This seems pretty wrong-headed to me.

Yes, the ROEs reflect strategic considerations. They must; especially in the environment we're in.

I'm not sure why you think JA's add a PID component to self-defense. I'm not aware of any case this decade where a SM was court-martialed on such basis.

ROEs can and do reflect considerations beyond the LOAC. Certainly one could dispute the efficacy or need for certain limitations; but that's not a discussion we can have in an open forum. But I'm not aware of any such limitations being based upon misstatements of the LOAC.