How confident are you of "Probability penalties are epistemic features - they affect what we believe, not just what we do. Maps, ideally, correspond to territories."? That seems to me to be a strong heuristic, even a very very strong heuristic, but I don't think it's strong enough to carry the weight you're placing on it here. I mean, more technically, the map corresponds to some relationship between the territory and the map-maker's utility function, and nodes on a causal graph, which are, after all, probabilistic, and thus are features of maps, not of territories, are features of the map-maker's utility function, not just summaries of evidence about the territory.
I suspect that this formalism mixes elements of division of magical reality fluid between maps with elements of division of magical reality fluid between territories.