COMMENT ON PROPOSED RULE

To: [AGENCY NAME]
Docket/Reference: [DOCKET/REGISTER 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 Hawaii APA requirements (HRS § 91-3 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]

Hawaii-Specific Statutory References

• Hawaii Administrative Procedure Act: HRS § 91-1 et seq.
• Rulemaking procedures: HRS § 91-3
• Public hearing requirements: HRS § 91-3(a)
• Small business impact statements: HRS § 201M-2
• Judicial review: HRS § 91-14

[// GUIDANCE: For Hawaii rulemaking, submit comments in accordance with the agency's public notice published in the Hawaii Administrative Rules Bulletin and attend the public hearing if one is scheduled under HRS § 91-3(a).]