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Thus far I've tried it with multipass with 3x VMs and it works well.

I guess that's personal preference on ease-of-use and resource usage. With k3d (docker) you can also interact with the individual nodes (e.g.

docker exec -it k3d-k3s-default-server-0 sh

to get a shell in the first server node). However, some things may work better in a VM where OS dependencies are present (e.g. deploying Longhorn that relies on iscsi-drivers of the host).