xdm starts at S99 for purely historical reasons. It was that way when I took over the X packages from Mark Eichin in 1998 and the closest thing to an articulated reason I ever came up with, or heard anyone else offer, for leaving it there was the usual exceptionalism having to do with X. The default configuration is to run a local X server, of course, and that will go poke the hardware rather hard (which most daemons don't do).
I think in the years since someone has filed a bug requesting that xdm (and the other *dms) be kicked down to S90 or so. Certainly once mode-setting gets into the kernel, I think any remaining reasons for leaving xdm at the tail end of the init sequence will have been vitiated.
You should certainly raise this issue with the current X Strike Force when you feel the time is ripe. xdm is where it is almost entirely due to inertia.
I find the EEE 1000 model very tempting, so I am watching your work with great interest and appreciation. Thank you for your efforts!