It would be better if they just used that subset and just published it directly instead of needlessly repackaging it, but if that's what was meant then sure. Maybe we need a better name for simple, semantic HTML and basic CSS.
The point of it is to be a self-contained package. You still need hardware to read it, but not a server. In theory at least, once you have it, it's yours. (of course the commerical ebook vendors are trying to spoil that.)