The courts don't have to examine whether or not they think a rule change is in the public interest, nor would they have to conclude that the public interest is

The courts don't have to examine whether or not they think a rule change is in the public interest, nor would they have to conclude that the public interest is proven by what position got the most individual comments in support of it. https://en.wikipedia.org/wiki/Administrative_Procedure_Act_(United_States)#Standard_of_judicial_review https://en.wikipedia.org/wiki/Administrative_Procedure_Act_(... They could conclude that an agency unreasonably ignored specific arguments in public comments, but probably not that the fact that the agency wasn't swayed by the volume of the comments was unreasonable.