Would it make sense to omit the word "Comment" and the single quotes from the initial name of a Comment Action?

I agree, but I also think this is a low priority change request for Keyboard Maestro.

I make use of @DanThomas' great KMFAM system to have a Comment Action preconfigured as I like it. I set the Action name, and leave the Action Title blank, in most cases.

I use this Macro routinely to change the Name of an Action: