The battle lines around orphan works are interesting because they don't really follow the same contours as do a lot of the other disagreements about copyright law. From what I've seen, the main opponents of freeing orphan works are individual content creators and the organizations that purport to represent them like ASMP.

The fear I gather is that large content users won't make much of an effort to contact rights holders and will use orphan works legislation to just take it for free.

And this is one reason why i believe that copyright should require a minimal-fee registration every ten years. If you keep your registration current, there is no effort required to contact you. If you can't be bothered to do that, your copyright clearly isn't worth much to you and expires. Either way, the status of the work is unambiguous.

In the case of something like a photograph, that means a minimal-fee registration on each photograph every 10 years. This is also exactly the sort of effort that opponents of orphan works legislation feel that large content corporations will take advantage of when all the little guys forget to renew.

I'm actually mostly for orphan works legislation but I understand the perspective of the opponents.

Wouldn't it be easy to have a provision for bulk registration?

Like, "renew the photographs with SHA's .....", and then providing a simple tool to list all the SHA's of all files with a given extension in a directory?

One request with 50.000 photographs?

How about if I draw 7000 sketches or drawings in a year? How would that be "bulk registered"?