The Copyright Board deals with published materials. Since archival materials for the most part are unpublished materials, our materials are not covered by the Copyright Board, so we don't have a lot to say about the Copyright Board.
I know that the process has been criticized for being very long and complicated. Certainly, we have issues around orphan works in archives. There have been some suggestions to include published materials as well as unpublished materials under the Copyright Board. I'm not sure that adding the burden of unpublished materials to the Copyright Board is the way to go for orphan works. I guess my answer, in terms of archives, is that I don't have any concrete suggestions, but I wouldn't recommend adding unpublished materials to the Copyright Board mandate at this point.