@SmokeyJoe - Last week I would've agreed with you completely. But the shift in ANTZ tactics referenced in post #12 is very disconcerting. Remember, they have insider info on this whole process. There must be a reason why they decided to go for quantity vs quality.
OTOH, it's clear to me, both from the deeming doc itself (give a brief read to Section IV.B), and also from Zeller's statements, that facts or science won't stand in the way of FDA on this matter. IMO, this is a move motivated by politics and money and has nothing to do with public health. I also know for a fact, from participating in a few of these regulatory decision-making processes, that unsupported opinion does actually count. As part of this process, FDA will have to prepare a summary of the comments and the ones in the "generic pile" will be summarized as the "public sentiment" with respect to the regs. I'd rather this "pile" weigh in our favor.
I do agree with you, however, that substantive, factual contributions should theoretically carry more weight than "generic" pro or con comments. That's why in each of my own micro-comments I highlight one particular topic and try to contribute sound science and interpretation in addition to strong opposition to the deeming.
Finally, I also agree that lobbying congress on the appropriateness of PACT remains a priority, as well as the FSPTCA, in particular the issue of the grandfather date.