The last Hulk move had what, three action scenes in the whole movie? The Ang Lee version didn't have much more. Spiderman didn't have that much action beyond Peter Parker farting around until the end.
When this kind of movie has few action scenes, at least these scenes last quite long (far too long in the last Hulk) and have been included for the sake of the action. The scenes are spectacular and are done mainly to entertain the audience. It doesn't work like that in Unbreakable, Watchmen and The Dark Knight Rises.
Let's review the action sequences I can remember from TDKR (I will not discuss the quality of these sequences here because that's not the point, but for the record, they're mainly wrong paced with poor camerawork/editing):
- Opening plane sequence: a REAL a action sequence.
- Stock exchange robbery: starts like a real action sequence, and then becomes an anti-climatic chase... in which we spend most of the time watching reactions (people watching TV, cops discussing weither they're chasing Bane or the Batman, Catwoman...) rather than the actual action, appart fro ma few highlight in the tunnel. The point of the sequence is 70% "what people think of it" (about the return of Batman) and 30% "a cool chase".
- Catwoman vs the bad guys in the restaurant: real action, but short. It even stops being action once they leave the room: the part where Gordon is in the sewer is so quicly executed that it's obvious the only point was to get him to the hospital and know about Bane. It's not enjoyable at all.
- Catwoman at the bad guys office: starts like some real infiltration, then ends with a fist fight where Batman helps her and Nolan stops to care about what's happening on-screen: now it's about "Batman helped her" and "Batman's moral vs Catwoman's moral" ("no guns").
- Batman and Catwoman in the sewer: nice little montage of a few baddies getting punched. It's more of a comedic sequence than real action.
- Batman vs Bane, first try: like I said, the point here is to show a weak Batman, and it makes us sad. There is (almost) as much action in this scene as their is in, say, Tuco vs Wallace in the prisoners camp.
- The revolution: the stadium part is real action! Also very short, but hey, here, we're supposed to be entertained.
- Ultra quick killing of the army spy: well, that was quick. It lasts just long enough for you to get surprised, but do you actually remember what happens? They're walking, they die. One of them lasts 10 seconds longer than the others.
- Final: the charge of the policemen is never really shown to us (do you have any idea who wins this fight?) and the fact that their is no attention to details in it (strategy, guys?) is further evidence that Nolan didn't care about HOW things were happening, Bane vs Batman is ultra short and unspectacular, so is the chase that follows. Furthermore, the parallel editing does little to help the action to be developed, since we spend a lot of time just seeing what's up with each character. Even Gordon's friend death, which is overly (for what it is, since we don't care about that guy) dramatized is offscreen.
I probably missed a couple action sequences here and there (and telling the truth I almost forgot about the stadium, that's a last minute addition), but my point here is: Nolan didn't care about the action at all, here cared about what it means for the characters and the story arc. So even if you have a few action sequences, it doesn't feel like action.
To have them FEEL like action you have to do more than "cops shoots robber", "Batman hits Bane", "the Joker tries to shoot at the truck and misses it". You have to show HOW this happens: "the Joker aims at the truck, Batman sees this, drives faster and takes the shot". If you're not doing this kind of stuff in your action sequences, if the stakes and conflicts stand somewhere else (Batman being suicidal, for instance), then you're NOT shooting a real action scene. You're not involving the audience into the action. So may be there is a lot of "people shooting at each other" in TDKR, but there is very, very, very very few proper action.
You can have action sequences for the sake of the action, you can have them develop organically from the story, you can have both, but here, it's pretty obvious than Nolan put them for the story and then stopped caring about them. So, like I explained, my point is that if Nolan doesn't care about them, then it reports our attention on what he cares (which is where the stakes and conflicts are): characters and "sociological message", which were big points of TDK. And it's an epic fail with both.