Yes i would agree.
Spoiler deflection cannot be related to IAS or something like that.
It starts at a specific point of control wheel displacement and is proportional to this.
In my opinion during some x-wind conditions you have to give much aileron input (with spoiler rise) to keep the wings level during rotation. No matter if it causes too much drag, according to the FCTM. (Still better than a wing tip touching the grass
)