Spent a while over the past two days looking at udev, and specifically, the udev initrd/earlyboot integration work. I still think that things could be simpler if udev didn't try to allow any policy that anyone could ever want, but I know how to choose my battles and that's not one I'm going to fight right now.
I don't think that anything I suggested should be too controversial. Granted, this is completely ignoring the “persistent device naming” issues and some other stuff, but it will get us started down the path and we can make improvements from there.
I do think that the lack of ability to have “access device, load module” is going to break a fair bit, but again, start down the path and go from there I think. If we turn it on and things start breaking for a lot of people, then we know of things that are broken and can decide what to do from there with better information as opposed to now which is going to be largely incomplete information.