Eh, more important, honestly. To get a character up to 20-ish refresh to match a three or four person party, as the game book suggests, the powers wouldn't stack in a way that makes them actually more effective, meaning they'll just get swarmed by actions. Unless you put all that refresh into wizardry, which does stack, and puts it way too far the other way.
The Black Court are a prime example -- it has a whopping 14 refresh spent. Going by the guide-book, he should qualify as a challenging rating against a 3-character, Feet in the Water party all on his own. But its Fists are only at 3, its defense is at 4. That puts him equal, on those terms, to one feet in the water character who's built to fight.
Against two, he might, barely, be able to keep up. Against three, he's getting his ass kicked -- the odds are simply against him that they'll hit him more than he hits them.
And that's without getting into his weaknesses.
But you could build an NPC with no refresh spent on powers and make him a challenge just by setting his relevant skills at 5 or 6. Then, you have someone the party needs to maneuver against to reliably hit, one they'll need to actively and creatively defend against, instead of one they'll be more or less okay with if they just attack, attack, attack.
I firmly believe that Not All Refresh Is Equal. Refresh spent on combat powers -- attacks, defenses, etc -- should be much more dangerous *in*combat* than Refresh spent on social stuff; but in turn the Brawler is nigh-helpless in a social/diplomacy conflict.
The thing that makes those high-refresh characters so dangerous isn't (necessarily) facing them in combat; it's that, when you arrived Armed To The Teeth for that Boss Fight, you discover instead that you're walking into a Joint-Ops sting between local cops & the Feds, who are expecting a group who has an uncanny resemblance to... the PC's.
etc etc etc.
Planners PLAN. Manipulators MANIPULATE. Actually getting one of those foes to a genuine "boss fight" combat is... challenging. Just doing it is probably the majority of the victory! By all means, let the players get to apply their smack-down... but at that point, it may well be more like a coup de grace or "finishing move." The players actually BEAT that foe by getting them to the fight!
