On Thu, Feb 17, 2022 at 1:10 AM 'Brittany Randall' via
[email protected] <[email protected]> wrote:

>
>
> This email begins a 3-week comment period, after which Mozilla is expected
> to consider approval of GoDaddy’s request.
>
My individual position would be that GoDaddy does not perform this signing
unless, and until, https://bugzilla.mozilla.org/show_bug.cgi?id=1727941 is
resolved with a positive disposition.

I think there's wide agreement and understanding that the security risks to
the community, and to end users, remains, at minimum, the same whether
introducing a root or an intermediate, as they both have the same
capability. Cross-signing an intermediate versus adding a root largely only
functionally differs in that rather than Mozilla and the community
reviewing the CA-to-be-signed, the cross-signer performs that review. I
don't think we have reason to be confident in the general case that CAs are
effective at upholding the same principles or thoroughness as the current
Mozilla process was designed to engage and promote. I don't mean this as a
slight against GoDaddy, but rather the general principle.

The public review policy for intermediates was designed to address this
gap, by ensuring intermediates and roots undergo the same level of public
review and consideration. It applies for two cases:
1) Where the CA-to-be-signed does not plan to operate as a root
2) Where the CA-to-be-signed does plan to operate as a root (as is the case
here)

Strangely, 1) is a bit academic, because there's very little compelling
reason to pursue that path given the above considerations, so it's not
surprising that we find ourselves in 2).

However, this means that the cross-sign review period is, in effect, a way
to "jump the queue", as it were, bypassing the priorities applied to CA
review in order to get to a state where certificates work with Mozilla
products (and broadly, the ecosystem). It's difficult to imagine a scenario
where a positive dispensation is given to a cross-signing, but then later
rescinded for the root; and, in that case, one would expect (as has
happened in the past), that the cross-sign itself would then be prohibited
as well.

On the upside, the suggestion here is that GoDaddy has reviewed Certainly
to a level that they are satisfied, and given the substantial risk that
GoDaddy would be embracing, it might be reasonable to allow the queue jump
on the principle that GoDaddy is vouching for Certainly. On the downside,
there's likely a form of remuneration involved here, so it may simply be a
"pay for play", except that GoDaddy is the beneficiary for such scheme.

It's possible for both of these things to be true, and I don't mean to
suggest that they are morally correct or incorrect, but it's worth careful
evaluation when considering the next steps. Certainly is not yet to the
public discussion phase, indicating that there are still a number of
factors to occur, including the detailed CP/CPS review. To try to "do this
right" would suggest that this process be compressed, and where normally
there would be three weeks of discussion *after* a lengthy discussion with
the CA in question (Certainly), that this all happen within three weeks.
Alternatively, it's to suggest that these things are not actually essential
for CA Root Inclusion, since it would be granting Certainly the same
privileges without these having occurred.

I say this as someone who suspects that Certainly is in good hands,
especially given the stakeholders involved, which notably includes former
Mozilla CA Certificate Policy Owner Wayne Thayer. I realize that, in the
absence of a cross-sign, the widespread interoperability is not yet
achievable. However, it seems to be a feature, not a bug, to ensure a
process of multi-stakeholder review and comment occurs, and that's why I
think coupling the cross-sign to the dispensation of
https://bugzilla.mozilla.org/show_bug.cgi?id=1727941 is an ideal outcome.
It does mean that the benefit of a cross-sign is reduced from "skips the
root inclusion phase" into one of "updates quicker than a new Firefox
release, and works with those that haven't yet updated", but that's still a
hugely valuable outcome, and hopefully not too unreasonable a burden.

>From a prioritization perspective, it might be reasonable to consider
"Another CA has expressed a willingness to cross-sign" as a reason to
prioritize a given CA higher, precisely because it's a CA willing to risk
their reputation for the to-be-signed entity, and thus we can expect some
degree of self-interested due diligence. I have no objections to doing that
in this case, and further discussion later for any gotchas about making
that a general policy principle. But that would still suggest some period
longer than three weeks, to allow for the detailed information gathering
and CP/CPS reviews, and to treat Certainly as any other root from a
policy/process standpoint.

Knowing Wayne's familiarity with policy and practices, I suspect this would
be a hopefully very streamlined process, as there have been for other CAs
(e.g. Amazon Trust Services) in which long-standing mdsp participants were
involved in the design and establishment. That said, we also have
counter-examples, in which CAs with long-standing participants repeatedly
demonstrate failures to adhere to the minimum expectation, so it's not a
guarantee, just a suspicion :)

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