COMMENT ON PROPOSED RULE

To: [AGENCY NAME]
Docket/Reference: [DOCKET/FR NUMBER]
Subject: [RULE TITLE]
Submitted by: [NAME/ENTITY]
Date: [DATE]

1. INTEREST AND BACKGROUND

• Identify commenter, industry, and stake in the rule; brief credentials.

2. SUMMARY OF POSITION

• Concise summary of support/concern and key requested changes.

3. COMMENTS AND REQUESTED CHANGES

3.1 Specific Provision: [Cite Section/Page]

• Concern/Support: [Describe]
• Evidence/Analysis: [Data, studies, legal citations, economic impact]
• Requested change: [Proposed text or alternative]

3.2 Additional Provision (repeat as needed)

• Concern/Support: [Describe]
• Evidence/Analysis: [Data, studies, legal citations]
• Requested change: [Proposed text or alternative]

4. COSTS, BENEFITS, AND BURDENS

• Discuss compliance costs, operational impacts, benefits, and suggested adjustments to reduce burden while meeting agency goals.

5. LEGAL AUTHORITY AND COMPLIANCE

• Note statutory authority limits, consistency with enabling act, and APA requirements (notice/comment sufficiency, arbitrariness concerns if applicable).

6. CONCLUSION

• Reiterate key requested changes; offer to discuss with agency staff; provide contact info.

Contact: [NAME/TITLE/EMAIL/PHONE]