In reviewing the IANA registrations for this draft, I noticed a design issue 
that I think the working group needs to discuss more.

>From a strictly schema perspective, the whitespace normalization requirements 
>for token will likely have implications for usability of passwords that 
>include spaces on the <pw> and <newPW> elements.  That's a problem for 
>manually constructed messages, so it would be a minor comment.

However, that would ignore the fact that use of plaintext passwords is not a 
good practice.  Even if this is merely revising something from RFC 5730 to 
extend their length (which is fine in isolation), I think that the working 
group needs to more fully consider.  Though it remains common, relying on 
password-based authentication is generally regarded as a failing; though it 
might be unavoidable, most authentication systems try to avoid it, or only use 
passwords as a way to step up to something stronger.  Sending passwords in 
cleartext in protocols is regarded as a serious exposure in most systems.  Even 
passing hashed and salted passwords has risks that mean that is generally 
avoided where possible.

For a protocol of this nature, it seems like alternative methods could be 
developed.  And if passwords are unavoidable for usability reasons I can't see 
right now, then the CFRG is developing password-based authentication protocols 
that might be suitable for this.  Or there are protocols like OAuth that might 
allow for delegation.

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