Wayne, For TLS/SSL certificates, I think PKCS #12 delivery of the key and certificate at the same time should be allowed, and I have no problem with a requirement to delete the key after delivery. I also think server side generation along the lines of RFC 7030 (EST) section 4.4 should be allowed. I realize RFC 7030 is about client certificates, but in a world with lots of tiny communicating devices that interface with people via web browsers, there are lots of highly resource constrained devices with poor access to randomness out there running web servers. And I think we are heading quickly towards that world. Tightening up the requirements to allow specific, approved mechanisms is fine. We don't want people doing random things that might not be secure.
As usual, non-TLS certificates have a completely different set of concerns. Demand for escrow of client/email certificates is much higher and the practice is much more common, for a variety of business reasons. -Tim
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