According to the latest latest rate limit update the order of new issuances and renewals should not matter.
I assumed that means if i renew a large number of certs I can still issue 20 new ones for the domain within one week.
But it does not seem to work this way. I renewed 40 certs on July 27th and now tried to issue a new one and still get a “get too many certificates already issued” error. I checked all 40 certificates using crt.sh and all had a previous cert with the same set of dns names.