This is essentially identical to what we're already doing with our legacy rate limits. The most direct way to get this done is to haul the Renewal detection up from the legacy implementation in the RA to the WFE. Then pass the result of this check through to RA NewOrderAndAuthz method using a new RPC field so it can still be excepted from the legacy rate limits. If we do add a new RPC field track a TODO to its removal along with the legacy rate limits implementation.