Dear authors,

I could finally find some time to make a more thorough personal (chair-hat off) 
preliminary review on this document.
Here are my comments:

First of all, I think everyone knows I’m a big fan of automating DNS 
provisioning processes and I would very much like this effort to succeed, so 
thank you to the authors for this attempt. However:


Abstract:

"When the domain uses DNSSEC it necessary to make regular”

Nit: I think the word "is” is missing here?

" This document describes a simple protocol that allows a third party
   DNS operator to update DS records for a delegation, in a trusted
   manner, without involving the Registrant for each operation.  This
   same protocol can be used by Registrants.”

This sounds dubious. Is the registrant involved or not?
I would say:

" This document describes a simple protocol that allows any
   DNS-operator to update DS records for a delegation, in a trusted
   manner, without involving any intermediate administratieve entities between 
the DNS-operator and the parent.”


1. Introduction:

"After a domain has been registered, one of three parties will
   maintain the DNS zone loaded on the "primary" DNS servers: the
   Registrant, the Registrar, or a third party DNS operator.”

I object to this phrasing, as it suggest an entity performs it’s role as 
DNS-operator as part of another role he might play. It’s always the 
DNS-operator and only the DNS-operator that maintains the DNS zone.
An entity can act as both registrant AND DNS-operator, registrar AND 
DNS-operator, or as a standalone DNS-operator, but an entity never maintains a 
zone in any other role than as DNS-operator. They should be clearly separated 
to keep roles and entities clearly defined.
This whole section need a thorough review on definitions of roles and entities 
performing multiple roles.


2.1. Definitions:

"After a domain has been registered, one of three parties will
   maintain the DNS zone loaded on the "primary" DNS servers: the
   Registrant, the Registrar, or a third party DNS operator.”

Again, BY DEFINITION a registrar NEVER IS a DNS-operator, and a registrant 
NEVER IS a DNS-operator.
A DNS-operator is a role that may be performed by an entity that ALSO acts in 
an administrative role as registrar, registrant, or neither.
Registrars and registrants are administrative roles, not technical and not 
entities. The only way to solve this is to make a DNS-operator an 
administrative role as well, separate from any other RRR role.
I can probably help with some text here. Please read section II-B of this 
whitepaper for inspiration: 
https://www.sidnlabs.nl/downloads/wp_2013_EPP-keyrelay_v1.en.pdf


3.2 Establishing a Chain of Trust:

This is the section where I have most problems with.
The bootstrapping of a secure delegation can never be done over an insecure 
channel such as DNS without a chain of trust for polling the initial key.
Unfortunately, I have not followed the discussions for RFC8078, but when I read 
that now, I think paragraph 3.3 and 3.5 from RFC8078 are a terrible mistake 
security wise, and a downgrade from previous practice. I believe that insertion 
of the first key at the parent should always have been over a secure channel, 
or confirmed over a secure channel, and in the absence of a chain of trust in 
DNS prior to a secure delegation, the only way to do that is over the secure 
administrative channel such as EPP or another proven secure channel which DNS 
without DNSSEC validation is not.
I challenge RFC8078 that it probably had too little review from security folks, 
and I don’t want to make the same mistake here, which makes it even less secure 
by saying "Once the Registrar sees these records it SHOULD start acceptance 
processing.”
No way. It should never accept a security proof or security inception process 
over an insecure channel.

Also, the introduction of this document only states "Update DS records” which I 
agree with, but Establishing a Chain of Trust is not updating but bootstrapping.

4.1 Authentication

This chapter starts correctly with mentioning of publication of CDS/CDNSKEY 
records, but continues from section 4.2 onwards only mentioning CDS ignoring 
explanation what happens with CDNSKEY.


Other comments:

There are still some sections in this document that contain placeholders for 
text.
In it’s current form, I challenge the intended status of "standards track”. I 
would say it reads more like a problem statement with it’s proposed processes 
to solve issues of inconvenience rather than a document that defines a BCP or 
makes definitions.
I’d say there is still work to do, and I can probably help with some 
definitions, but let’s first start the discussion on what this document wants 
to define.

Regards,

- --
Antoin Verschuren

Tweevoren 6, 5672 SB Nuenen, NL
M: +31 6 37682392





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