It's not assuming it follows the same restriction as programs, but rather imposing the same limit System has which is an appropriate interpretation barring actual errata to the contrary.
Firewall is
software, but it is not
a Program ... it's a Matrix Attribute.
If it were a Program, it would count against the System's limit on concurrently-running programs. However, it is not, and thus, does not.
If it were a Program, it could have program Options. Including Optimisation, or Ergonomic. However it is not, and thus, cannot.
Simply put, it is abundantly clear that Firewall is not "a Program", and thus, neither limited as Programs are, not eligible for the same advantages Programs have access to.