It could be, but I'm not convinced that's it. If I lived in San Francisco the system would be working all the time. I have found that the threshold for when it comes on is just above the point of most inclines I stop on. Enough for me to get roll-back when I take my foot off the brake, but not enough for the system to engage. If I let it roll back, then "jerk" the car to a stop, it will hold. Presumably, I've given the accelerometer enough of a nudge to get it to register. It does work well enough on steep inclines.
I was one of those who felt it was an unnecessary addition to the car in the first place. Hill hold is good for manual transmission cars where you have three pedals to work with two feet. But in the Model S, it is easy enough to hold the brake with one foot and let up on it as you press the accelerator. But the problem is with the feature in place, I never know if it is going to work or not.