As far as I know, most public libraries' electronic lending programs are using something similar to Rakuten OverDrive and are limited to books published in electronic editions and then leased by the library systems. Do you know of any libraries other than the Internet Archive that make scanned copies of physical books available?
If you find yourself in the position of needing a copy of Charles Ross' biography Edward IV (https://www.google.com/books/edition/_/m8Ojo6VI8KUC?hl=en), as far as I know you're pretty much limited to the Internet Archive (https://archive.org/details/edwardiv00ross) unless you have an open research library handy. But you'd best make it quick, because the publishers want those copies deleted.
You could now try, if the DRM allows it, and the Internet Archive only temporarily during the lockdowns, through the DRM, allowed more than one person to read the book. That is, you could have had it for 14 days, but now you just couldn't renew it anymore unless nobody reads it.
I guess the correct term to use would be something along the lines of "lending that doesn't follow the legal definition of controlled lending" or something along those lines, but that is a somewhat unwieldy phrase to use as a part of most posts.
Uncontrolled does not mean zero constraints whatsoever.
Especially when used in opposition to the precisely defined phrase Controlled Digital Lending, where controlled is a well defined set of constraints.
Also, why does it matter if 130 libraries said they were okay with the CDL program, since that's not at issue here?
Library CDL programs were still online and functioning the entire time. Only the physical facilities were closed.