Right,  it all depends on how many modules you have on a page.

In practice you could create a few containers, with H1, H2 and H3 tags.

Depending on the importance of the module you would use a different container.

If a module would be alone on a page, or more important then the rest it would get the H1 container.

If not the H2+ container

Difficult to solve for the example skin (I don't want to add more contianers, it will only confuse new users).

I guess H2 would be the best compromise here...

One of the things on my wishlist is to add Skin and Container settings into the core, similar to the Module Settings bits. I don't see the point in having a million copies of the same skin/container to only adjust a color setting, css class, or html headers. If the core allowed skinners to add settings which the portal administrator/host account could easily override in the skin/page/module settings controls, thing would start to get alot simpler for everyone...