Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
What strikes me most is that, to this day, the reserved, non-routable IP address ranges were associated with unresolvable .local domains.
The logic was coherent.
With your proposal, you want to provide a *public* resolution of non-routable IP addresses: this means first and foremost a leak…
An attacker wishing to enumerate targets on a non-routable network will then be able to listen to DNS traffic to gather information about an otherwise unreachable network.