Your LMS doesn;t conform to the SCORM 1.2 standard then, which in this case is a happy situation for you. 4K is the limit. A lot do conform to that limit.
cmi.comments is another read write data field available to the courseware. The official definition is:
cmi.comments (CMIString (SPM: 4096), RW) Textual input from the learner about the SCO
Note it's read / write and is another 4K so basically 'doubles up' on the suspend_data field.
It's not something you could implement yourself (well you could with Javascript calls, but there would be no point as the suspend_data is still going to be used to store bookmarks currently as that is what Articulate decided). It is something that Articulate would have to implement in the back end.