I think the way ntpd is started the way it is, is to get proper timestamps in logfiles, and no time jumps when services are running. So it is likely put as early in the boot process as possible.
-Olaf. -- ___ Olaf 'Rhialto' Seibert -- The Doctor: No, 'eureka' is Greek for \X/ rhialto/at/xs4all.nl -- 'this bath is too hot.'
