Per Roger's questions,
The FDA and other e-cig prohibitionists chief goal will be to get FDA to issue the Final Rule while Obama is still in office (as many/most newly elected presidents push their own regulatory agenda, and often scrap those of the preceding administration).
So our key goal must be to prevent the FDA from issuing a Final Rule while Obama is in office. The best tactic to delay the regulatory process is to request more than 75 days to submit public comments (especially since it took dozens of FDA staff and lawyers nearly three years to write the complex 241 page proposal).
If Republicans win control of the US Senate in November, the Obama administration will sharply scale back its huge regulatory agenda (which will significantly increase our chances of preventing Obama's FDA from issuing the Final Rule), as Durbin, Brown, Blumenthal, Boxer, Markey, Merkley will lose control and much of their influence (to lobby for the FDA deeming reg, increase e-cig taxes, and ban e-cig advertising).
That seems like an excellent approach. Who would have the standing to push for extension of that public comment period? Also, what is the likelihood that they would grant such an extension?