The functional test for this tool fails. Looking at the XML wrapper, it looks like $comments is invalid....it doesn't exist anywhere else in the xml file. I know that comments can be specified multiple times however there is no way to get the comments fields to appear multiple times in the UI as far as I can tell. So, I changed it from

#for $element in $comments:
COMMENT="${element.comment}"
#end for

to

COMMENT="${comment}"

and the functional test passes.