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It seems like the core problem here is that certificates are considered part of infrastructure, and further that they're part of infrastructure that requires approval!

Clearly not all automated infrastructure requires approval: autoscaling groups spin up and tear down compute instances all the time. Further, changes to data can't universally require approval, otherwise every CRUD operation would require a committee meeting.

Are certificates truly explicitly defined to be infrastructure that requires change approval? If not, perhaps more careful interpretation of the regulations could allow for improved automation and security outcomes.



> Clearly not all automated infrastructure requires approval: autoscaling groups spin up and tear down compute instances all the time.

In these sort of environments, they do not.

We're talking about environments where it is forbidden to make _any_ change of any kind without a CCB ticket. Short cert lifetimes are fundamentally at odds with this. Luckily these systems often aren't public and don't need public certs, but there's a slice of them that do.




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