When a proposed FCC action is publicized, but there is no filing number yet, there is no way to record a comment.
When the news media publishes a potential FCC hearing or action, but there is no filing number published yet, it would be good to have a way to record public comments during the period when our interest is highest because of the news coverage. At present, no filing number means there is no way to make any comment. As an example, there is a proposed Time Warner-Comcast merger. But there is no way to comment on it on your website.