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ISP Dual Queue Networking Deployment Observations
draft-livingood-low-latency-deployment-15

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Author Jason Livingood
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draft-livingood-low-latency-deployment-15
Independent Stream                                          J. Livingood
Internet-Draft                                                   Comcast
Intended status: Informational                              2 March 2026
Expires: 3 September 2026

           ISP Dual Queue Networking Deployment Observations
               draft-livingood-low-latency-deployment-15

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 some of the implications of
   those decisions and makes suggestions that can help drive adoption
   and acceptance of L4S and NQB based on observations from the world's
   first large scale deployment.

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
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   Internet-Drafts are draft documents valid for a maximum of six months
   and may be updated, replaced, or obsoleted by other documents at any
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   This Internet-Draft will expire on 3 September 2026.

Copyright Notice

   Copyright (c) 2026 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
     1.3.  Application Performance Benefits  . . . . . . . . . . . .   5
   2.  Key Low Latency Networking Concepts . . . . . . . . . . . . .   5
     2.1.  Throughput is Bounded by Congestion Control Algorithms  .   6
     2.2.  Best Effort Priority  . . . . . . . . . . . . . . . . . .   7
     2.3.  Shared Capacity . . . . . . . . . . . . . . . . . . . . .   8
     2.4.  Access-Agnostic . . . . . . . . . . . . . . . . . . . . .   8
     2.5.  End-to-End Diagram  . . . . . . . . . . . . . . . . . . .   8
   3.  Application Developer Implementation Suggestions  . . . . . .   9
     3.1.  Delivery Infrastructure for L4S . . . . . . . . . . . . .   9
     3.2.  Delivery Infrastructure for NQB . . . . . . . . . . . . .   9
     3.3.  Only Mark Delay-Sensitive Traffic for L4S or NQB  . . . .  10
     3.4.  Consider Application Needs in Choosing L4S vs. NQB  . . .  10
     3.5.  Example: iOS Application for L4S  . . . . . . . . . . . .  10
   4.  ISP Implementation Suggestions  . . . . . . . . . . . . . . .  10
     4.1.  Allow ECN Across Network Boundaries . . . . . . . . . . .  11
     4.2.  Allow DSCP-45 Across Network Boundaries . . . . . . . . .  11
     4.3.  Last Mile Network (Access Network)  . . . . . . . . . . .  12
     4.4.  Customer Premise Equipment (Customer Edge)  . . . . . . .  12
     4.5.  Inside the Home - Customer Local Area Network (LAN) . . .  13
       4.5.1.  802.11 WiFi Queuing . . . . . . . . . . . . . . . . .  13
     4.6.  Packet Loss Effects . . . . . . . . . . . . . . . . . . .  13
     4.7.  Avoid Middleboxes . . . . . . . . . . . . . . . . . . . .  14
   5.  IANA Considerations . . . . . . . . . . . . . . . . . . . . .  16
   6.  Security Considerations . . . . . . . . . . . . . . . . . . .  16
   7.  Acknowledgements  . . . . . . . . . . . . . . . . . . . . . .  16
   8.  Revision History  . . . . . . . . . . . . . . . . . . . . . .  16
   9.  Open Issues . . . . . . . . . . . . . . . . . . . . . . . . .  17
   10. Informative References  . . . . . . . . . . . . . . . . . . .  17
   Author's Address  . . . . . . . . . . . . . . . . . . . . . . . .  22

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.

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   This document explores some of the key deployment decisions and makes
   suggestions that may help drive adoption by network operators and
   application developers.  These decisions are not inherent to L4S and
   NQB per se, but are decisions that can change depending upon
   differing technical, regulatory, business or other requirements.
   This document suggests that certain specific deployment decisions -
   based on observations from the world's first large scale deployment -
   that can help maximize the value of low latency networking to end
   users, network operators, and application developers.

   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.  Introducing a new queue enables incremental
   development of a new standard rather than changing existing
   congestion control algorithms for existing traffic on all networks,
   hosts, and clients - 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 is not delay-sensitive, at
   least on a millisecond level basis.  The other type of traffic is
   real-time, interactive traffic that is latency-sensitive, such as
   video conferencing, gaming, and artificial intelligence (AI)
   interactions.

   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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   +============+=====================+==============+================+
   | Primary    | Examples            | Flow         | IETF           |
   | Goal       |                     | Properties   | Classification |
   +============+=====================+==============+================+
   | Low        | VoIP, DNS, game     | Low data     | Non-Queue-     |
   | Latency    | sync packets, some  | rate,        | Building (NQB) |
   |            | machine-to-machine  | application- |                |
   |            | and IoT             | limited      |                |
   |            | communications      | flows        |                |
   +------------+---------------------+--------------+----------------+
   | Low        | Cloud gaming, video | Low data     | Low Latency,   |
   | Latency    | conferencing,       | rate,        | Low Loss,      |
   | with High  | adaptive video      | application- | Scalable       |
   | Throughput | streaming, instant  | limited      | Throughput     |
   |            | messaging, web      | flows and    | (L4S)          |
   |            | browsing, VoIP,     | high data    |                |
   |            | cloud-based         | rate,        |                |
   |            | interactive video,  | throughput-  |                |
   |            | cloud-based virtual | limited      |                |
   |            | and augmented       | flows        |                |
   |            | reality             |              |                |
   +------------+---------------------+--------------+----------------+
   | High       | Bursty traffic      | Software     | Queue-Building |
   | Throughput | flows and high data | Updates,     | (QB)           |
   | without    | rate traffic flows  | Cloud        |                |
   | Respect to |                     | Backups, P2P |                |
   | Latency    |                     | File Sharing |                |
   +------------+---------------------+--------------+----------------+

           Table 1: Latency Sensitivity of Example Applications

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

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   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.

1.3.  Application Performance Benefits

   The benefits of low latency networking to end user applications,
   especially interactive ones, is significant.  In the Comcast network
   in the United States, this technology is deployed to over ten million
   homes as of January 2026.  That encompasses over 300 million end user
   devices, based on the typical number of devices on a user Local Area
   Network (LAN).  Comcast has shared in many IETF meeting presentations
   the data showing latency and jitter reductions (such as in
   [IETF-122-Slides]).  At a high level, 99th percentile loaded latency
   for downstream traffic declined from ~65 ms to ~33 ms from
   implementation of downstream Active Queue Management (AQM) on the
   Cable Modem Termination System (CMTS).  The new low latency queue
   (for L4S and NQB) further lowered downstream loaded latency to ~18 ms
   and upstream loaded latency to ~20 ms.  The DOCSIS link layer itself
   in the Comcast is responsible for a baseline idle latency of 13-17
   ms, which means that loaded latencies for L4S and NQB traffic are
   very close to idle latencies.  Jitter is also significantly lower and
   more consistent.

   This means that video conferencing applications such as Apple
   FaceTime and cloud gaming such as NVIDIA GeForce NOW and Valve's
   Steam platform will perform much better on a network that supports
   low latency networking.  It benefits any marked application that is
   interactive in nature, where a user is interacting with a screen or
   other device, via mouse, keyboard, voice command, gesture, or other
   interactivity mechanism, and the interaction involves remote
   entities.  Apple recently shared statistics [IETF-123-Slides] that
   they collected that confirm this performance, using Responsiveness
   Under Working Conditions tests [I-D.ietf-ippm-responsiveness].

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.  It was also thought that networks and applications had
   to choose between either high throughput or low delay - but dual
   queue low latency demonstrates that both can be achieved
   simultaneously.

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2.1.  Throughput is Bounded by Congestion Control Algorithms

   The Mathis Equation [Mathis] explains how throughput is bounded in
   the Reno congestion control algorithm that was in use at that time.
   Reflections on this approach were published later and hint at the
   potential for new approaches like those explored in this document
   [Mathis-Reflections].

   This equation shows that throughput scales at 1/sqrt(p), where p is
   the packet loss probability.  The square root is a problem, because
   achieving a ten-fold increase in throughput requires a one-hundred-
   fold reduction in packet loss probability, and thus a ten-fold
   reduction in packet loss rate on a per-second basis.  This becomes
   unscalable as path capacities increase, as the required time between
   congestion signals becomes longer than the typical duration of a
   connection.

   This nonlinear relationship described in the equation means that, to
   take a link from 1 Gbps to 10 Gbps for example, packet loss would
   need to be reduced one-hundred-fold.  This makes it increasingly hard
   to hit ever-higher data rates in real world environments, especially
   with WiFi and 5G links, where those levels of loss are unachievable
   at the current time.

   While the dominant congestion control algorithm today (Cubic)
   improves upon this, it still requires long intervals between
   congestion signals as rates increase [RFC9438].  Alternative
   congestion controllers like BBR [BBR-Paper] aim to infer the link
   rate without relying on packet loss as a signal but do so with very
   limited information from the path, and can lead to fairness issues,
   oscillations in throughput, starvation and other unwanted effects
   [Starvation] [BBR-Analysis].

   L4S replaces packet loss with an explicit signal (CE mark) and it
   takes advantage of the fact that, in contrast to packet loss, the
   explicit congestion signal is not a degradation of communication and
   thus can be provided liberally by the network.

   L4S also requires that the congestion control algorithm scales its
   throughput proportional to 1/p, where p here is the congestion
   marking probability.  What this means in practice is that if you
   increase throughput by 10x, you only need to reduce the congestion
   signal probability by 10x rather than 100x, and the rate of
   congestion signals on per-second basis remains constant.  As a
   result, applications get very frequent and fine-grained feedback that
   they use to make adjustments to their sending rate, and congestion
   control is fully scalable, with no loss in the frequency of signals
   as the path capacity increases.

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   This table illustrates the implications of this for an example of a
   TCP connection with 50 ms RTT (example idle and working latencies can
   be seen in [FCC-MBA-2023]).

    +======+====================+====================+===============+
    | Data | Reno: Interval     | Cubic: Interval    | L4S: Interval |
    | Rate | Between Congestion | Between Congestion | Between       |
    |      | Signals            | Signals            | Congestion    |
    |      |                    |                    | Signals       |
    +======+====================+====================+===============+
    | 1    | 285 ms             | 160 ms             | 12.5 ms       |
    | Mbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+
    | 10   | 2.85 sec           | 350 ms             | 12.5 ms       |
    | Mbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+
    | 100  | 28.5 sec           | 740 ms             | 12.5 ms       |
    | Mbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+
    | 1    | 4.75 min           | 1.6 sec            | 12.5 ms       |
    | Gbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+
    | 10   | 47.5 min           | 3.5 sec            | 12.5 ms       |
    | Gbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+
    | 100  | 7.9 hrs            | 7.5 sec            | 12.5 ms       |
    | Gbps |                    |                    |               |
    +------+--------------------+--------------------+---------------+

      Table 2: Comparison of Congestion Signal Frequency at 50ms RTT

2.2.  Best Effort Priority

   Low latency traffic is not prioritized over other (best effort
   priority) "classic" Internet traffic.  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].

   Those approaches are grounded in an assumption that there is scarce
   bandwidth and so the network must grant higher priority to some
   flows, creating bandwidth winners and losers.  That has raised the
   ire of network neutrality proponents, who have focused on negative
   effects this can have on flows that are not prioritized and the terms
   under which certain applications or destinations may be granted
   priority.

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   Another contrast with 5G network slicing is that IETF standards such
   as L4S do not require network operator-specific APIs, direct
   coordination, or the granting of permission by technical or legal
   means.  Rather, marking packets with ECT(1) or CE as part of L4S will
   work on any network that has implemented L4S, with no need to
   coordinate with each network or seek permission.  This exemplifies
   the loose coupling across layer (network and application) and
   permissionless innovation (at the edge by application developers)
   that are core tenets of the Internet's architecture.

   The only exception for priority is within a user's in-home Wi-Fi
   network (in the case of a fixed network) due to the particulars of
   how the IEEE 802.11 wireless protocol [IEEE] functions at the current
   time - see [RFC8325].  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].

2.3.  Shared Capacity

   Low latency networking flows do not get access to greater capacity
   than "classic" flows.  Thus, a user's total provisioned or permitted
   capacity on an ISP access network link is shared between both classic
   and low latency queues.  This removes an incentive to game the system
   through low latency packet marking.

   Another way to think of L4S is that it is not really an instruction
   to a dual queue network link to ask for low latency treatment per se.
   Rather, applications marking for L4S are essentially making a promise
   to the network that the application will rapidly reduce throughput if
   needed (when detecting CE marks); it promises to help keep latency
   low by being a good network citizen.

2.4.  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], WiFi, Low
   Earth Orbit (LEO) satellite and many other types of networks.

2.5.  End-to-End Diagram

   This diagram shows an example of the end-to-end path for two
   different user devices; one phone connected to the home WiFi network
   and one PC connected via Ethernet to the home LAN.  Along this full
   path, L4S or NQB marks must be able to pass between an application on
   a client device and an application server.  While in theory dual
   queue low latency networking can be implemented on any of the routers
   on this path or the access point, the most common bottlenecks are in

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   the home network (WiFi), the CPE router, and the aggregation router.
   This alone will provide a tremendous benefit to interactive end user
   applications and dual queue need not in that case be deployed at any
   of the other hops.

   (Artwork only available as SVG: see https://www.ietf.org/archive/id/
   draft-livingood-low-latency-deployment-15.html)

                   Figure 1: Network Architecture Diagram

3.  Application Developer Implementation Suggestions

   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.  The application 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
   (removing) the value set in 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.

3.2.  Delivery Infrastructure for NQB

   NQB uses the DSCP-45 code point in the DiffServ part of the packet
   header to ensure NQB works end-to-end.  To achieve end-to-end
   marking, 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 (removing) a DSCP-45 mark.  The server
   does not need to run a special responsive congestion controller.
   Since it is common for networks to bleach DSCP marks on ingress

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   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.

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 sensitive 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 necessary.

   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.

3.5.  Example: iOS Application for L4S

   Implementations will vary depending upon variables such as server
   operating system, transport and application protocols, and client
   software and operating system.  To use the example of an Apple device
   such as an iPhone, running iOS, L4S support is built into iOS by
   default [L4S-Testing].  If the developer uses the QUIC protocol, they
   can use "URLSession" [URLSession] which enables L4S.

4.  ISP Implementation Suggestions

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

   These suggestions focus on not bleaching (removing) ECN or DSCP-45
   marks for L4S and NQB, respectively.  That is because low latency
   networking will not work on any connected downstream network if these
   marks cannot travel end-to-end (e.g., a customer of the network,
   including fixed and mobile end users, enterprises, and other users).

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   There are also applications that will work on a peer-to-peer, intra-
   domain basis in a network, and those also would not be able to take
   advantage of L4S and NQB.

   ECN generally works across all domain boundaries, so unless a network
   has gone out of their way to bleach the ECN header, this is unlikely
   to be a major concern.

   The key issue for modification or bleaching (removal of marks) is
   really DSCP.  NQB depends upon DSCP-45 passing across domain
   boundaries.  Historically, there is little alignment between networks
   over common DSCP marking since historically DSCP marks have not been
   used across domain boundaries, and each network has implemented
   unique approaches to how DSCP is used.  In practice this means most
   network have a router policy that will replace most or all DSCP
   values on ingress and mark DSCP-0 or 8 or whatever code point the
   receiving network uses for best effort or default traffic.  That
   means a router policy change will be needed here.  Any concern over
   this can be mitigated by ensuring that DSCP-45 traffic is treated as
   best effort priority like regular internet traffic.

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 L4S-
   aware and able to add a CE mark to signal that it is experiencing
   congestion at that hop.  The end-to-end integrity of ECN marks is
   explored in Appendix C.1 of [RFC9331].

   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).  The end-to-end integrity of the
   DSCP-45 mark is explored in Section 6.4 of [I-D.ietf-tsvwg-nqb].

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   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 these 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.

4.4.  Customer Premise Equipment (Customer Edge)

   In most residential Internet services, there are typically two
   equipment modes.  One is a 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.  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.

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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.  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).

   As explored in Section 7.3 of [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.  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.

4.6.  Packet Loss Effects

   As networks implement low latency networking, including L4S, NQB, and
   new forms of AQM, they may notice somewhat less packet loss.  This is
   because applications now have new signals, such as a CE mark, to
   signal congestion.  This signal is faster than the typical TCP packet
   loss mechanism.

   Thus, this is expected, as noted in Section 5.1 of Section 5.1 of
   [RFC9330]:

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   |  Latency is not the only concern of L4S.  The 'Low Loss' part of
   |  the name denotes that L4S generally achieves zero congestion loss
   |  due to its use of ECN.  Otherwise, loss would itself cause delay,
   |  particularly for short flows, due to retransmission delay
   |  [RFC2884].
   |  
   |     RFC9330

   In addition see Section 3 of Section 3 of [RFC2884]:

   |  Since ECN marks packets before congestion actually occurs, this is
   |  useful for protocols like TCP that are sensitive to even a single
   |  packet loss.  Upon receipt of a congestion marked packet, the TCP
   |  receiver informs the sender (in the subsequent ACK) about
   |  incipient congestion which will in turn trigger the congestion
   |  avoidance algorithm at the sender.
   |  
   |     RFC2884

4.7.  Avoid 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 middlebox in the ISP network.  In this
   case, these are network elements that have not been configured by an
   end user application but rather inserted in the path by a network
   operator as an element where active network management policies could
   be applied.  An application-configured element, in contrast, could be
   something like an Oblivious HTTP Relay Resource (server) [RFC9458].

   As explored below, avoiding a middlebox and leaving marking to
   application clients is the most efficient, least prone to
   misclassification, and is most acceptable from the standpoint of
   network neutrality.  So, while a middlebox may exist on an end-to-end
   path, it is best not to have a middlebox actively classify traffic
   for a low latency queue; let applications make that decision to limit
   the potential for problems that middleboxes can cause.

   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.  IANA Considerations

   RFC Editor: Please remove this section before publication.

   This memo includes no requests to or actions for IANA.

6.  Security Considerations

   The key security consideration relates to access to capacity by flows
   using a low latency queue when those flows do not follow the
   guidelines or L4S or NQB behavior.  If flows mark for low latency
   queue treatment but are not correctly rate-responsive or low bitrate,
   then there is a potential risk that they may disrupt the low latency
   goal of the low latency queue.  [RFC9331] introduces a Queue
   Protection function to mitigate this risk.  More can be learned about
   this in Section 5.2 of Section 5.2 of [I-D.ietf-tsvwg-nqb].

   The necessity of Queue Protection (also referred to as Traffic
   Protection) remains in 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.  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 so much traffic
   to the low latency queue that the queue or both queues become
   unusable.  This is quite similar to other "traditional" denial of
   service (DoS) attacks, so it does not necessarily seem unique to low
   latency networking.  But due to the possibility of this occurring,
   and low latency networking being such a new approach, it seems
   prudent to implement Queue Protection.

7.  Acknowledgements

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

8.  Revision History

   RFC Editor: Please remove this section before publication.

   v00: First draft

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   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

   v10: Final changes from review

   v11: Suggestions and nits from Greg White, other nits

   v12: Sec 2.1 suggestions from Greg White, other nits

   v13: Nits from Jason Schnitzer, suggestions from Matt Mathis

   v14: Changes from Eliot Lear

   v15: fix minor SVG nit

9.  Open Issues

   RFC Editor: Please remove this section before publication.

10.  Informative References

   [RFC2884]  Hadi Salim, J. and U. Ahmed, "Performance Evaluation of
              Explicit Congestion Notification (ECN) in IP Networks",
              RFC 2884, DOI 10.17487/RFC2884, July 2000,
              <https://www.rfc-editor.org/info/rfc2884>.

   [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>.

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   [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>.

   [RFC9438]  Xu, L., Ha, S., Rhee, I., Goel, V., and L. Eggert, Ed.,
              "CUBIC for Fast and Long-Distance Networks", RFC 9438,
              DOI 10.17487/RFC9438, August 2023,
              <https://www.rfc-editor.org/info/rfc9438>.

   [RFC9458]  Thomson, M. and C. A. Wood, "Oblivious HTTP", RFC 9458,
              DOI 10.17487/RFC9458, January 2024,
              <https://www.rfc-editor.org/info/rfc9458>.

   [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-09, 12 January
              2026, <https://datatracker.ietf.org/doc/html/draft-ietf-
              tsvwg-l4sops-09>.

   [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-33,
              16 September 2025, <https://datatracker.ietf.org/doc/html/
              draft-ietf-tsvwg-nqb-33>.

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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>.

   [I-D.ietf-ippm-responsiveness]
              Paasch, C., Meyer, R., Cheshire, S., and W. Hawkins,
              "Responsiveness under Working Conditions", Work in
              Progress, Internet-Draft, draft-ietf-ippm-responsiveness-
              08, 20 October 2025,
              <https://datatracker.ietf.org/doc/html/draft-ietf-ippm-
              responsiveness-08>.

   [BITAG]    Broadband Internet Technical Advisory Group, "Latency
              Explained", 10 January 2022,
              <https://papers.ssrn.com/sol3/
              papers.cfm?abstract_id=5677705>.

   [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>.

   [Mathis]   Mathis, M., Semke, J., Mahdavi, J., and T. Ott, "The
              macroscopic behavior of the TCP congestion avoidance
              algorithm", DOI 10.1145/263932.264023, Association for
              Computing Machinery Sigcomm Computer Communications
              Review, 1 July 1997,
              <https://dl.acm.org/doi/10.1145/263932.264023>.

   [Mathis-Reflections]
              Mathis, M., "Reflections on the TCP Macroscopic Model",
              ACM SIGCOMM Computer Communication Review vol. 39, no. 1,
              pp. 47-49, DOI 10.1145/1496091.1496099, January 2009,
              <https://doi.org/10.1145/1496091.1496099>.

   [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>.

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

   [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>.

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   [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>.

   [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>.

   [IETF-122-Slides]
              Livingood, J., "Dual Queue Low Latency Networking Update",
              17 March 2025,
              <https://datatracker.ietf.org/meeting/122/materials/
              slides-122-tsvwg-41-jason-livingood-update-on-deployment-
              00>.

   [IETF-123-Slides]
              Cheshire, S., "L4S with Apple Devices", 23 July 2025,
              <https://datatracker.ietf.org/meeting/123/materials/
              slides-123-tsvwg-l4s-with-apple-devices-00>.

   [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>.

   [FCC-MBA-2023]
              Federal Communications Commission, "Twelfth Measuring
              Broadband America Fixed Broadband Report", January 2023,
              <https://www.fcc.gov/reports-research/reports/measuring-
              broadband-america>.

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   [URLSession]
              Apple, "Apple Developer Documentation, URLSession",
              <https://developer.apple.com/documentation/foundation/
              urlsession>.

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

   [BBR-Paper]
              Cardwell, N., Cheng, Y., Gunn, C. S., Yeganeh, S. H., and
              V. Jacobson, "BBR: Congestion-Based Congestion Control",
              ACM Queue, Vol. 14, Issue 5, September 2016,
              <https://dl.acm.org/doi/10.1145/3022184.3012426>.

   [Starvation]
              Arun, V., Alizadeh, M., and H. Balakrishnan, "Starvation
              in End-to-End Congestion Control", Proceedings of the ACM
              SIGCOMM 2022 Conference, August 2022,
              <https://doi.org/10.1145/3544216.3544223>.

   [BBR-Analysis]
              Scholz, D., Jaeger, B., Schwaighofer, L., Raumer, D.,
              Geyer, F., and G. Carle, "Towards a Deeper Understanding
              of TCP BBR Congestion Control", 2018 IFIP Networking
              Conference, May 2018,
              <https://doi.org/10.23919/IFIPNetworking.2018.8696830>.

Author's Address

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

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