I think this is important work.   I have to confess that I haven't followed the 
development of this draft, so this may be an observation that's already been 
addressed, but I'm concerned that there's nothing in this document about 
ensuring that the negative trust anchor is trustworthy through validation other 
than through the X.509 CA infrastructure currently used for TLS.

The problem with this is that it means that a compromised CA (of which there 
have been a number recently) can be used as an attack on the DNSSEC validation 
chain.   In addition, some CAs have been known to issue Certs for the express 
purpose of circumventing privacy and authentication features of X.509 certs.

DANE has recently published documents that leverage the DNSSEC infrastructure 
to protect organizations that have implemented DNSSEC from X.509 PKI attacks.   
If you use that same PKI to validate negative trust anchors, you're effectively 
invalidating the security model of those RFCs.

I think therefore that using X.509 certs as negative trust anchors is a really 
bad idea, and I would suggest that it might be worth proposing a mechanism in 
your draft that does not rely on such trust anchors.

I would suggest that the right solution is to rely on the DNSSEC security 
infrastructure to publish negative trust anchors, rather than relying on 
RFC5280.   I realize that this means more work, probably for DNSEXT, the chairs 
of which were hoping for a vacation after completing their current work, but I 
think this would be a much better option nevertheless.

Again, sorry if I'm misunderstanding what you're proposing.

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