*   Note that since the registration policy is "specification required", 
doing this in an extension spec instead would not require the consent of the 
IESG.

Right, which is how I prefer to see this move forward.  Putting it into the 
ACME doc, however, *does* require IESG approval.


  *   I think you're confused here, Rich.  This error code relates to *account 
keys*, not keys that are certified by the CA.

Not really, which is why I chose the example I did.
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