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 Minnesota APA requirements (Minn. Stat. § 14.001 et seq.) (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]
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