Comment letters are in my job description. But, whatever we write, we ask for suggestions and input from the business unit managers. Lucy's comments are right on, this trips my soapbox too! I view comment letters as your golden opportunity to make a difference; and if you choose to let that chance slide, then I think sometimes we don't like the results. One other thing that we do to try to make this as painless as possible for the business unit managers, is to advise them of the comment period when the proposal is issued, and then two or three times prior to the expiration date we remind them of the date. Sometimes, it even helps to set up a meeting (lunch, whatever) with them to get their thoughts.