Of course, if they eventually adopt the quad layer disc, this may be possible for some titles. It's a question of whether there will be sufficient demand for it.
The only problem with this approach is that it would only work with shorter films, and I suspect this is how Shout! Factory has handled its short documentary titles. I'm pretty sure there isn't a feature length title out there that uses less than a BD-66 and in some cases a BD-100 triple layer...
Standardisation seems to have been a problem from the dawn of the digital formats, and one on which our dear RAH has been raging against the machine for some time. http://www.thedigitalbits.com/site_archive/articles/robertharris/harris102802.html