no, they are all valid transactions to users who just haven't been born yet
But you could just use OP_RETURN! Better: you could use OP_RETURN inside TapScript and just commit to the blockchain, instead of burning coins! There is no reason to burn anything, there is also no reason to bloat the chain. Another thing is that one commitment for the whole network would be cheaper than pushing every commitment for every user.
using OP_RETURN to store data in blockchains actually creates far more bloat then the method we are describing here.
the maximum amount of OP_RETURN data currently supported by the network per transaction is 80 bytes.... i think..

it has been awhile since i checked.
80 bytes limitation is only enforced by Bitcoin node though. If you're pool owner or can convince pool miner to add your transaction, OP_RETURN would create less bloat.