Trying to put technical requirements like this into law and public policy is an extremely terrible idea. This letter should never be sent.
The regulatory agencies today don't have the manpower or expertise to adequately enforce the more generic broadband deployment rules. What fantasy world exists where they have the manpower or expertise to monitor for and enforce something like this? Hell, there are constant , legitimate technical discussions between experts on HOW to *properly* monitor things just like this. We want to have someone at the FCC deciding what that should look like?
4.4 What the hell? The regulatory agencies should be allocating spectrum, and making sure it's not used improperly with the rules of allocation. Making it work 'better' is OUR job in the technical community. Not an FCC rulemaker.
4.8 There are zero scenarios there should ever be regulatory rules about device software. In our space (non-ISP) , TONS of people run older versions of vendor code. Why? The shit DOESN'T WORK RIGHT YET and it causes other problems. You suggest that regulatory bodies be involved in dictating anything about this?
The bufferbloat work belongs in the technical area, full stop. Nowhere near regulatory / legal.