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.