Comments that have no legal force (because they're not actually required to respond or respect them) surely aren't.

There's other situations like community meetings for land use that are far more democratic. Although, those are mostly bad, because it means only people with lots of free time can attend them!

Yet public commentary was requested and even required to be evaluated. Therefor, fraud existed. Either is was the US government implying this was a democratic process, or the perpetrators of identity theft committed a crime. Which was it?