That's not for in-VPC functions, although if the underlying instance changes with firecracker migration users might see ENI start improvements. Currently your ENI usage is roughly floor(3GB/Memory Allocation)*(Concurrent Executions). If the 3GB changes users will see huge gains as each ENI creation can take around 9s.
I'm wondering how that's even possible if it includes the time for downloading your code from S3. I.e. normal cold starts (as I understand it) involve fetching the code from S3 to install on a VM. Perhaps they aren't including that time when claiming single milli cold start times?