In response to the following concern raised by Andrew:

On Mon, Feb 21, 2022 at 11:06 AM Andrew Ayer <[email protected]> wrote:

> 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.
>
>
*The CP/CPS goes on to describe specific methods that are used by
Certainly. The language Andrew is pointing out is referring to the ACME
dns-01, http-01, and tls-alpn-01 implementations. It meant that Certainly
might foreseeably perform a manual 3.2.2.4.7 validation rather than using
Boulder’s dns-01 implementation. We’ve never done that, and given the
complexity of getting it right I’m confident that we never will. I don’t
agree that this is a “security-critical omission”, but I do see how this
language is concerning, so it has been removed from the latest version of
the CP/CPS that Ben reviewed.*
 - Wayne

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