That's not really how NaCL works. Any instruction that can't break out of the jail can be whitelisted; this includes all versions of SSE.
Additionally, PNaCL can be retargeted at as-of-yet unknown architectures.
The result is that binaries would have been either shipped as PNaCL-only, or optimized for i386+SSE1 with fallback to PNaCL. As new hardware was shipped, new binaries could be targeted appropriately.
This seems reasonable to me; default to portability, provide an option for best-case performance.