Yes, all images, models and sounds would be gone. Even if you made a barebones replacement that only provides a very limited selection of assets you would need to create thousands of files just to achieve basic game functionality (movement sounds, guard clothes and speech, menus, tools and weapons etc.). It's probably orders of magnitude more work than when TDM got rid of all Doom3 assets for going standalone in v2.0.
Technically it's probably possible for an FM to contain a full game's worth of assets, except for the code itself. IIRC some Doom3 mods had custom .dll's to extend the base code, though.