Wow, I hadn't considered that. It might explain why I get terrible battery life when playing movies on a TV over HDMI with the screen "turned off" by dimming it down to zero. Thanks for the hint.
Perhaps latency? Suppose it takes 0.5-1 second to switch between "Off" and "Lowest brightness" when turning On/Off the GPU, that could create a bad experience when every other brightness change is instantaneous. Though it is a great power optimization idea, if the (unknown to me) downsides aren't too bad!