Comment by invalidator

If the write-cache is reordering requests (and it does, that's the whole point), you can't guarantee that $milliseconds will be enough unless you stop all requests, wait $milliseconds, write your commit record, wait $milliseconds, then resume requests. This is essentially re-implementing write-barriers in an ad-hoc, buggy way which requires stalling requests even longer.

Flush+FUA requires the data to be stored to non-volatile media. Capacitor-backed RAM dumping to flash is non-volatile. When a drive knows it has enough capacitor-time to finish flushing all preceding writes from the cache, it can immediately say the flush was completed. This can all be handled on the device without the software having to make guesses at how long something has to be written before it's durable.