, It's interesting that you interpret "Comment on" to mean that you wish to bring something to the attention of the 'powers that be'
As far as I am aware, the wording was picked because PM is not just a discussion board. It includes other types of node, such as code, polls, etc. You can't really reply to a piece of code (well, I suppose you can if it's a CGI script ;). The wording "Comment on" is generic enough to cater for all node types - if you can think of something better, please suggest it.
When it comes to the reply links, these only appear on notes, i.e. nodes which are themselves replies, for which replying always makes sense. If you go to one of these nodes (by clicking on the node title), you will find that the link you need to reply to this node is "Comment on ...".
Hope this helps
I'm Not Just Another Perl Hacker
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