Note that several us contributed comments to the rule making process the last time around to ask for an anti-circumvention exemption for space-shifting.
(We're in the
federal register, yea!)
Be aware that, while I'm sure that comments and logical arguments can't hurt, they made it clear that mere plain-language opinions were of no interest to them.
They want legal opinions and arguments formally addressing relevant matters of law (copyright, commerce, civil rights, whatever).
So we, as a community, would be much more effective if we hire a lawyer to draft a comment for us.