I took a look at parts of Certainly's CP/CPS.  I'm happy to see
Certainly use a combined CP/CPS.  However, section 3.2.2 says:

"Certainly validates domain control primarily in an automated fashion
using the ACME protocol. In exceptional cases control may be validated
using methods similar to those employed by ACME, but performed
manually."

The BRs permit the ACME methods.  The BRs do not permit CA-invented
methods that are "similar to" ACME methods.  This is the same as the
forbidden "any other method of confirmation", and relies on trusting
the CA's judgment that the methods "similar to" the allowed methods
are as secure as the allowed methods themselves.  It should be
very clear that the BRs no longer permit CAs to make this judgment call.

I agree with Sleevi: Mozilla should not extend trust to a new
organization until it completes the normal, full review process. As
shown by this security-critical omission by GoDaddy, Mozilla cannot
rely on the "due diligence" of another CA to substitute for Mozilla's
own process.

Regards,
Andrew

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