This is true, but also - not every action scene needs to be an active environment. If the scene itself isn’t in some way wild and interesting, you’re probably better off having some bigger scene challenges in place to reflect whatever is going on, and then the twists can be about the challenges themselves.
Like, if I was just having a fight with four heroes against a villain on a Crowded Megalopolis Street, I would probably take the following scene elements:
- The villain, probably with an upgrade if the scene is moderate difficulty
- A set of minions for the villain, possibly with lieutenants if it’s appropriate and I didn’t upgrade the villain
- A 3-4 step challenge involving getting civilians to safety before they’re trampled or caught in the crossfire. Twists either reflect what the heroes are doing, or reflect partial success through damage and people getting hurt (or killed, if you’re going dark.)