My broader point is that the majority of kexec issues are associated with the difficulty in quiescing the hardware, and there's simply no need to load the majority of drivers before offering this option which constrains the problem significantly.
Again, I think you’re thinking I’m saying which I’m not. I’m not saying it’s impossible. I’m suggesting the scope of work may be harder than they pitched which is that they have all the pieces and don’t really need to do much other than some packaging & some EFI integration. UDEV changes and kernel patches (more than the trivial 2 they have right now) would prove that the idea requires more work than anticipated.
I don't see any need for kernel patches, and the udev policy is just config rather than code as far as I can tell. Bringing kexec into this is certainly more complicated than not using kexec, but I wouldn't expect (and I do have some familiarity of working with kexec) this to be a lot of engineering work.
I'm more-or-less just a dumb user in these matters, but I've been using Linux to boot Linux with my semi-elaborate desktop rig because that's how ZFSBootMenu[0] do. Keeping [fairly] quiet about unnecessary hardware (like nVidia drivers) during this bootloader phase seems to be doing the trick for me.
Or, at least: I certainly didn't have to do anything to the kernel for it to work. I'm just running whatever Void Linux is rolling with right now.