Public comment is meant to surface arguments to be taken into account to guide policy. As such, having 1 or 10 million people make the exact same argument in the same words doesn't change anything.

This is only true in the most simple cases. If there’s any portion of a proposed policy which is balancing different interests - which is almost always the case - the ratio of comments is a useful metric because it would surface problems such as e.g. a policy which big companies are comfortable with but hit many small ones with substantial compliance overhead.

In this case, having tons of AstroTurf comments allows them to say that there’s public support outside of large ISPs. Given how anticompetitive the decision was, they needed that fig leaf.

No agency would be on firm footing pointing to a large number of identical form comments received for one side as a factor in a balancing of interests. It would not survive the “reasoned decision making” requirement. To the extent you’re talking about balancing the needs of small and large companies, for example, you’d have to point to concrete examples and data. That could come in comments (small businesses talking about real challenges they’ve faced), but relying on a large number of identical form comments wouldn’t pass muster.

If you assume good faith, yes. In the environment they were in where they knew that oversight was in friendly hands, however, I think they were just looking for enough to say the process was followed knowing that it’d be done before it’d get any critical examination.

Exactly. This is why the continued focus on "fake comments" in this process is so tiring... They didn't mean anything to begin with. Just as the comments opposing net neutrality didn't matter either. The FCC does not pass regulations by open voting and never did.

If the fake comments didn't mean anything, why make them?

That's a very interesting question.

I suspect this incident demonstrates the scope of disinformation campaigns and the industry that enables them.

It is totally possible that cramming a couple million fake comments into the FCC was done solely for the purpose providing a politician a "talking point" in favor of getting rid of net neutrality.