One of the reasons we've been reluctant to label the new round of PvP gear "PvP Tier 2" is because the damage is in fact on par with the Tier 3 Raid sets.
When we sat down and made the PvP gear which accompanies the Shrines of Bori we decided to give it stats which would be representative of the highly competitive nature of that PvP content. Since Tier 3 raid gear is the current "latest and greatest" in terms of raid