Just to be clear, this is equivalent to saying don't bother with SSL for your blog or cat-sharing site (because without pinning someone else can get a cert for your blog/cat-sharing site).
> the ability for sites with low security requirements to opt out of HPKP.
opt out?! It's off by default.
> Remember, the threat model for HPKP isn't fraudsters or trolls; it's state-level adversaries.
Again, by saying HPKP is only for high security sites (now you're saying only for those threatened by state-level adversaries) you are essentially saying SSL is useless for everything less.