These comments should be between two and three pages, and it should include a paragraph on your thoughts about how your comments will be received and whether or not they will have an impact on the regulation/standard, etc.
1.2: Develop coherent paragraphs or points so that each is internally unified and so that each functions as part of the whole document or presentation.
1.6: Follow conventions of Standard Written English.
2.5: Develop well-reasoned ideas, conclusions or decisions, checking them against relevant criteria and benchmarks.
5.3: Support policy decisions with the application of specific cybersecurity technologies and standards.