I would say that any individual owner should make comment if they feel they have some worthwhile comment to make. Similarly, if the EC, representing the OC as a whole, feels that there is a worthwhile comment to make in the interests of the entire OC or part of the OC then it should also submit a comment.
Anecdote: I recall an occasion when our local government called for comment on a development down the road from us. It was for a government building providing an important local service. One owner put in a negative comment and drew it to the EC’s attention hoping we would similarly object. We could see no negative effect on the OC, or logic to support the owner’s concerns. Indeed, we believed that the OC as a whole could derive a benefit from the availability of the service from close by without any negative consequence. We then submitted a comment welcoming the development.