I think so. Given the tolerances usually laid down to holding patterns, I can't imagine the difference between an aerodrome and that ad's DME not co-sited being enough to cause a major terrain clearance problem, so the other alternative would appear to be entering a 14 mile leg from a non-DME waypoint, (CCK?) a different matter altogether.
Thanks. Just curious, I certainly won't be offering any opinions on the crew's actions.