That's not my take. He's just saying that the linked document states > If your CA will not be revoking the certificates within the time period required by th

That's not my take. He's just saying that the linked document states > If your CA will not be revoking the certificates within the time period required by the BRs, our expectations are that: > The decision and rationale for delaying revocation will be disclosed to Mozilla in the form of a preliminary incident report immediately; preferably before the BR-mandated revocation deadline. The rationale must include an explanation for why the situation is exceptional. Responses similar to “we do not deem this non-compliant certificate to be a security risk” are not acceptable. When revocation is delayed at the request of specific Subscribers, the rationale must be provided on a per-Subscriber basis. However, letsencrypt's report neglected to do any of this, so he queried them on this