Cool experiment. I have a different take on how to fix this:
First, I audited every case of attachments claiming to represent more than 99 "comments" from 2005 to 2020, and the only ones with inflated numbers were not from legit organizations. This is because organizations with reputations to maintain don't want to be caught lying to the agencies they are trying to persuade. (https://judgelord.github.io/research/whymail/)
Second, if organizations are trying to drive up the comment count, and the only way to do so is to have a million people submit separate comments, they will tell their supporters to do that. This will (1) make it more difficult to participate, (2) make more of a mess for officials to process, and (3) lead to many more comments (both mass and non-mass) being discarded and lost in the mess.
Thus, the better way would be only to allow official organizations to upload bulk comments from their members and supporters (e.g., by asking for a tax ID number). Indeed, this should be encouraged, because when organizations don't do this and send their members to regulations.gov, they make a real mess of the docket, with lots of comments that add nothing beyond a number to the tally.
Where are you finding the number of people each attachment claims to represents, at the individual comment level? I looked for this for a previous proposed reg and was not able to find it anywhere!
Sadly, the field "numberOfCommentsReceived" seems to no longer be returned with v4 of the API. In previous versions, I believe this field contained a combination of the number the submitter claimed to represent (at some agencies) and deduping (at some agencies, now returned in "duplicateComments").
Interesting! Thanks. Glad I'm not missing it, but it would be helpful when I'm trying to figure out how many additional comments haven't been posted yet.
Cool experiment. I have a different take on how to fix this:
First, I audited every case of attachments claiming to represent more than 99 "comments" from 2005 to 2020, and the only ones with inflated numbers were not from legit organizations. This is because organizations with reputations to maintain don't want to be caught lying to the agencies they are trying to persuade. (https://judgelord.github.io/research/whymail/)
Second, if organizations are trying to drive up the comment count, and the only way to do so is to have a million people submit separate comments, they will tell their supporters to do that. This will (1) make it more difficult to participate, (2) make more of a mess for officials to process, and (3) lead to many more comments (both mass and non-mass) being discarded and lost in the mess.
Thus, the better way would be only to allow official organizations to upload bulk comments from their members and supporters (e.g., by asking for a tax ID number). Indeed, this should be encouraged, because when organizations don't do this and send their members to regulations.gov, they make a real mess of the docket, with lots of comments that add nothing beyond a number to the tally.
Where are you finding the number of people each attachment claims to represents, at the individual comment level? I looked for this for a previous proposed reg and was not able to find it anywhere!
Sadly, the field "numberOfCommentsReceived" seems to no longer be returned with v4 of the API. In previous versions, I believe this field contained a combination of the number the submitter claimed to represent (at some agencies) and deduping (at some agencies, now returned in "duplicateComments").
Interesting! Thanks. Glad I'm not missing it, but it would be helpful when I'm trying to figure out how many additional comments haven't been posted yet.