I don't see how pgsql could perform such optimizations as eliminating a sorting step when ordering results by column(s) in a clustered index if there is no guarantee that new or updated data will also be ordered by the clustered index. I agree that both models have their pros and cons. While I am a big fan of pgsql, I do also appreciate those databases that offer both heaps and clustered indexes that I can mix and match in my schema as best suits my workload.