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Some authors have as many as four levels in main text and appendices. As I count, this would require 13 structural levels in Mellel auto-titles: 1 for unnumbered headings such as used for Summary, Preface, Acknowledgment, and Reference pages, and 4 each for Summary, main text, and appendix "parts" of the document. Although it is probably good writing practice to avoid so many levels, some documents are inherently complex. To be sure, it's easy enough to treat lowest-level sections with mere editing (e.g., mark them with an underline, small font, or italics, but don't treat them as a sub sub sub section.). However, that means that they won't show up in the TOC or outline, if one cares.

I don't know whether anyone else has ever found the number of structural levels to be a bit limiting, but suspect so.