Off topic for a moment…
This is standard practice for a LOT of colleges. Williams has similar numbers, as do Wellesley, Boston University, and many others.
There is some overlap between Bates and the other colleges OP has listed. If it’s her top choice and she wants to remain on the WL, there is no harm sending a LOCI, but yes, she needs to assume it won’t happen and get invested in the choices she has.