Comments wont appear if you spread the votes over multiple comments
This could work if the number of comment are high (say 20 or 30 per day), and people spread out their votes on the lower value comments, but that's a bit of a leap, since you can't control where people vote.
Based on low effort of the presented content
Low effort is kind of irrelevant since the reward is zero. The ratio of effort to reward is more favorable than any other post in fact.
Now if other people want to make higher effort, higher quality posts and also burn a serious chunk of their rewards (maybe not 100%, but also not the token 3% that I sometimes see), they would probably get more votes than burnpost (since, yes, by intent and in fact burnposts do suck on matter of content), and this problem would be solved.
Despite being the creator of burnpost, I routinely direct my own vote power to other posts that burn and also have other value instead of to burnpost (which only burns and has no other value), so this is not entirely theoretical. I'm pretty sure I'm not the only one.