Hi Mark.
Not arguing with Chief Counsel's interpretation, DTDT.
But if you really are interested in learning, and understanding the confusion on this matter, I refer you to Webster's dictionary definition of the word, ""rating" :
((one of them) : "The designation of the operating capacity of a piece of machinery, as expressed in horsepower, kilowatt, etc."
With this common understanding of the definition, it is reasonable to understand that most people would take the meaning of "Rated" to mean qualified to act as PIC.
And, it is reasonable to expect that logging PIC and acting as PIC are one in the same.
The fact that the CC has endorsed the special definition that is outside of the normal definition is why so many of us are outside the loop,..
...in the words of the Great Teacher, "Forgive them, for they know not what they do."