[cabf_validation] Revision to OU requirements

Thu Sep 24 06:59:27 MST 2020

Hi Christian,

I'm not sure I understand your point here. The CA/Browser Forum is a
discussion forum for browsers and CAs to discuss product requirements for
browser products. While I agree that PKI technologies are used in a wide
variety of use cases, proving how general purpose the technology is,
there's no requirement that they all use the same CA infrastructure.
Indeed, as the industry has shown consistently, both in terms of standards
evolution and in response to security incidents, there are ample harms from
using the "same" certificate hierarchy. That doesn't mean a single
organization can't operate multiple hierarchies, but we should be careful
to not mistake PKI hierarchies as general purpose, because they are not.

In this model, it helps to think of PKI like JSON or XML: a general purpose
technology for expressing attributes, but specific uses of it (e.g.
specific APIs or service endpoints) will define their own requirements on
how that general technology is used. Much like it would be strange to think
of an API for listing, say, shopping products, use the same structure and
format as an API for managing smart meters, we can substitute "API" for
"PKI" and get the same conceptual clarity about why they are fundamentally
different.

As it relates to the question I asked of Michelle, which you're replying to
here, it appears the relevant standards document is WEQ-012, developed by
NAESB, and recognized by FERC. In that case, it would appear there is
limited to no risk of the removal of OU creating incompatibility, because
it appears the specification for the NAESB PKI within WEQ-012 is already
incompatible with the specification for browser PKIs within browser root
store requirements and the Baseline Requirements. Of course, I'm certainly
hoping Michelle can share more details, such as a readily attainable public
version of the most recent version, to facilitate further discussion.

On Thu, Sep 24, 2020 at 5:26 AM Christian Heutger <ch at psw.net> wrote:

> Hi,
>
>
>
> SSL/TLS certificate usage is much wider than only for Web Sites, primary
> they are server certificates. Similar to client certificates, which may be
> S/MIME certificates, user certificates, signing certificates on machines,
> clients or gateways. The view here seems sometimes a bit to reduced, but
> has larger impact as sometimes recognized.
>
>
>
> Regards,
>
> Christian
>
>
>
> *Von: *Validation <validation-bounces at cabforum.org> im Auftrag von Ryan
> Sleevi via Validation <validation at cabforum.org>
> *Antworten an: *Ryan Sleevi <sleevi at google.com>, CA/Browser Forum
> Validation SC List <validation at cabforum.org>
> *Datum: *Donnerstag, 24. September 2020 um 00:11
> *An: *Michelle Coon <Michelle.Coon at oati.net>, CA/Browser Forum Validation
> SC List <validation at cabforum.org>
> *Betreff: *Re: [cabf_validation] Revision to OU requirements
>
>
>
> Thanks Michelle,
>
>
>
> This is really useful! However, it's not clear to me why the wholesale
> electric industry is using browser-based certificates. The discussion here
> would only be regarding those used as part of browser/OS, and surely these
> devices aren't using the same trust anchors, given the risks, right?
> Certainly, using a dedicated trust anchor for different compliance regimes
> has long been understood as good practice, at least within the Forum, as we
> saw first-hand with 1024-bit RSA and SHA-1.
>
>
>
> Given the size and depth of this information, could you perhaps provide a
> more specific reference? Looking through FERC 888, 889, and 2222, I don't
> see any specific references to organizationalUnit. Perhaps I'm overlooking
> something, however?
>
>
>
> On Wed, Sep 23, 2020 at 3:59 PM Michelle Coon via Validation <
> validation at cabforum.org> wrote:
>
> OATI has the following comments regarding the OU field discussion:
> The wholesale electric industry currently uses the optional OU field in
> the certificate string of client certificates to identify a specific
> organization unit having authority to conduct business transactions as
> allowed under regulatory requirements promulgated by the Federal Energy
> Regulatory Commission (FERC). In FERC Orders 888 and 889, utilities were
> required to isolate business units for purposes of sharing transmission
> grid information. Transmission and wholesale energy trading business units
> in all major U.S. grid interconnections, Western, Eastern, and ERCOT, are
> required to be broken up into separate business units for different
> activities. Different units must be completely "brick walled" from each
> other, and operate as different entities even though they are still
> technically sub units of the same company. For more than 20 years, OU field
> has been and is currently used by energy industry entities as an integrated
> business process to clearly and distinctly identify the specific
> organization unit associated with discrete certificates in compliance of
> FERC Orders 888 and 889. Additionally, with the recent FERC Order 2222, the
> use of the optional OU field in the certificate string may be expanded as a
> business practice to the distribution/retail level of power entities as
> integrated into energy markets of North America.
> Removal of the optional OU field in the certificate string would cause
> disruption of current business practice in the energy industry of North
> America. Specifically, removal of the optional OU field would prevent
> energy industry entities from clearly and distinctly identifying the
> specific organization unit associated with discrete certificates, thereby
> compromising their compliance with U.S. federal regulatory mandates.
> Additionally, it would require energy industry entities to modify their
> current business processes, requiring time, staff, and resources.
> The OU field in the certificate string is optional and should remain
> optional, to accommodate all organizations-those that use the optional OU
> field as part of their established business processes, as well as those
> organizations that do not use the optional OU field.
>
> Michelle Coon
> Associate Director, Compliance
> Phone: 763.201.2000 <(763)%20201-2000>
> Fax: 763.201.5333 <(763)%20201-5333>
> Open Access Technology International, Inc.
> 3660 Technology Drive NE, Minneapolis, MN 55418
>
>
>
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> -----Original Message-----
> From: Validation [mailto:validation-bounces at cabforum.org] On Behalf Of
> Kurt Roeckx via Validation
> Sent: Monday, September 21, 2020 3:47 PM
> To: Ryan Sleevi <sleevi at google.com>; CA/Browser Forum Validation SC List <
> validation at cabforum.org>
> Subject: Re: [cabf_validation] Revision to OU requirements
>
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>
> On Mon, Sep 21, 2020 at 02:01:20PM -0400, Ryan Sleevi via Validation wrote:
> > Can you clarify: Was this at the request of BCSS (the "server", in
> > their
> > parlance) or in the use of TLS certificates as client-auth certificates?
> >
> > This appears to be detailing a very specific mutual-TLS authentication
> > flow, and it's unclear whether or not a browser-used CA is essential
> > for this.
>
> Reading the document, it says that the KSZ/BCSS/CBSS has 3 certificates
> (TLS server, TLS client, TLS client to sign documents), and depending on
> the communications, one of the 3 is used. Clients wishing to authenticate
> them should get the certificates. Clients should also send their own
> certificate to KSZ/BCSS/CBSS.
>
>
> Kurt
>
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