In response to the FAA’s Notice of Proposed Rulemaking (NPRM) regarding Remote ID of small UAS, at least one national organization urged members to urgently file comments and helpfully provided a form letter – which as I showed previously – were submitted by many people. Submitting form letters is a waste of your time, as I explained then.
Here is what happened when another agency with another NPRM was overwhelmed with form letter responses from the public – they ended up ignoring most public input!
In 2017, the Federal Communications Commission (FCC) solicited public comments on proposed rules regarding Internet “net neutrality”.
The FCC received about 23 million public comments.
“For example, Ars Technica reported in May 2017 that 128,000 identical comments were submitted through the portal for receiving public comments on this particular matter.”Source: https://techraptor.net/technology/news/985-of-non-form-letter-fcc-comments-support-net-neutrality
In many cases, “bots” had harvested actual comments by actual people, and then generated dozens more comments using the same names and addresses of real people, creating false public comments.
“According to Pew Research, only 6 percent of the roughly 23 million comments submitted to the FCC were actually unique. The rest were a combination of form letters and bots. The most popular form, submitted 2.8 million times, was a pro-net neutrality comment drafted by the advocacy group Battle for the Net.”Source: https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/
The FCC was so overwhelmed with these garbage comments that, according to Wired magazine,
“As a workaround, the FCC has decided to ignore the majority of comments submitted by the public in favor of lengthy legal arguments submitted by interest groups and corporations.”Source: https://www.wired.com/story/bots-form-letters-humans-fcc-net-neutrality-comments/
The above is what happens when the public overwhelms the agency with form and template letters. It happened to the FCC. It could happen to the FAA as some groups have published form letters with instructions to “urgently” comment on the FAA NPRM.