No, the keypool feature was created as a response of someone else (see
http://forum.bitcoin.org/index.php?topic=782.msg8620). The creation of at least one new address must be triggered in order for the keypool to be filled, and that is still the case for version 0.3.22. So is there a reason why a new wallet.dat contains only 1 keypair until you create a new address? Seems like a bug to me...
Oh sorry, anyway close enough. But yes, its a bug and there is a pull to fix it, probably to be pulled very soon or fixed in some form or another.