Currently there appears to be no character or word limit for comments. Per this KB article, comments of 20,000 characters will still display on Report Cards, but we would like to control just how much teachers can write for these.
I envision the easiest and most flexible method would be to add a checkbox when creating a grade plan grade that identifies it as a comment. Once selected, this would allow us to choose between a character or word limit and enter a value for this. This way any grade plan group the grade plan grade is assigned to will apply these settings.
I suggest the above so that we could say that for a mid-semester comment grade plan grade the character/word limit is X while for semester comment grade plan grade that the character/word limit is Y.
Additionally, when teachers are entering comments in the text field within Grading, show the configured character/word number (ex. 0/2000 characters, 0/200 words) ratio so they can clearly see the limit and how many characters/words they've already entered.