Some might call that genre emulation rather than simulation, but I still think it's a good point. I might put it more that - what are the proper referents for simulation, and what counts as sufficiently well simulated?
I apologize for not getting back to you - I've been very occupied recently. That said, I wanted to address this issue in a general way before addressing the issues more specifically.
First, I think I need to explain why I don't participate in many of these conversations any more (and this is not directed at you, by the way!). One of the recurring issues I see is what I call the "Texas Two Step," when it comes to jargon, and despite devoting several posts to the issues with it, it just keeps happening. Let's use "simulation" as an example.
"Simulation" was first widely used in the threefold model (GDS). While it has various definitions, I'll just crib the one from wikipedia which is close enough for our purposes-
Simulation is concerned with the internal consistency of events that unfold in the game world, and ensuring that they are only caused by in-game factors - that is, eliminating metagame concerns (such as drama and game). Simulation is not necessarily concerned with simulating reality; it could be a simulation of any fictional world, cosmology or scenario, according to its own rules.
Notice that this is jargon. It has a specified technical meaning that arose in the context of RPGs, and it was about goals. It was trying to set it off against the "G" and "D" components.
The trouble is that while this is jargon, it also has specific connotations that people are familiar with in the real world. For example, when someone says that a pilot has 1,000 hours in a Boeing 737 simulator, a person who hears that assumes that the machine is designed to simulate the reality of flying a Boeing 737- not just some fictional world. In common parlance, simulations usually reflect our reality.
So this is where the Texas Two Step comes in, over and over and over again.
Zeno: I like playing that RPG because I like Lord of the Rings.
Achilles: Well, we all know that is a simulationist RPG. You like simulations! (Using the JARGON)
Zeno: Um, sure. I like the way the game immerses me in the feeling of Middle Earth, and the fiction of Tolkien.
Achilles: HA! How dare you say that? Don't you know that game doesn't accurately simulate the economics of Middle Earth? For that matter, how can a world exist on the same technology for thousands of years? It's not a simulation! (Using the COMMON VERNACULAR)
Unfortunately, this happens repeatedly- people that deliberately conflate jargon with more widely-understood meaning in order to berate people for differing preferences. It's the Texas Two Step- first, get people to use jargon, then use the non-jargon meaning to criticize them, and then go back to defending the jargon. Rinse, repeat.
So when I say that FKR is "simulation," I only mean that by default, it doesn't really do a great job of advancing G goals (because it relies on minimal game mechanics) or D goals (because D goals are usually created through emergent play), and instead is concerned with in-game consistency with a fictional world. And I don't say that to exclude other goals, or to say that others don't have success with it- just to relay my own experiences running it.
Okay .... now, addressing the following specifically-
If I thought that simulation depended on structured referents and relationships (i.e. models), and I believed that those were not internalizable, then it would seem I should not think that FKR can achieve simulation. Going from the other direction, if I think that FKR can achieve simulation, and I think that simulation depends on models, then it would seem that I ought to think models can be internalized.
I think that this is an interesting way of summarizing the push-pull that FKR illustrates. There are those that have spoken eloquently in this thread about why they prefer and enjoy rules for purposes of simulation. There is nothing wrong with that- to use an obvious example, having a common set of written and known rules is great when you have groups that are not familiar with each other and with the shared fiction. Because these models aren't internalized, or because these models are internalized differently, then FKR will probably be harder to run.
On the other hand, when internal models are close in alignment, and/or there is trust that differences in alignment can be resolved equitably by the participants, the advantages of running with a lite rulebook can shine- from speed to engagement.
I hope this answers the questions you were asking, albeit in a roundabout manner.