Your points in regard to the combination of Level 3 and 4 for testing purposes are well taken from a technical point of view.
My concern is that both are required for the business process, so there is little practical value to courts from compliance with Level 3 but not Level 4.
I fully agree that the e-commerce shortcomings in the current DTD are serious and must be rectified.
Part of that solution necessarily involves Court Policy, which suggests that Level 4 cannot be established for ECF 1.1 in isolation.
I would suggest that is also true for level 2, except that I don't want to be thrown out of the TC.