Eldartford: What you wrote isn't exactly correct. Although few folks will turn their volume up to max, there are ocassions when that becomes neccessary. I have experiemented with amplifiers with sensitivities so low that my volume control was at max with some recordings.
But, the reason I stated 100% of the range is that the loudness control is a relative to the volume setting. By design, if it can't function properly over 100% of the range, the circuit is flawed by definition.
Secondly, all preamps have a dual knob loudness control if they have a bass control. Simply turn the bass up slightly to your preferece when you turn the volume down. At least you will get the proper amount of bass. Please understand the loudness control is simply nothing more than an attempt to eliminate one additional tone adjustment. It isn't much effort to tweak the bass control a smidge.
Lastly, the Fletcher Munson curves are an average, they aren't correct for all humans. Consequently, even if the loudness control followed the curves perfectly, it would still be wrong for many, if not most, of us.