Script Frenzy is about writing the script. The fact that the script is going to be used for a Graphic Novel and not a screen or stage play is immaterial, it's still a script. 100 pages of graphic novel layout is not the same as 100 pages of written script.
While I think your idea is inspired as far as mapping out your story, I doubt that it would count as an actual "script" and verification would be very difficult. If you don't care about verification, then it won't matter. In fact, none of the rules actually matter unless you choose to abide by them. But this is not, even in the very flexible and non-codified world of comic script writing, a script.
--Jenn
SF! '08 Adaptation of NaNo '04: Wedding Tarot
http://www.theweddingtarot.com/blog
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