Yes, you are right. But when I see which tools are below /pub/os2/dev that aren't languages, I find it confusing to have a few under /pub/os2/dev/tools. I would just move /pub/os2/dev/tools with their dirs to /pub/os2/dev. Example: /pub/os2/dev/make.
IMO another dir that could receive some rework is /pub/os2/dev/util. In case of the one that I've contributed (htext201.zip), all files in /pub/os2/dev/help are rather utils. So why have some of them below dev/utils and others below dev?
Another dir is /pub/os2/dev/misc. I don't have an idea so far. So, there are utils, tools and misc. I would either remove them all or move many packages to either utils or tools and remove the others.