I don't understand this entire line of discussion. Lets look at the definition of the word 'simulation':
noun
1
: the act or process of
simulating
2: a sham object
: counterfeit
3 a
: the imitative representation of the functioning of one system or process by means of the functioning of another, ex: a computer simulation of an industrial process
b
: examination of a problem often not subject to direct experimentation by means of a simulating device
I think 1 is of little use to us, as it seems to be effectively the same as 3. 2 likewise isn't terribly relevant here. Both of the senses of 3 seem pretty much what we're talking about here. So, when we simulate something we must thus have some conditions that hold:
a) The thing we are simulating must exist! OK, I'm willing to be less rigid on this point, we just have to be able to agree on its properties, so we can know what to represent when we simulate it.
b) There must be some meaningful process (functioning) of the thing being simulated. Clearly we would have to agree on what that functioning is and its salient characteristics.
Neither requisite a, nor b exist for a D&D dragon, ogre, or spell. They hardly even exist for a D&D fighter, though at least we can perhaps get SOME level of agreement on what a fighter is a simulation of. The point is, we cannot possible simulate, or have a simulation of, a dragon, ogre, or spell. No such thing is possible, and no RPG can ipso facto possibly be doing such simulating. It simply fails at the level of logical impossibility.
So, can we characterize this thing that an RPG, at least a fantasy one, is doing? I mean, we could more deeply consider the question WRT ALL POSSIBLE RPGs, as certainly a game which intended to portray jungle fighting in Guadalcanal in WWII has at least the bare logical prerequisites to potentially be a simulation. FRPGs and TBH basically about 99.9% of all RPGs ever written, nope!