PUBLIC COMMENT LETTER ON PROPOSED REGULATION

[Full Title of Proposed Regulation]

Delaware Register of Regulations Reference: [CITATION]

Submitted To:
[AGENCY NAME]
[Office/Division, if any]
[Agency Address]

Submitted By:
[COMMENTER NAME] ("Commenter")
[Affiliation / Organization]
[Address]
[Email] | [Telephone]

Submission Date: [DATE]

TABLE OF CONTENTS

1. Document Header
2. Definitions
3. Executive Summary
4. Commenter Identification & Standing
5. Statutory & Regulatory Framework
6. General Comments
7. Section-by-Section Comments
8. Economic Impact Analysis
9. Alternatives & Recommendations
10. Procedural Requests
11. Reservation of Rights
12. Conclusion
13. Exhibits & Supporting Materials
14. Execution Block

1. DOCUMENT HEADER

This Public Comment Letter is submitted pursuant to the notice of proposed rulemaking published in the Delaware Register of Regulations in which the [AGENCY NAME] requests public comment on the above-captioned proposed regulation under the Delaware Administrative Procedures Act, 29 Del. C. Section 10101 et seq.

2. DEFINITIONS

"APA" means the Delaware Administrative Procedures Act, 29 Del. C. Section 10101 et seq.

"Commenter" has the meaning provided in the preamble above.

"Proposed Regulation" has the meaning provided in Section 1.

3. EXECUTIVE SUMMARY

• The Commenter supports the Agency's overarching goal of [STATE POLICY GOAL], but believes certain provisions warrant revision.
• Key recommendations include:
  1. Clarify scope of [SPECIFIC SECTION].
  2. Align compliance deadlines with practical implementation timeframes.
  3. Incorporate a de minimis exemption for small entities.

4. COMMENTER IDENTIFICATION & STANDING

4.1 Business Overview. Commenter is a [TYPE OF ENTITY] established under the laws of Delaware.

4.2 Interest in Rulemaking. The Proposed Regulation directly affects Commenter because [EXPLAIN NEXUS].

4.3 Authority to File. The undersigned is duly authorized to submit this Comment Letter.

5. STATUTORY & REGULATORY FRAMEWORK

5.1 APA Compliance. Under 29 Del. C. Section 10115, the Agency must provide notice and opportunity for public comment.

5.2 Delegated Agency Authority. Section [STATUTORY CITATION] authorizes the Agency to promulgate regulations.

6. GENERAL COMMENTS

6.1 APA Compliance

• Notice Adequacy and Reasoned Decision-Making analysis.

6.2 Policy Considerations

• Competitive Impact and Implementation Feasibility analysis.

7. SECTION-BY-SECTION COMMENTS

8. ECONOMIC IMPACT ANALYSIS

8.1 Cost Estimates. First-year and ongoing annual costs.

8.2 Cost-Benefit Comparison. Analysis of benefits versus costs.

8.3 Small Business Impact. Consideration of impact on small businesses.

9. ALTERNATIVES & RECOMMENDATIONS

• Adopt a tiered compliance schedule based on entity size.
• Utilize voluntary pilot programs.
• Coordinate with existing federal or industry standards.

10. PROCEDURAL REQUESTS

10.1 Extension of Comment Period. Request for supplemental comment period if materially revised.

10.2 Public Hearing. Request pursuant to 29 Del. C. Section 10115.

11. RESERVATION OF RIGHTS

Nothing in this Comment Letter shall be deemed a waiver of any procedural or substantive rights, including the right to seek judicial review under 29 Del. C. Section 10142.

12. CONCLUSION

Commenter respectfully urges the Agency to revise the Proposed Regulation as set forth herein.

13. EXHIBITS & SUPPORTING MATERIALS

• Exhibit A - Redline of Proposed Regulation Text
• Exhibit B - Economic Impact Study
• Exhibit C - Technical Feasibility Analysis

14. EXECUTION BLOCK

Respectfully submitted,

[COMMENTER NAME]
By: ___________________________
Name: [TYPED NAME]
Title: [OFFICER TITLE]
Date: [DATE]