+1 to Ryan's comments.  The plan locks small CAs into being small while letting 
big CAs continue to dominate the market.  It basically prevents new CAs for 
even entering the market. 

-----Original Message-----
From: dev-security-policy 
[mailto:dev-security-policy-bounces+jeremy.rowley=digicert....@lists.mozilla.org]
 On Behalf Of Ryan Sleevi
Sent: Friday, March 6, 2015 6:40 PM
To: Richard Barnes
Cc: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: Name Constraints

On Fri, March 6, 2015 4:26 pm, Richard Barnes wrote:
>  Hey all,
>
>  I've been doing some research on the potential benefits of adding 
> name  constraints into the Mozilla root program.  I've drafted an 
> initial  proposal and put it on a wiki page:
>
>  https://wiki.mozilla.org/CA:NameConstraints
>
>  Questions and comments are very welcome.  There's a lot of details to 
> work  out here, but I think there's some significant benefit to be realized.

This seems unfortunate, especially given ICANN's efforts to extend the set of 
gTLDs.

While it might seem simple to argue from a security benefit, the reality is 
that it further ensures "too big to fail", by reducing the number of CAs that 
can issue for a given name.

If a CA wishes to extend beyond the assigned scope, it would now have a 1 month 
waiting period, although there will inevitably be a queue, and then have to 
wait for a 12-18 month upgrade period for projects that have used the name 
constrained roots.

We've already seen the negative effects this can have on roots wishing to 
migrate to stronger algorithms (ECC, SHA-2), in which they have to wait a long 
time in the queue.

Given that sites in consideration already have multiple existing ways to 
mitigate these threats (among them, Certificate Transparency, Public Key 
Pinning, and CAA), and that there are further proposed solutions to mitigate 
the risks (such as OCSP Must Staple), I'm curious what are the specific 
benefits you see versus the real costs for users and CAs.

While the CA costs are both obvious and somewhat mentioned above, consider the 
user costs. If there's a site that operates in multiple gTLDs (say, for sake of 
example, Google), the set of CAs they can now use are the set of CAs that are 
authorized to issue for the union of those domains, or they must issue and 
manage multiple certificates for multiple domains and manage them, their 
policies, and their expirations separately. As we know, many users of 
certificates complain the operational costs are a significant burden, and while 
ACME hopes to address some of them, it's also hopefully evident that it will 
fail to do so for some time.

What would you imagine the name restrictions for the major CAs to be? Or for 
Let's Encrypt's nascent CA? Presumably unrestricted, correct?

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