denial of service risk
To prevent trivial dos attacks where an attacker with a single IP generates several new relay fingerprints until the entire AS is blocked from adding new relays for a few hours these relays should come from distinct IP addresses.
That actually opens a possibility to bypass the entire rate limiting by creating all keys with a single IP and then distribute them to the actual IPs, but it would still be limited to 2x24 new relays/fingerprints per day.