SWIP weirdness

The new ARIN SWIP template confuses me. The reassign-simple I sent in
lastnight came back with:

Fail to Pass Validation. Error Message:
    *PUBLIC COMMENTS can not be removed

I had:

9. Customer Country Code: US
10. Public Comments: NONE

END OF TEMPLATE

And the docs say:

PUBLIC COMMENTS SECTION (Optional)

10. If there are any comments that you would like publicly displayed in
    WHOIS regarding this registration, detail them here. If you wish to
    remove the publicly displayed comments from WHOIS, enter NONE.

Where's the misunderstanding?

Mr. Zeier,

I have just review the template you submitted. The error listed below was
generated because the template you submitted was a NEW. The NONE feature
is used to remove existing public comments. We will modify our software to
be more forgiving in the future. BTW, Registration Services has
successfully processed your template, and you should have a confirmation
in your inbox.

Ginny Listman
Director of Engineering
ARIN