“I’m curious how many FReepers filed a formal comment against this rule during the comment period.”
That always does a lot of good.
Perhaps you could have someone read over your comments prior to submission? I’ve had a rather good success rate at getting changes made to proposed rules.
Obviously, this doesn’t mean that they can ignore the law they’re implementing, nor that they will totally fold, but remember that even if the comment suggestion isn’t incorporated, they’re forced to address it and it’s on the record.