The university libraries have jumped in the orphan works fray, giving their unique perspective. In a reply comment to the Copyright Office, Dale B. Canelas, director of university libraries, writes:

Of the volumes identified in UF collections as so brittle they should not be used again until reproduced, approximately 40% are copyrighted. And of these, only 10% were published by publishers we know to continue in business today. … approximately 38,000 volumes unique to UF – mostly regional and area studies collections – are in immediate danger and will likely deteriorate beyond recovery before copyright allows us to do anything to preserve them. (emphasis added)

The full comment is available here in PDF.

We should applaud the UF libraries for their forward thinking. This sort of input is exactly why the Copyright Office asked for comments in regards to the problem of orphan works. The libraries are wise to voice their support for copyright reform in this situation that so hampers scholarship and does irreversible harm to preserving Florida’s history.