   based on different opinions, market structures, business practices,
   laws, and regulations.  Generally speaking, In the context of the
   United States' market, it has come to mean that Internet Service
   Providers (ISPs) should not block, throttle, or deprioritize lawful
   application traffic, and should not engage in paid prioritization,
   among other things.  Net Neutrality concerns can sometimes affect the
   deployment of new technologies by ISPs, so they should carefully
   consider regulatory issues when making deployment decisions.

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   As it is envisioned in the design of the IETF's new low latency
   networking protocols, the addition of a low latency queue at a
   network link is merely a second packet queue and does not mean that
   this queue is hierarchically prioritized or that it has more
   capacity.  As a result, low latency networking appears to pose NO new
   Net Neutrality issues.

   One key aspect of low latencty networking is that it operates, from
   the perspective of an ISP's deployment, is application-agnostic.  The
   ISP creates a second network queue on key network links, but does not
   decide on their own what applications can use this queue.  Rather,
   they add the queue and packet flows are sent to that queue based on
   packet marking set by application developers.  This approach is far
   superior to older approaches, which caused significant Net Neutrality
   risks [Lotus], that used middleboxes to attempt to infer applications
   based on observing packet flows on ISP network links.

9.  Revision History

   RFC Editor: Please remove this section before publication.

   v00: First draft

   v01: Incorporate comments from 1st version after IETF-115

   v02: Incorporate feedback from the TSVWG mailing list

   v03: Final feedback from TSVWG and prep for sending to ISE

   v04: Refresh expiration before major revision

   v05: Changes from Greg Skinner and Eliot Lear

   v06: More changes from Eliot Lear

   v07: More changes from Eliot Lear

   v08: Misc updates from IETF review

   v09: Additional updates during review

10.  Open Issues

   RFC Editor: Please remove this section before publication.

   - Open issues are being tracked in a GitHub repository for this
   document at https://github.com/jlivingood/IETF-L4S-Deployment/issues

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11.  Informative References

   [RFC8325]  Szigeti, T., Henry, J., and F. Baker, "Mapping Diffserv to
              IEEE 802.11", RFC 8325, DOI 10.17487/RFC8325, February
              2018, <https://www.rfc-editor.org/info/rfc8325>.

   [RFC9330]  Briscoe, B., Ed., De Schepper, K., Bagnulo, M., and G.
              White, "Low Latency, Low Loss, and Scalable Throughput
              (L4S) Internet Service: Architecture", RFC 9330,
              DOI 10.17487/RFC9330, January 2023,
              <https://www.rfc-editor.org/info/rfc9330>.

   [RFC9331]  De Schepper, K. and B. Briscoe, Ed., "The Explicit
              Congestion Notification (ECN) Protocol for Low Latency,
              Low Loss, and Scalable Throughput (L4S)", RFC 9331,
              DOI 10.17487/RFC9331, January 2023,
              <https://www.rfc-editor.org/info/rfc9331>.

   [RFC9332]  De Schepper, K., Briscoe, B., Ed., and G. White, "Dual-
              Queue Coupled Active Queue Management (AQM) for Low
              Latency, Low Loss, and Scalable Throughput (L4S)",
              RFC 9332, DOI 10.17487/RFC9332, January 2023,
              <https://www.rfc-editor.org/info/rfc9332>.

   [RFC9435]  Custura, A., Fairhurst, G., and R. Secchi, "Considerations
              for Assigning a New Recommended Differentiated Services
              Code Point (DSCP)", RFC 9435, DOI 10.17487/RFC9435, July
              2023, <https://www.rfc-editor.org/info/rfc9435>.

   [I-D.ietf-tsvwg-l4sops]
              White, G., "Operational Guidance on Coexistence with
              Classic ECN during L4S Deployment", Work in Progress,
              Internet-Draft, draft-ietf-tsvwg-l4sops-07, 17 March 2025,
              <https://datatracker.ietf.org/doc/html/draft-ietf-tsvwg-
              l4sops-07>.

   [I-D.ietf-tsvwg-nqb]
              White, G., Fossati, T., and R. Geib, "A Non-Queue-Building
              Per-Hop Behavior (NQB PHB) for Differentiated Services",
              Work in Progress, Internet-Draft, draft-ietf-tsvwg-nqb-27,
              8 November 2024, <https://datatracker.ietf.org/doc/html/
              draft-ietf-tsvwg-nqb-27>.

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   [I-D.briscoe-docsis-q-protection]
              Briscoe, B. and G. White, "The DOCSIS(r) Queue Protection
              Algorithm to Preserve Low Latency", Work in Progress,
              Internet-Draft, draft-briscoe-docsis-q-protection-07, 23
              November 2023, <https://datatracker.ietf.org/doc/html/
              draft-briscoe-docsis-q-protection-07>.

   [BITAG]    Broadband Internet Technical Advisory Group, "Latency
              Explained", 10 January 2022,
              <https://bitag.org/documents/BITAG_latency_explained.pdf>.

   [Lotus]    Eckerseley, P., von Lohmann, F., and S. Schoen, "Packet
              Forgery By ISPs: A Report on the Comcast Affair", 28
              November 2007, <https://www.eff.org/wp/packet-forgery-
              isps-report-comcast-affair>.

   [IETF-114-Slides]
              White, G., "First L4S Interop Event @ IETF Hackathon", 25
              July 2022,
              <https://datatracker.ietf.org/meeting/114/materials/
              slides-114-tsvwg-update-on-l4s-work-in-ietf-114-hackathon-
              00.pdf>.

   [LLD]      White, G., Sundaresan, K., and B. Briscoe, "Low Latency
              DOCSIS: Technology Overview", February 2019,
              <https://cablela.bs/low-latency-docsis-technology-
              overview-february-2019>.

   [Ericsson] Willars, P., Wittenmark, E., Ronkainen, H., Johansson, I.,
              Strand, J., Ledl, D., and D. Schnieders, "Enabling time-
              critical applications over 5G with rate adaptation", May
              2021, <https://www.ericsson.com/49bc82/assets/local/
              reports-papers/white-papers/26052021-enabling-time-
              critical-applications-over-5g-with-rate-adaptation-
              whitepaper.pdf>.

   [CTI]      International Telecommunications Union - Telecommunication
              Standardization Sector (ITU-T), "Optical line termination
              capabilities for supporting cooperative dynamic bandwidth
              assignment", Series G: Transmission Systems and Media,
              Digital Systems and Networks Supplement 71, April 2021,
              <https://www.itu.int/rec/T-REC-G.Sup71-202104-I>.

   [IEEE]     IEEE Computer Society (IEEE), "Part 11: Wireless LAN
              Medium Access Control (MAC) and Physical Layer (PHY)
              Specifications", DOI 10.1109/IEEESTD.2021.9363693, IEEE
              Standard for Information Technology--Telecommunications
              and Information Exchange between Systems - Local and

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              Metropolitan Area Networks--Specific
              Requirements 802.11-2020, 26 February 2021,
              <https://ieeexplore.ieee.org/document/9363693>.

   [Microsoft]
              Microsoft, "Quality of service (QoS) packet tagging on
              Xbox consoles", 19 August 2022,
              <https://learn.microsoft.com/en-
              us/gaming/gdk/_content/gc/networking/overviews/qos-packet-
              tagging>.

   [Comcast]  Comcast, "Comcast Introduces Nation's First Ultra-Low Lag
              Xfinity Internet Experience with Meta, NVIDIA, and Valve",
              29 January 2025,
              <https://corporate.comcast.com/press/releases/comcast-
              introduces-nations-first-ultra-low-lag-xfinity-internet-
              experience-with-meta-nvidia-and-valve>.

   [CDT-NN]   Doty, N. and M. Knodel, "Slicing the Network: Maintaining
              Neutrality, Protecting Privacy, and Promoting Competition.
              A technical and policy overview with recommendations for
              operators and regulators.", April 2023,
              <https://arxiv.org/pdf/2308.05829>.

   [van-Schewick-1A]
              van Schewick, B., Jordan, S., Open Technology Institute at
              New America, and Public Knowledge, "FCC Ex Parte In the
              matter of Safeguarding and Securing the Open Internet, WC
              Docket No. 23-320", 20 March 2024,
              <https://www.fcc.gov/ecfs/document/103120890811342/1>.

   [van-Schewick-1B]
              van Schewick, B., Jordan, S., Open Technology Institute at
              New America, and Public Knowledge, "Net Neutrality & Non-
              BIAS Data Services", 20 March 2024,
              <https://www.fcc.gov/ecfs/document/10323701322790/2>.

   [van-Schewick-2]
              van Schewick, B., "Net Neutrality & 5G Network Slicing", 3
              April 2024, <https://law.stanford.edu/wp-
              content/uploads/2024/08/van-Schewick-2024-5G-Network-
              Slicing-and-Net-Neutrality-Shetler-Steffen1.pdf>.

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   [van-Schewick-3]
              van Schewick, B., "Network Slicing and Net Neutrality: No
              Throttling Rule", 18 April 2024,
              <https://law.stanford.edu/wp-content/uploads/2024/08/van-
              Schewick-2024-5G-Network-Slicing-and-No-Throttling-Rule-
              20240418.pdf>.

   [Apple]    Apple, "Testing and Debugging L4S in Your App",
              <https://developer.apple.com/documentation/network/
              testing-and-debugging-l4s-in-your-app>.

   [Tussle]   Clark, D., Wroclawski, J., Sollins, K., and R. Braden,
              "Tussle in Cyberspace: Defining Tomorrow's Internets", 19
              August 2002,
              <https://dl.acm.org/doi/10.1145/633025.633059>.

Author's Address

   Jason Livingood
   Comcast
   Philadelphia, PA
   United States of America
   Email: jason_livingood@comcast.com

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