I disagree. Comments cited by the FCC's final report and decision are part of a permanent public record that can be scrutinized, including in lawsuits (such as the one filed by the EFF) and by politicians considering legislative changes in response to regulatory failures. Ajit Pai was forced to publicly dismiss comments containing only facts related to the technical details of the Internet, which made it harder for the FCC to defend its decision in court (as they are supposed to consider those technical details).

Also, it may seem hard to believe, but some regulators do actually care and they do pay attention to expert comments that the FCC (or whoever) receives. Sometimes they will invite the author of a well-research comment to meet with their staff and discuss the issue in more depth. The system is not as completely corrupted by money as people sometimes claim (not that there is no corruption at all; it is almost obvious that deep-pocketed corporations have outsized influence in these processes).