Agreed with last point. Though we respondents can link to studies, and I'm sure CASAA will suggest as much.
As I've said elsewhere, I think any response that is citing (legitimate) scientific data ought to go to a database in addition to FDA so it is made abundantly clear that (back) in 2014, FDA was given a substantial amount of commentary regarding available 'data' and 'research' regarding what they said they were seeking info on. Otherwise, it could be later in 2014, or sometime in 2016, or perhaps still in 2025 that FDA claims 'to date, we have not seen any evidence (whatsoever) that helps us understand the effects eCigs will have on the public health.' And they could tell bald faced lie of 'we asked for this in our comment period, but no one provided that' or what was provided was not legitimate.
I see science as on our side, and I think FDA knows this, but has been able to play a game of sorts of not acknowledging that for various reasons (namely, because ANTZ controls TCA narrative). This proposal does open the door, and I'm sure us CASAA types will provide that, but if we are all so distrusting of FDA come time of actual rules/enforcement, then I'm not sure why anyone would be trusting of FDA collection process of commentary. If I write response that cites 11 scientific studies and have a rambling philosophical message as well (no seriously, I sometimes ramble), then I'd just copy and paste the scientific portion and submit to this large database that shows that yes, I was one of the respondents, and here are the linked research items that I submitted to FDA.
I'll say this. They're probably still stinging from the beating they got in the courts. That may be a factor. ...but emphasis on 'may'.
Another scenario could be - they put out the worst case scenario - when all they really wanted was a tax. And even if it's a heavy tax, if they leave all else alone, then many will be 'satisfied'*. And CASAA can say: they prevented a ban. It wouldn't be the first time for such a scenario. NRA has done it on a few occasions and there are many more - many leftist groups also can relate to that.
*even then, a black market will form.
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