You've just done the same thing as the author of the article, only there are Raymond Chen references elsewhere in this thread that contradict your statements.
There was a lot of HW which only had DOS drivers which were loaded prior to starting Windows.
Yes, the Windows kernel took the whole thing further but it still relied on MS-DOS for some things.
TSRs (which amount to "DOS drivers") were notoriously flaky with Win3.1. Some requiring installation prior, some requiring installation inside of a guest DOS shell, some just not working at all. More reliable ones (such as MSCDEX) were explicitly compatible with Win3.1 and its IDT.
https://devblogs.microsoft.com/oldnewthing/20100517-00/?p=14...
There was a lot of HW which only had DOS drivers which were loaded prior to starting Windows. Yes, the Windows kernel took the whole thing further but it still relied on MS-DOS for some things.