I appreciate your raising awareness of this comment period.
One concern that exists for DoH / DoT (or even DoQ) usage, is with respect to providers - that one trusts the provider on what they might be intervening with. Typically, this is about what they are blocking and why. I suspect the focus is rather significant things being BLOCKED, but how much attention is there on the things that they might ADD? What is to prevent a DoH provider from injecting their own TLDs or alternative roots at the top level outside of the MSM processes and/or circumnavigating the i* vetting processes like were used for .onion or other special use TLDs?
As many of the DoH providers are private and/or proprietary, something akin to the commitment Mozilla adheres to for the Public Suffix List, where things that are not compliant with the ICP-3 Document [
https://www.icann.org/resources/pages/unique-authoritative-root-2012-02-25-en] or have been vetted through IETF/IAB et al I* are excluded. This helps with continuity with respect to the root and TLDs that the resolution process will (or won't) support.
If DoH providers pledge to only resolve the items in the ICP-3 root or those strings carefully vetted via I* processes, and furthermore pledges to mute or block any traffic from strings that are non-compliant being sent out to the root nameservers, this would aid in a better measurement of Name Collision data, and perform the valuable function of controlled interruption in advance of the coveted next round, while playing a valuable service in improving what outcomes we might see from things like Name Collision noise measurement at the root.
-Jothan