I submitted a comment basically along the same lines, but focusing on rebutting particular claims in the FCC's notice:
Would be an interesting experiment to have a page to submit HN comments as posts (add a title, get a few ppl to recommend).
Just to be clear, it's not an "Express Filing", it's a "Standard Filing", which allows attaching a document (express just lets you paste in text, with no formatting--not even line breaks). Those are the only two options on the FCC's site for submitting filings.