Saying "you can modify the documentation, just not the invariant sections" isn't enough, incidentally, to answer this, because the attachment of the invariant section to the documentation *is* a property of the documentation. (Consider if there were such a thing on a piece of software: you can modify all these functions, but not that one. The result is that the whole thing is nonfree.)
This would be like having a technical section which can't be changed. That would be non-free, but it's not what our actual invariant sections do. For them, the preamble of the GPL is a better analogy. That too is text that can't be changed or removed from the program, but does not restrict its practical functionality.