The only Ms 22 with countershading I can remember is
Washington, such as
this photo. I can't tell you if it started on any particular level as the regulations generally didn't go into that level. The goal was to reduce shadows and you'll get that at any level, so I doubt that it was for any particular level and higher, it makes more sense to focus on platform depth than height. But I've only ever seen an order to paint certain ways, no exceptions other than when there was a pattern (Measure 12, 22, dazzle, etc.)
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Tracy White -
Researcher@Large"Let the evidence guide the research. Do not have a preconceived agenda which will only distort the result."
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Barbara Tuchman