Interesting point (and important if we consider the author as a Tolkein critic). But I'm not sure if evil Orcs is totally inconsistent with Tolkein. If they're Elves who have been perverted mentally and physically, then they could end up effectively evil. It's also worth noting that they still have some deep senses in which they are good-oriented in the Catholic sense that Tolkein works with. I think there's a line about them essentially needing proper food, and also something about how they hate their leaders and creators. There's a sense in which they know they're WRONG.
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.