There would probably be more fatigue when going full speed using full explosiveness in multiple directions against multiple world-class athletes than performing a simple dribbling drill. A player wouldn't get winded in one possession but the intense repetitive dribbling might be enough to affect their shot, and the effect would compound as a player does that continually.
That said it seems 2K sort of lumped the loss of focus, accuracy and control from over dribbling and exertion into their "short term fatigue" model. I wonder if the zig-zag cheese prevention mechanic still exists separately from the short-term fatigue mechanic.
It might be better if dribble fatigue was thought of or named something like "Focus". Fatigue tends to suggest pure physical tiredness, while something like over-dribbling before shooting might also involve loss of accuracy and stability due to mental concentration, repetitive motions in a short period, and elevated breathing.