Yes, that's what I measured. For analysis, I added some debug outputs
to
the phy reset and the 1st phy register access. And as I can see, the
phy register access happens when userland sets up the network:

Please repeat the measurements with NFS root.

You will find that the kernel brings the interface up right have
register_netdev() is called, and starts transmitting. It can happen
before register_netdev() even returns.

	Andrew