I'm not sure this is true in practice, if we're counting init scripts themselves. Which we should, because init scripts are code and they often re-implement standard systemd features. Usually in wonky, broken ways.

What about other init systems? The GP said "any alternative." I am not familiar with how complex they are but was under the impression that there are a number much simpler than sysv init?

I think that even if we count init scripts which are way different level of complexity than C LoC, the Systemd would still be larger. Especially if we count just the scripts that are deployed.