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I'm not that bothered about minor amounts of packet loss (running at about 5% this morning)
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Hell's bells, I would be. Shouldn't be seeing any packet loss at the IP layer.
I doubt it would be upstream congestion, which is probably what the engineer was talking about, but I'll check if you send me your modem MAC. You can't actually move between UBRs individually, only as part of a resegmentation.