I'm nearly certain commenting, at least from my monitoring of commenting on ATF rulemaking, achieves the opposite of what the commenters hope. While there is ~

I'm nearly certain commenting, at least from my monitoring of commenting on ATF rulemaking, achieves the opposite of what the commenters hope. While there is ~zero chance that commenting can help you, it absolutely is used against you as their lawyers sharpen their claws by crowdsourcing possible sources of challenge and use your comments to predict them and determine how to undermine such positions.