In the rounds of reviews on https://github.com/ietf-wg-acme/acme/pull/445, I missed an addition: the suggestion to use capability URLs for access control on certificate URLs. We should definitely not introduce this into the spec: ACME has one authentication model, based on JWS signing. We shouldn't introduce another, weaker authentication model. I pointed this out way back in 2015: https://github.com/letsencrypt/acme-spec/pull/48#issuecomment-70169712.

At the time, the WG decision was to split resources into sensitive ones (authenticated) and non-sensitive ones (unauthenticated). The recent round of POST-as-GET changes consolidates things so nearly everything is authenticated. I don't think there's a strong case to introduce a new, halfway level of authentication based on capability URLs. If we want certificates to be authenticated, let's authenticate them the same way as everything else, and let the STAR group define an extension for unauthenticated URLs. Here's my PR backing out the change: https://github.com/ietf-wg-acme/acme/pull/457

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