Internet DRAFT - draft-livingood-low-latency-deployment
draft-livingood-low-latency-deployment
Independent Stream J. Livingood
Internet-Draft Comcast
Intended status: Informational 28 September 2023
Expires: 31 March 2024
Comcast ISP Low Latency Deployment Design Recommendations
draft-livingood-low-latency-deployment-03
Abstract
The IETF's Transport Area 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 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 those in experimental status, certain
deployment design decisions are ultimately left to implementers.
This document explores the potential implications of key deployment
design decisions and makes recommendations for those decisions that
may help drive adoption.
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
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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
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 31 March 2024.
Copyright Notice
Copyright (c) 2023 IETF Trust and the persons identified as the
document authors. All rights reserved.
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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.
Table of Contents
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . 2
2. A New Understanding of Application Needs . . . . . . . . . . 3
3. New Thinking on Low Latency Packet Processing . . . . . . . . 4
4. Network Neutrality and Low Latency Networking . . . . . . . . 5
4.1. Application-Agnostic Low Latency Networking . . . . . . . 5
4.2. User-Centric Monetization, Not Application Provider
Monetization . . . . . . . . . . . . . . . . . . . . . . 6
4.3. Prioritization: Same Best Effort Priority for All
Traffic . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.4. Thoughput: Shared Across All Traffic . . . . . . . . . . 6
4.5. Can Work on All Types of Network Technology . . . . . . . 7
5. Recommended Deployment Design Decisions . . . . . . . . . . . 7
5.1. Only Applications Mark Traffic . . . . . . . . . . . . . 7
5.2. All Application Providers Welcome . . . . . . . . . . . . 9
5.3. End User CPE Choice . . . . . . . . . . . . . . . . . . . 9
5.4. Opt Out Capability During Technical Trial Experiments . . 9
5.5. Consider Traffic Protection . . . . . . . . . . . . . . . 10
5.6. Avoid Internal Remarking of DSCP Values if Possible . . . 10
5.7. In Home Wi-Fi LAN Considerations . . . . . . . . . . . . 10
6. Summary of Recommended Deployment Design Decisions . . . . . 11
7. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . 11
8. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 12
9. Security Considerations . . . . . . . . . . . . . . . . . . . 12
10. Privacy Considerations . . . . . . . . . . . . . . . . . . . 12
11. Revision History . . . . . . . . . . . . . . . . . . . . . . 12
12. Open Issues . . . . . . . . . . . . . . . . . . . . . . . . . 12
13. Informative References . . . . . . . . . . . . . . . . . . . 12
Author's Address . . . . . . . . . . . . . . . . . . . . . . . . 15
1. Introduction
The IETF's Transport Area Working Group (TSVWG) has finalized
experimental RFCs for Low Latency, Low Loss, Scalable Throughput
(L4S) and Non-Queue-Building (NQB) per hop behavior [RFC9330]
[RFC9331] [RFC9332] [I-D.ietf-tsvwg-l4sops] [I-D.ietf-tsvwg-nqb]
[I-D.ietf-tsvwg-dscp-considerations]. 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 those in experimental status, certain deployment design
decisions are ultimately left to implementers.
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This document explores the potential implications of key deployment
design decisions and makes recommendations for those decisions that
may help drive adoption. In particular, there are best practices
based on prior experience as a network operator that should be
considered and there are network neutrality types of considerations
as well. These technologies are benign on their own, but the way
they are operationally implemented can determine whether they are
ultimately perceived positively and adopted by the broader Internet
ecosystem. That is a key issue for low latency networking, because
the more applications developers and edge platforms that adopt new
packet 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 both users and network operators.
It is also apparent from the IETF's work that it is clear that nearly
all modern application types need low latency to some degree and that
applications are best positioned to express their needs via
application code and packet marking. Furthermore, unlike with
bandwidth priority on a highly/fully utilized link, low latency
networking can better balance the needs of different types of best
effort flows (with some caveats - see Section 3).
For additional background on latency and why latency matters so much
to the Internet, please read [BITAG]
2. A New 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 fundamentally two types of Internet traffic and that these two
major traffic types could benefit from having separate network
processing queues in order to improve the way the Internet works for
all applications, and especially for interactive applications.
One of the two major traffic types is Queue Building (QB) - things
like file downloads and backups that are designed utilize as much
network capacity as possible but with which users are usually not
interacting with in real-time. The other was Non-Queue-Building
(NQB) - such as DNS lookups, voice interaction with artificial
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intelligence (AI) assistants, video conferencing, gaming, and so on.
NQB flows tend to be ones where the end user is sensitive to any
delays.
Thus, the IETF created specifications for how two different network
processing queues. Early results, such as from the IETF-114
hackathon [IETF-114-Slides], demonstrate that L4S and NQB (a.k.a.
dual queue networking, and simply "low latency networking" hereafter)
can work across a variety of access network technologies and deliver
extraordinary levels of responsiveness for a variety of applications.
It seems likely that this new capability will enable entirely new
classes of applications to become possible, driving a wave of new
Internet innovation, while also improving the applications people use
today.
3. New Thinking on Low Latency Packet Processing
The Introduction says that unlike with bandwidth priority on a
highly/fully utilized link, low latency networking can better balance
the needs of different types of best effort flows. But this bears a
bit of further discussion to understand more fully.
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 an idea that
network capacity is very limited and that links are often highly
utilized. But in today's Internet, it is increasingly the case that
there is an abundance of capacity to end users (e.g., symmetric 1
Gbps), which makes such traditional QoS approaches ineffective in
delivering ever-lower latency. This new low latency networking
approach is not based on hierarchical QoS prioritization. Rather, it
is built upon conditional priority scheduling between its two queues
that operate at best effort QoS priority.
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4. Network Neutrality and Low Latency Networking
Network Neutrality (a.k.a. Net Neutrality, and NN hereafter) is a
concept that 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, NN means that Internet Service Providers (ISPs) should not
limit user choice or affect competition between application
providers. In the context of the United States' marketplace, it has
come to mean that ISPs should not block, throttle, or deprioritize
lawful application traffic, and should not engage in paid
prioritization, among other things. The meaning of NN can be complex
and ever changing, so the specific details are out of scope for this
document. Despite that, NN concerns certainly bear on the deployment
of new technologies by ISPs in many countries and so should be taken
into account in making deployment design decisions.
It is also possible that there can be confusion - for people who are
not deep in this highly technical subject - between prioritization,
provisioned end user capacity (throughput or bandwidth), and low
latency networking. As it is envisioned in the design of the
protocols, the addition of a low latency packet processing 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. Thus, a low latency queue does not create a so-called
"fast lane" (in the way that this term is used in policy-related
discussions in the U.S. to describe higher than best effort priority
or greater capacity being assigned to some traffic compared to
default traffic) - but there are certainly other NN considerations in
the operational implementation worth exploring.
In short: implemented right, low latency networking is fully-aligned
with net neutrality and has no impact on user choice and competition.
The principles below describe guidelines for a user-centric,
application-agnostic, and monetizable implementation of low latency
networking that is aligned with NN frameworks and interpretations, at
least in the U.S. and Europe.
4.1. Application-Agnostic Low Latency Networking
A key principle of NN is that all applications should be treated the
same by ISPs. As such, any application should be able to request
access to low latency networking using the available marking
techniques, and the network should forward packets through a low
latency queue only based on such markings, without inferring or
taking into consideration from which application certain packets
originate.
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4.2. User-Centric Monetization, Not Application Provider Monetization
To incentivize low latency networking deployments, ISPs should be
able to monetize it in some way, such as by enabling it on specific
tiers of service. This could be misinterpreted as paid
prioritization. To avoid such conflicts or misinterpretations, ISPs
should charge users (and not application providers) for access to low
latency networking, and follow common charging regimes used for best-
effort services. For example, different price-points may be achieved
by adjusting the throughput, monthly data allowance, in home network
equipment maintenance, in home network services (e.g., parental
controls), provision of low latency networking, or other service
attributes. Thus, ISPs should not limit the number or types of
applications that can access low latency networking, as this would
eventually conflict with the application-agnostic requirement.
4.3. Prioritization: Same Best Effort Priority for All Traffic
A key aspect of NN is that traffic to certain Internet destinations
or for certain applications should not be prioritized over other
Internet traffic. This means in practice that all Internet traffic
in an ISP network should be carried at the same (best effort)
priority and that any network management practices imposed by the
network should be protocol (application) agnostic. Low latency
networking is fully consistent with this aspect of NN, because it is
designed so that all traffic is treated on a best effort basis in the
ISP network (this is 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, as noted above, unlike with bandwidth priority on a
highly/fully utilized link, low latency networking can better balance
the needs of different types of best effort flows.
4.4. Thoughput: Shared Across All Traffic
Low latency networking is also consistent with the NN goal of not
creating a fast lane, because the same end user throughput in an ISP
access network is shared between both classic and low latency (L4S/
NQB) queues. Thus, applications do not get access to greater
throughput depending on whether or not the leverage low latency
networking.
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4.5. Can Work on All Types of Network Technology
Ultimately, the emergence of low latency networking represents a
fundamental new network capability that applications can choose to
utilize as their needs dictate. It reflects a new ground truth about
two fundamentally different types of application traffic and
demonstrates that networks continue to evolve in exciting ways.
In addition, this new network capability 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. Anywhere
that a network bottleneck could occur may benefit from this
technology.
5. Recommended Deployment Design Decisions
Like any network or system, a good deployment design and
configuration matters and can be the difference between a well-
functioning and accepted design and one that experiences problems and
faces opposition. In the context of deploying low latency networking
in an ISP network, this document describes some recommended
deployment design decisions that should help to ensure a deployment
is resilient, well-accepted, and creates the environment for
generating strong network effects. In contrast, creating barriers to
adoption in the early stages through design and policy decisions will
presumably reduce the predicted potential network effect, thus
choking off further investment across the Internet ecosystem, leading
to a vicious circle of decline - and then the potential value is
never realized.
5.1. Only Applications Mark Traffic
Only applications should mark traffic to inidate their preference for
the low latency queue, not the network. This is for several reasons:
* 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.
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* 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.
* To correctly utilize L4S, the application and the server needs to
use a scalable congestion control algorithm in order to use the
packet marking for L4S and respond to congestion experience (CE)
marking. This is done by using the ECN field of the packet
header, with an ECT(1) marking, according to Section 4.1 of
[RFC9331] and being responsibe to Congestion Experienced (CE)
marks. But only the application (not the network) knows what
congestion control it is using. So, with L4S, the network cannot
properly mark on behalf of the application.
* To correctly utilize NQB for non-L4S traffic, then the DSCP field
of the packet header is used, with a DSCP 45 marking, according to
Section 4.1 of [I-D.ietf-tsvwg-nqb]. But the majority of traffic
is now encrypted, so it seems implausible for a network to try to
infer the type of traffic and whether an application could benefit
from NQB treatment; this is best left to application developers to
determine as they are the experts in the particular needs of their
application.
* Network operators and equipment vendors attempting to infer
application type and application need will always make mistakes,
incorrectly classifying traffic [Lotus], and potentially
negatively affecting certain flows.
* 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.
* Note, however, that this does not preclude an ISP from changing
packet marking within their internal network due to an existing
use of a particular code point.
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5.2. All Application Providers Welcome
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 or greatly
reducing any need for application providers and networks to
coordinate on deployment (though such coordination is normal in the
early experimental phase of any deployment).
As noted above, this is another example that low latency networking
will have strong network effects, any barriers to adoption such as
this should be avoided in order to maximize the value to users and
the network of a new low latency queue.
5.3. End User CPE Choice
Both customer-owned and ISP-administered Customer Premise Equipment
(CPE) should be supported, when applicable (not all networks support
this nor is it necessary in some networks). This avoids the risk
that an ISP can be perceived as giving preference to their own
network demarcation devices, which may carry some monthly recurring
fee or other cost. This also means that retail CPE manufacturers
need to make the necessary development investment to correctly
implement low latency networking, though this may not interest or may
be outside the capabilities of some organizations. In any case, the
more devices that implement then adoption is broader, positively
driving network effects.
5.4. Opt Out Capability During Technical Trial Experiments
During technical trial experiments of low latency networking, ISPs
should consider making available some mechanism for users to opt out
of (deactivate) it. If low latency networking is functioning
correctly, it seems extremely unlikely that a user should ever want
or need to turn it off. On the other hand, it is also possible that
it may be desirable in some troubleshooting situations to turn it
off.
As this technology enters normal production operation, there will not
be a long term need or practical benefit to having an opt out
mechanism. Thus, that mechanism will no longer be necessary or
practical; any problems should be handled like typical production
network problems.
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5.5. Consider Traffic Protection
The specifications in [I-D.ietf-tsvwg-nqb] describe a concept of
Traffic Protection, also known as a Queue Protection Function
[I-D.briscoe-docsis-q-protection]. The document says that Traffic
Protection is optional and may not be needed in certain networks. In
the case of an ISP deploying low latency networking with two queues,
an ISP should consider deploying such a network function to at least
detect mismarking (if not necessarily to correct mismarking). This
may be implemented for example in end user CPE, last mile network
equipment, and/or elsewhere in the ISP network - or closely monitors
network statistics and user feedback for any indication of widespread
NQB packet mismarking by applications.
5.6. Avoid Internal Remarking of DSCP Values if Possible
If possible, based on a network's existing use of DSCP values, a
network should try to maintain the use of DSCP 45 on an end-to-end
basis without remarking. While this may not be possible in all
networks, it can reduce complexity, enable simpler network
operations, and ease troubleshooting of NQB traffic flows. In some
cases a network may need to migrate an existing, private internal use
of DSCP 45 to some other mark to achieve this. In the long term that
may be best, even if it takes a bit more initial effort when
deploying low latency networking. In addition, if a network does
have their own private internal use of DSCP 45, then they alone
should be responsible for any necessary remarking for traffic passing
through their network (it would be unfair and unreasonable for a
given network's private use of a DSCP mark to pose a burden on other
networks).
5.7. In Home Wi-Fi LAN Considerations
As noted above with respect to prioritization of packets in the ISP
network, all packets should be handled with the same best effort
priority. 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:
* User Priority 1 or 2, AC_BK = Background
* User Priority 0 or 3, AC_BE = Best Effort
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* User Priority 4 or 5, AC_VI = Video
* User Priority 6 or 7, AC_VO = Voice
Thus, as recommended in [I-D.ietf-tsvwg-nqb], the low latency queue
should be different from the best effort queue. That means default
best effort traffic will be in User Priority 0 or 3 (AC_BE) and it is
recommended that the low latency queue will be in User Priority 4 or
5 (AC_VI). For additional context, please refer to Section 8.1 of
[I-D.ietf-tsvwg-nqb].
It is also worth noting that, in the short-term, Microsoft has taken
a slightly different approach to packet marking on their Xbox
platform [Microsoft]. They are using DSCP-46 rather than DSCP-45,
though presumably once the IANA port assignment for DSCP-45 is made
this will change. As a result, a more permissive WLAN marking policy
is initially recommended until RFCs for NQB are published and
developers coalesce around DSCP-45. This means that the network
which will put packets marked with DSCP-46 (and potentially other
values, such as 40 and 56) into the low latency queue. They are also
using the AC_VO queue rather than the AC_VI queue, but it is not
known if that may change when the DSCP marking changes.
6. Summary of Recommended Deployment Design Decisions
1 Only Applications Mark Traffic: Not the network
2 All Application Providers Welcome: Any application provider can
mark with no restrictions other than standards compliance or other
reasonable and openly documented technical guidelines
3 End User CPE Choice: When applicable, both customer-owned and ISP-
administered devices supported
4 Opt Out Capability During Technical Trial Experiments: Users can
opt out during technical trial expriments
5 Consider Traffic Protection: Consider potentially deploying a
network function to detect mismarking of NQB traffic
6 Avoid Internal Remarking of DSCP Values if Possible: Try to
maintain DSCP 45 on an end-to-end basis with remarking
7. Acknowledgements
Thanks to Bob Briscoe, Mat Ford, Vidhi Goel, Sebastian Moeller,
Sebnem Ozer, Jim Rampley, Dan Rice, Greg White, and Yiannis Yiakoumis
for their review and feedback on this document.
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8. IANA Considerations
RFC Editor: Please remove this section before publication.
This memo includes no requests to or actions for IANA.
9. Security Considerations
RFC Editor: Please remove this section before publication.
This memo includes no security considerations.
10. Privacy Considerations
RFC Editor: Please remove this section before publication.
This memo includes no security considerations.
11. 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
12. 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
13. 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>.
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[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>.
[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-05, 26 July 2023,
<https://datatracker.ietf.org/doc/html/draft-ietf-tsvwg-
l4sops-05>.
[I-D.ietf-tsvwg-nqb]
White, G. and T. Fossati, "A Non-Queue-Building Per-Hop
Behavior (NQB PHB) for Differentiated Services", Work in
Progress, Internet-Draft, draft-ietf-tsvwg-nqb-19, 26 July
2023, <https://datatracker.ietf.org/doc/html/draft-ietf-
tsvwg-nqb-19>.
[I-D.ietf-tsvwg-dscp-considerations]
Custura, A., Fairhurst, G., and R. Secchi, "Considerations
for Assigning a new Recommended DiffServ Codepoint
(DSCP)", Work in Progress, Internet-Draft, draft-ietf-
tsvwg-dscp-considerations-13, 3 March 2023,
<https://datatracker.ietf.org/doc/html/draft-ietf-tsvwg-
dscp-considerations-13>.
[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-06, 13
May 2022, <https://datatracker.ietf.org/doc/html/draft-
briscoe-docsis-q-protection-06>.
[BITAG] Broadband Internet Technical Advisory Group, "Latency
Explained", 10 January 2022,
<https://bitag.org/documents/BITAG_latency_explained.pdf>.
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[Lotus] Eckerseley, P., "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-
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Livingood Expires 31 March 2024 [Page 14]
Internet-Draft ISP L4S Deployment Design September 2023
Author's Address
Jason Livingood
Comcast
Philadelphia, PA
United States of America
Email: jason_livingood@comcast.com
Livingood Expires 31 March 2024 [Page 15]