That is not strictly required though. LE did this in order to speed up the rollout but you can also skip that step and submit the root CA to the appropriate places, e.g. Mozillaʼs CA Certificate Program.
Anyway I'm not arguing that it would be impossible to create an LE2 but it would not be that simple. Especially if the buyer is someone already in the certificates business that wants to destroy the "free-for-all" concept.