In the forward looking sense you are using it, sure. In the backward looking way it's usually used ("development on that is slow because it's full of technical

In the forward looking sense you are using it, sure. In the backward looking way it's usually used ("development on that is slow because it's full of technical debt") it usually 10% what you are talking about and 90% over engineering and stupid things that were done for no good reason at all where no one at the time was even thinking about the tradeoff for speed.