The whole "is online requirement = DRM" is a red herring. One can argue until they are blue in the face about it. To me - that is DRM, but it doesn't matter.
What DOES matter is they promised an offline mode (as previously quoted above) and have now retracted that:
Update! The above is the intended single player experience. However it will be possible to have a single player game without connecting to the galaxy server. You won't get the features of the evolving galaxy (although we will investigate minimising those differences) and you probably won't be able to sync between server and non-server (again we'll investigate).
Last updated: Tue, Dec 11 2012 3:56 AM CST
Not delivering what was promised - THAT alone is enough to get a refund. It doesn't matter if some particular person thinks of that as DRM and another does not. Red herring. Not delivering what was promised = REFUND eligible. Simple.
However, it is also OBVIOUS that Frontier knows that online = DRM; as they also have this in the FAQ:
Will the game be DRM-free?
Yes, the game code will not include DRM (Digital Rights Management), but there will be server authentication when you connect for multiplayer and/or updates and to synchronise with the server.
See - they recognize RIGHT THERE that a good place to mention the online requirement is in the question about DRM. Hmmm...