To me rate of fire is like the term assault weapon. My rate of fire would probably be different than yours with the exact same equipment, and compared to Jerry Miculek's, lol...
Who is going to decide what the "ROF" is for each gun? If I change the trigger so it is smoother, but I don't change my ROF, will that be okay, if its not - who is going to determine that my ROF increased, the gravel pit police? What if I build my own gun from the ground up and choose a Timmney Trigger, does that make my gun okay, but the factory gun with an aftermarket Timmney not okay?
Maybe they should just say you cannot exceed the maximum ROF inherent in the design - you know the ROF determined by the physical limitations inherent on the design, i.e. the amount of time it takes to extract and eject the spent cartridge case from the firing chamber, re-cock the firing mechanism, and load a new cartridge into the firing chamber. This way the Jerry Miculeks of the world, and the rest of us can just go about our lives, hurting no one but paper and steel...