General criticisms:
1 - Whole piece (all 14 parts) are very disorganized. Hard to understand the story being told, even while I find around 80% of it be data that is worthy of consideration.
2 - Piece isn't even written to FDA regarding regulations, as noted in post #18 of this thread. It is one big diatribe that is partially meant to convey the other side of eCig data (which FDA and cohorts seem to ignore) and partially about conveying the merits of smokeless tobacco as reasonable policy. FDA comments portal mostly just serves as a platform for which to share this diatribe.
More specific criticisms:
1 - The conclusion (found in part 14) says, "The scientific and empirical evidence has consistently found that e-cigs (and smokleless tobacco) provide significant health benefits for smokers and for public health, with negligible risks for users, no risks for nonusers." Because of my bias, I don't have strong disagreement with what this is saying, but do have some reasonable concern with how it is being conveyed. Because a story isn't being told well in the 14 parts, it is challenging to decipher where these "significant health benefits" have been cited. Based on word search of "benefits," most of it is based on potential and thus scientific opinion, not evidence. IMO, this is partially why I would find it easy to dismiss this commentary on whole as it presents an onslaught of data and then attempts to establish a conclusion where the dots have not been connected as well as they could have, or arguably not at all, depending on one's bias going in. Like if FDA had 50,000 words regarding "problems with tobacco use" and then concluded with "scientific evidence consistently shows significant hazards of eCigs" without making that connection. Those who want to believe eCigs have hazards will praise the 50,000 words that came before it as 'hard work' and 'great effort.' Those who understand reasoning will criticize the piece for not making that connection.
2 - Conclusion also says, "The evidence also consistently confirms that the FDAs proposed Deeming Regulation would protect cigarette markets, threaten the lives of millions of vapers and 45 million smokers, and give the e-cig industry to Big Tobacco companies by banning >99% of all e-cig products, including all of the most effective e-cig products for smoking cessation." And again, I am 80% in harmony with this type of propaganda, even while I think it is open to fair criticism. I've routinely questioned the greater than 99% claim and have already challenged Bill on this before plus challenged those who claim vaping products in neighborhood of 100K items or less. Reality is it is millions, given flavor combinations. I'm not sure why that doesn't register with those who claim to have knowledge on these matters but even in these comments from Bill it is presented as thousands. But more to the point, I am not seeing the way around this hyperbolic claim of "giving eCig industry to Big Tobacco companies." The solution offered up, as noted in the following paragraph is for FDA to not issue final rule and to apologize to all vapers. Yeah, that's going to work. That's being practical, reasonable. Would be like me expecting (or rather demanding) apology from Bill based on my spin of what he has written. Anyone reading this want to let me know when I should expect that apology? As I'm thinking it will never happen, then getting back to the point, when Bill had prime opportunity and much motivation to comment to FDA, his comment ended up being part of that which will plausibly hand eCig industry over to big tobacco companies while offering nothing practical to change that course.
We all should be familiar with his views by now and, as far as I can see, there's nothing new. I agree with him on certain points regarding dual use, but only from the view that people should have that choice, not that it's a healthy one, but disagree with him with regards to your full 'comment'. 
