I've read the document and have a few questions.

In section 5 we say " A CA offering certificates to ".onion"
Special-Use Domain Names SHOULD strongly consider making their ACME
server available as a Tor  hidden services." I think this sentence is
a misuse of BCP 14 language, and "RECOMMENDED" is the right one to use
here as something a step down from should

Section 3.1.2 says that there are modifications to the http-01
challenge, but I'm not sure what they are. Then in Section 8 we learn
the challenge would fail. I'm a bit confused what is intended here. I
think what's supposed to happen is there is text spelling out that
http-01 is an instance of methods described in the BR 3.2.2.4.18
(https://cabforum.org/wp-content/uploads/CA-Browser-Forum-BR-v2.0.1.pdf),
and that now the CA goes and resolves the .onion, but I missed where
this got spelled out. Maybe it's a matter of a missing reference in
3.1.2, although I think some text is needed.

Sincerely,
Watson Ladd

-- 
Astra mortemque praestare gradatim

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