IMHO still is. Just don't add any JS or CSS
On top of that come issues like the lack of pagination support in browsers, which make long document impossible to read and practically require to add custom UI inside the website itself.
ePub works much better, with readers giving control over line spacing, font size, pagination and proper markup for TOC and other metadata, but despite ePub being based on xHTML, browsers have ignored it (only old Edge supported it for a little while).