some concerns:

        DS only works in snapshot code.  And the publicly availble
        snapshots have known, serious operational problems. We -REALLY-
        need more stable code before committing this to production.

        there are some indications from the root testbed that there
        are fatal interactions with some released versions of DNS
        code.  further controlled testing should be done.

        the selection of RIRs.  RIRs -DO- have the DNS as a primary
        field of activity.  (see in-addr.arpa.) The holders of
        forward space (.SE, DE, NL, etc.) become disinfranchised
        "customers". 

        "sufficient number" and "out-of-band" are concepts that
        really need some concrete recommendations.

        key duration should be better fleshed out. Experiences from
        the existing testbed may be useful.

        key publication methods have been explored but do need further
        work.  

%    The same is true for the need for operational experience with a
%    signed root zone. There is no method of acquiring this experience
%    except by signing the root zone, so that is what is being proposed.

        this is not exactly true. 
        and your risk-analysis does not exactly match empirical evidence.

--bill

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