I will default my changes to "top", because this is the default behavior currently provided by OutputPage. In the spirit of trying to break as little as possible, I am now making this terrible historical default into an explicit value definition. The goal being to subsequently change the default behavior of OutputPage while breaking as little as possible.
"top" is a terrible default for styles that don't need to be rendered at pageload. If one of my changesets comes your way and it's obvious that the module at hand doesn't need to be in the head, please update the position value in the changeset to be "bottom" instead.