On Mon, 14 Nov 2016 06:00:24 -0800
Peter Bowen <[email protected]> wrote:

> > CT is getting to be very useful as a way of surveying the certificate
> > ecosystem. This is helpful to assess the impact of proposed policy
> > changes or positions, e.g. "how many certs don't have an EKU", or "how
> > many certs use a certain type of crypto". If certs under TCSCs are
> > exempt and this becomes popular, CT would become less useful for that.
> >
> > One possible answer is just to say: "Mozilla will not accept 'but we
> > have a lot of certs under TCSCs which will be affected by this' as a
> > valid reason not to do something. In other words, if you hide stuff and
> > it breaks, you get to keep both pieces. But in practice, such a line
> > might not hold.
> 
> I think this is the right answer.  Yes, CT has helped provide a better
> view into galaxy of CAs that is WebPKI, that was not its stated
> purpose.  CT was created to help domain registrants have visibility
> into what is issued for their domain names.

I disagree with your characterization of CT.  The first sentences of
RFC6962 say:

"Certificate transparency aims to mitigate the problem of misissued
certificates by providing publicly auditable, append-only, untrusted
logs of all issued certificates.  The logs are publicly auditable so
that it is possible for anyone to verify the correctness of each log
and to monitor when new certificates are added to it.  The logs do
not themselves prevent misissue, but they ensure that interested
parties (particularly those named in certificates) can detect such
misissuance."

Although issuing a certificate without the authorization of the domain
registrant is the most serious type of misissuance, it is not the only
type.  Apart from audits, TCSCs are subject to the Baseline
Requirements, and failure to comply is a type of misissuance that is of
interest to the Internet community, particularly to root store
operators and certificate validation implementers like Mozilla.

In any case, standards can provide unexpected benefits.  It would
be self-defeating to discount a benefit just because it wasn't
originally stated as a goal of the standard.

> If domain holders want to keep their certificates semi-private, then
> they need to be aware that security is a moving target and their
> input on data-driven decisions may be diminished.

Unfortunately, domain holders do not act rationally.  Just look at all
the domain holders who requested redacted franken-certificates from
Symantec for publicly-accessible websites even when it was immediately
apparent that such certificates do not work in Chrome.  Domain holders
would likewise fail to take heed that certificates issued from TCSCs
might stop working at some point in the future, and probably in greater
numbers since the consequences of their actions would be more abstract
and less proximate.

Meanwhile, end users have no say over what certificate a site uses
and just want their browser to work.  No browser maker wants to break
sites for users.  The rule about ignoring TCSCs when making decisions
will surely be reverted the first time it causes widespread breakage.
Then we'll be back in the same situation we are in now, where the lack
of complete information makes it difficult to make changes that
improve the security and robustness of the Web PKI.

I appreciate the need for domain name privacy, but it must be balanced
against the needs of the public.  I find the label redaction approach
in draft-strad-trans-redaction-00 to be more balanced, as it hides only
the minimum amount of information needed to provide domain name privacy.

Regards,
Andrew
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