It's not that easy. You must understand Nintendo strategy to know that a new browserhax release needs a counter strategy or just wast developer effort.
Nintendo planted let's called it a bomb timer in 9.9+ firmware. When Smealum first hinted freeHax (tubehax + Ironhax), 9.9 was the latest firmware. People with 3DS/2DS between 9.2 and 9.9 if they had not one of the Ironfall game & Youtube app or both installed, they had update to 9.9 to access Eshop (fall right into the trap)! Then we had Browserhax and Themehax, at the time, it's so easy to get Homebrew Launcher so most people keep updating until 10.1 to have Eshop access along with their freehax. Nintendo went into action to kill off freehax: first tubehax -> browserhax & homemenuhax/themehax by releasing firmware 10.2. Then a day or less after Smealum released HAX 2.5 which allows Eshop spoof. Nintendo went for the throat of freehax by trigger the bomb timer to brick most of 9.9+ browser console to force update to 10.2.
Why do Nintendo target homebrew? Because with Hombrew Launcher, less people want to buy theme/DLC/app from Nintendo Eshop as we are seeing more of alternative to Nintendo Eshop app within homebrew community: Pokebank, HANS... It's harder to exploit on latest firmware of course, so Nintendo would like to force as much people to update as possible.
Why do next browerhax need a different approach? Imagine next week browserhax for 10.2 would be released tomorrow. Nintendo with their man power may release a new firmware with only specific patch for the hax very shortly after. As you know 9.9+ already has this bomb-timer implemented, so once new firmware appears, same old problem we're having, would re-appear at that future time.
Even with N3DS work-around. Nintendo would be happy with people frustratingly give up the O3DS and boost sale on N3DS. At this moment, Nintendo is pretty much cornering much the freehax users (if you discounting buying N3DS as paid hax
).
There's this brilliant joke: