I would certainly agree with that, but it is also more. In most martial arts, including most FMAs, there is little to any discussion of how to attack properly. That is something which fundamentally sets PTK apart from other arts. If one is threatened (someone has drawn a weapon, etc. against you) do I want to wait for them to strike, or do I want to attack when the threat is detected? The latter is obviously a better choice, otherwise you are focused on counter-offense, behind in the timing, and in serious danger right off the bat. This is even more true of situations when there is more than one assailant.
So, when does one learn to attack and how does that happen? The answer (and I know you know this) is that it begins in Doce Methodos 1, Multiple Attacks. While much of the early part of the system is about what to do when you are behind in timing and someone else has attacked you, in Multiple Attacks, you get the first taste of how to attack someone with proper mechanics. In addition, the tactical understanding of when to use certain strikes is introduced (what are the strengths of the horizontal jab, when would you use it? How do you strike if you have managed to quarter your opponent and you can no longer perform fluid strikes? How can strikes be linked together in such a way that manipulation of the weapon can get you ahead in timing if they manage to counter the first strike?).
So while there are certainly major aspects of Multiple Attacks that have to do with attribute building, and that is much of the idea behind drilling them in solo fashion, there are legitimate applications of these things which are important and viable. I know that you are aware of all of that, but I thought it important to bring out for purposes of the discussion.