Thank you for the opportunity to comment on this draft regulation.  Our comments are as follows:

1. On line 2966, it appears this line numbering should be changed from a (g.) to a (17) to align with current E&S minimum standard 17
2. On line 2975, it appears this line numbering should be changed from a (h.) to an (18) to align with current E&S minimum standard 18
3. On line 2981, it appears this line numbering should be changed from an (i.) to a (19) and all subsequent line numbering should be updated accordingly to align with current E&S minimum standard 19