Apologies for not getting to this sooner.

This is the SECDIR review, should be treated like any other comments. I think the draft has nits, but they should be readily fixable.

In the ASN.1 definition of the PUBLIC KEY structures on page 6 I am a bit confused by why the key can be throw in without additional wrapping. This is probably due to my ignorance of ASN.1, but I'm sure I'm not the only one. 

On section 5, it might be worth reiterating why the key usage bits need to be set the way they are.

Section 8 ignores the ecosystem impacts as private keys propagate across systems. It might be worth giving some guidance, to avoid unfortunate results.

Sincerely,
Watson Ladd