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Thx for the laugh! No FCC regs demand sub 100ms latency, so unless you are taking a really big 24 hour average, that idea won't work.

However the technology exists to aim for 20ms - even 4ms - of both idle and working latency today, and the 100ms target - as well as the 95% cutoff for measuring latency, are nutty. It is not every day that key members of the ISP industry actually call for stricter metrics - If you cut the ISP working latency off at 99% instead - well, jason livinggood from comcast reported:

...

Looking at the FCC draft report, page 73, Figure 24 – I find it sort of ridiculous that the table describes things as “Low Latency Service” available or not. That is because they seem to really misunderstand the notion of working latency. The table instead seems to classify any network with idle latency <100 ms to be low latency – which as Dave and others close to bufferbloat know is silly. Lots of these networks that are in this report classified as low latency would in fact have working latencies of 100s to 1,000s of milliseconds – far from low latency.

I looked at FCC MBA platform data from the last 6 months and here are the latency under load stats, 99th percentile for a selection of ten ISPs:

ISP A 2470 ms ISP B 2296 ms ISP C 2281 ms ISP D 2203 ms ISP E 2070 ms ISP F 1716 ms ISP G 1468 ms ISP H 965 ms ISP I 909 ms ISP J 896 ms

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As for the insane 95% FCC working latency cutoff today - in terms of real time performance - what if, you got in your car, for a drive to work, and your steering wheel failed one time in 20. How long would you live? If we want a world with AR, VR, and other highly interactive experiences, 99.9% of no more than 20ms of consistent jitter and latency should the goal for the internet moving forward, and ideally, 4ms.




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