They may be in the form of a short statement or brief letter. However, comments may also be detailed documents prepared by an outside law firm or your company's in-house counsel. Although the Commission asks for comments or opinions, they really want arguments. Well-argued points are the most helpful to the Commission when it is writing new rules. In the end, new rules must stand the test of petitions of reconsideration by the parties involved, as well as court challenges.
Lawyers are great at arguing so they write a lot of comments.
The docket number is critical to make sure your comments are considered, no matter how you submit them. The Commission also accepts comments via email or fax. To encourage participation in the rulemaking process, the Commission is, in specific proceedings, encouraging comments to be submitted via electronic mail. If you cannot get your comments in on time this way, or if it is a choice of commenting informally or not commenting at all, please send your comments however you can and follow up with a phone call to ensure receipt. You should also be aware that in some instances the FCC has requested copies of comments to be filed on disk in addition to the paper copies.