By Sarah Oh
Published in Real Clear Policy on September 14, 2017
After collecting over 22 million electronic comments, the Federal Communications Commission must now read and interpret them. Over the last few months, data scientists have observed that many comments are from letters sent from fake email domains. These entries are likely bot generated and not submitted by individual people. Should the FCC count these robot comments? If so, how?
The short answer is that when bot commenters come to Washington, government agencies will need to rely on artificial intelligence to interpret artificial intelligence.
The Administrative Procedure Act mandates that the FCC consider relevant material in the public record. But with 22 million comments, that is more easily said than done. The Office of the Federal Registrar states that an agency is “not permitted to base its final rule on the number of comments in support of the rule over those in opposition to it,” explaining that the process is “not like a ballot initiative or an up-or-down vote in a legislature.” Therefore, the FCC needs a strategy to deal with the comments in a meaningful way, basing its final rule on “comments, scientific data, expert opinions, and facts accumulated” in the administrative process.
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