Should the nav element be sectioning content?

Recently we've been nurturing the document outlines at Lonely Planet to create a simpler snapshot of the page for both accessibility and SEO reasons. One thing I was surprised about is how the nav element creates a new section in the document outline.

Sectioning content requires a heading or it will appear in the document outline as "untitled".

How often do you code up a navigational section with a heading? More often than not the elements and their position on the page is self-documenting. And do you even want your navigation to be part of the document outline at all?

It is worth noting at this point that VoiceOver (I haven't tested other screen readers) will not read out 'Untitled nav' and will just honour the links within. Also, not all html5 elements create a new sectioning context. footer, for example, does not.

Decision time

This leaves you with a few options for marking up your navigation:

Which do you think is currently the most practical? More importantly, is the spec serving the majority of use cases with nav being sectioning content?

Handy resources