Well, for one, someone mentioned guest-posting. But then, guest-posting where? What if the blog is iffy? Would PA/DA give a solid indication of this kind of thing?
Or, for example, I know to stay away from "buy 40 bajillion backlinks for $3" and such, but what about an offer for an individual backlink from a high PR page, manually added potentially in the context of a guest post? Part of me thinks "okay, seems reasonable", but part of me thinks "if this is being offered then could the fact that it's being offered to others then pose an issue based on the appearance of high volume"?
Also: if there is the potential for "negative" SEO, wouldn't this be easily abusable? What's to stop me from blasting 60000 backlinks to one of my competitors?