True. On the other hand, the rules should simply state that there is no provision for playing "monster PCs" instead of offering a laughable "system" along with dire admonitions.
Either the rules allow for it, or they don't. If they allow for it, specify it. If they don't, then don't provide "guidelines" that clearly don't work well.
As "penalizing" as stock 3.5 is for high-ECL races, at least there is a relatively consistent mechanism.
Of course, the +2 CON, -4 INT, -4 CHA does tend to restrict one to the more martial classes. (In 3.5., I'd be thinking Swordsage...) Although Druid or Cleric isn't out of the question, either.