Does the minimum change based on the displacement resolution? Because a scale of 9 just so happens to match the number of vertices on an edge for a "power of 3" displacement.
OK, I know what each of those words means separately... but I have no idea what they have to do with each other. Also there are eight vertices on the side of a power 3 displacement.
But yes, the minimum lightmap scale is proportional to the size, as it turns out; I shrank that brush down to half the size both ways and I was able to get it down to 5 before it complained. I guess I could believe there are technical reasons for that.