Summary: Has enough positions to pass.
Section 8 still has some TBD. These should be completed before the document is published as an RFC.
Thanks for a well-written draft. I trust the TBDs Alexey already mentioned will be addressed.
One purely editorial comment: I much prefer the use of the RFC numbers as reference keys, however, I know that this style is possible as well and I also don't know if there are any recommendations by the RFC editor for this. However, I can say that the other style (use of [RFCXXX]) is more common.
This citation does not appear to be used anywhere in the document, and RFC 5480 is not mentioned (at least, not by number): [PKIXECC] Turner, S., Brown, D., Yiu, K., Housley, R., and T. Polk, "Elliptic Curve Cryptography Subject Public Key Information", RFC 5480, March 2009.