But then you're no longer doing anything that comments on Tolkien's actual work
It looks like it's basically shifting the view of the original LotR into an in-universe text with some serious history-as-written-by-the-winners bias instead of objectively described stuff that really happens. Haven't read the book yet, but this seems like a pretty interesting approach to me. It's a fun twist on the generally very literal-minded way speculative fiction is read.
This may be old news to some people, especially the Russian speakers, but I didn't see an article about it here.
In 1999, Kirill Yeskov, a Russian paleontologist, wrote The Last Ringbearer, a 270-page take on Lord of the Rings from the point of view of a medic in Mordor's dying armies who is also a "skeptic and a rationalist." In fact, Mordor represents the forces of reason in this retelling of the story. As a Nazgúl (himself a former mathematician) explains, Mordor is "the little oasis of Reason in which your light-minded civilization had so comfortably nestled." Barad-dur is "that amazing city of alchemists and poets, mechanics and astronomers, philosophers and physicians, the heart of the only civilization in Middle-earth to bet on rational knowledge and bravely pitch its barely adolescent technology against ancient magic."
The story has been newly translated and is available in free PDF form -- in English and the original Russian. There's a recent review from Salon as well.