I lean towards yes. Freeze is basically a game ender if either side gets it, since it pretty much stops the frozen pokemon from having a turn for who knows how long, whereas frostbite is essentially burn, but it cuts special attack instead of physical, which is still big, but not a game ender. Plus from a balance perspective, frostbite also acts as a way to counter special attackers, which is huge since there's not very many ways to do that otherwise, especially compared to physical attackers which are countered easily and consistently by things like burn or intimidate.
Honestly I'd like to see frostbite replace freeze in the main series as well, plus maybe a will-o-wisp type move, but with frostbite instead of burn.