Obviously DNA is low level. This means it must be assembler- and assembly often is as simple as removing comments and translating "written" code into "machine" code.
Yes, if your "compiler" translates "assembly with comments" to "assembly without comments," then your metaphor is apt.
Update: After reconsidering, I take it back. Introns are important, especially intron boundaries. So, my new assertion: so long as your "compiler" translates "assembly with comments" into "assembly with the same comments intact," then I agree that your metaphor is apt.