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Yes, the way BytesGenerator works is basically a hack to get the email package itself working. Use cases outside the email package were not really considered in the (short) timeframe during which it was implemented.
The longer term plan calls for redoing the way payloads are handled to generalize the whole process. I'd like to see this happen for 3.4, but I'm not sure I'm going to have the time to finish the work (I'm hopeful that I will, though).
In the meantime, while your suggestion is a good one, I'm ambivalent about applying it as a bug fix. It is on the border between a fix and a feature, since the email package in 3.x hasn't ever supported bytes payloads, only encoded payloads.