> To be clear, in the current spec, the new-app flow is not optional. 
> The new-cert endpoint has been eliminated, so clients have to be able
> to at least use new-app to request a certificate.
Right. To rephrase: If part of the rationale for new-application is that
some CAs want all validation to be connected to a CSR, then those CAs
won't be able to implement an independent new-authz flow. So the
new-authz flow is incompatible with one of the main reasons you proposed
a new-application flow.
>
>     The other motivation for the new-application flow was to provide a
>     framework that could support validation and issuance of wildcard
>     names.
>     However, the current spec doesn't actually go into detail about a
>     validation method for wildcard names.
>
>
> What else do you think is required for interoperability?  ISTM that
> the current spec captures most current and suggested practices,
> including everything from "validate the base name" to "validate some
> random subdomains" to "validate some WHOIS information" (via OOB). 
> I'm skeptical that we can define much more without ruling out some
> CAs' practices.
I think providing one "ACME-approved" process for wildcards doesn't rule
out existing CA practices, any more than the ACME HTTP-01, TLS-SNI-02,
and DNS-01 challenges rule out existing DV methods.

The CA/Browser Forum's recent Ballot 169 specifies that validating
control of a base domain is sufficient to issue a wildcard. But I think
folks have have expressed a feeling that that's not strong enough. ACME
hasn't hesitated to take a stance on challenge methods. Similarly I
think it would be worthwhile to say "this is the default ACME way to get
a wildcard, but you can also use out-of-band methods."
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