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"initial comment" is correct and usable in written English
It is commonly used to introduce a statement or comment. For example, "Initial comment: I think the new policy is a great idea."
Exact(37)
An army spokeswoman had no initial comment.
There was no initial comment from the government about the extent of the action.
Ergo, it would appear that said person making the initial comment does not technically have jurisdiction.
Then, tempering her initial comment, she continued, "You may actually change some hearts.
So we're pretty rare, if not quite as alien as that initial comment suggests.
The Down's Syndrome Association DSAA) issued a response to Dawkins's initial comment.
Similar(23)
The clarification was far more worrisome than his initial comments.
Her initial comments drew a sharp rebuke from China but she denies she overstepped the mark.
A few days after her initial comments, Firea tried to clarify her position.
Palestinian spokesmen, in their initial comments, properly kept aloof from the Israeli domestic fray.
But, as ever, the damage from his initial comments could not be undone.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com