Quite possibly. Also factor in that everyone is going to start with 0 draft points, so if you save them up at 2 per week, you'll have 54 to spend on that draft.
If you do just enough to promote, you will most likely have a mediocre D 3 roster anyway (by USA standards) because very few teams will have enough money to invest in an actual D 3 quality roster. And, those that have quality players are most likely older players and will drop skills quickly.
I think the best way to go is to try and hold your own until just before the allstar break and then look for bargains on the TL and try to do enough to promote. From there, it may or may not make sense to tank D 3 or to try and push ahead to D 2.