Three-railers aren't the only O scalers experimenting with battery power; two-railers are doing it, too. The three-rail guys share much the same concerns. Also, unlike three-railers, they can't run analog and many DCC locomotives on the same track at the same time.
Plus, there's another factor: many of them would like to set up outdoor trackage, particularly those lacking the wide open spaces needed for articulated steam locomotives and full-length heavyweight and streamlined equipment.