You're making this way more complicated than it needs to be.
I don't know what you're replying to, but your "simpler" version starts with what ron suggested and for multi-user setups recreates the /usr/local model. Or was this to the earlier man subdir question?
No recursive binds are needed in either case. The list of binds would be shorter with /usr/local than /opt, but that doesn't seem like much of a win to me. Includes in /lib/namespace for each package should make it even less of an issue. Our file server at the labs had >350 lines in /lib/namespace and the overlay worked very well.
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