The problems with QOS being applied to the download side are a CPU limitation issue.
That issue is not going to exist on a 22/1.5 DSL line.
You'd have to get close to 70-80Mbps combined to hit that limit on a ERL or ERpoe. The ERX QOS limit is even higher somewhere around 120-140Mbps.
The suggested changes DcUK made for a lower bandwidth DSL line are a reasonable starting point.
For example I use a 20ms target. Other than my first hop I NEVER see a sub 20ms latency.
In case you wanted to know my first hop is 18ms.
But my custom tuning keeps my latency generally below 24ms, which is my opinion is a good delta.