That assumes all or almost all the work is writing the code, with no time allotted to actually using the app with that code written, benchmarking or other measurements, research about possible alternatives, etc.
Not at all! The algorithm is calibrated with real human effort. So find/replacing something 1000 times will have nowhere near the same value as adding 1000 lines of new code. And given 1000 lines of new code, you'll get the same value for implementing the same functionality in 100 lines instead.
What we don't capture is any product or communication overhead - however our platform has other metrics which can help find if these are causing inefficiencies :)
In a complex, mature system, a high impact bug could have a very small fix that is highly non-obvious. Your metric assumes that the person shitting out 1000 lines of a new feature no one wants is equally as productive as a distributed systems wizard who can fix bugs no one else can figure out adding a 3 line fix for an issue that customers have been complaining about for years. It is inherently biased towards adding new features and against maintenance and system quality improvement.