Yes, it simulates something close to it, but I think the two-step distinction is enough that avoiding the word "rape" and its connotations is very appropriate. The "degrading and violent" taps into certain emotions, but lacks certain key other emotions and characteristics that make rape so bad and hurtful. To name some, the helplessness feeling is most likely not present (since it's consensual, as stated), and the whole existential crisis that is triggered by the emotional cascade and status markers and mental model updates that all happen at the same time during or in the aftermath. The trauma oft associated with "rape" seems to come mostly from those missing elements, so I wouldn't include this in my carving.

Obviously, there is a distinction between rape and BSDM play that simulates rape. Still, the claim that all penetrative sex is either rape or an attempt to capture certain emotional elements of rape seems very close to the statement that all penetrative sex is actual rape.