Yes, but preface can never be reached if there is no top level. That is the point. It looks like it is just for display purposes and you have no control over the display. Various readers display the ncx file directly and you have no control over this. It is not part of the book flow. You can place the above in an inline toc inside the book if you wish. But even in Paper books the preface is not shown as a level two by itself. There could be an Introduction section with dedications, preface, etc. in them or it can be under the title page. ncx is for traversal purposes not aesthetics.
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