How do 50+ frametimes indicate that this isnt due to frames dropping below 30 fps? (down to 22 fps in this case)
It 'is' frames dropping below 30fps - the argument was about what causes them.
There's an automatic assumption in tech-analysis discussions that frame-drops = GPU drops, 99.99% of the time even though that's categorically never been the case.
That said - I do remember original game hit the GPUs pretty hard on PC - 2080Ti was 'barely' enough to hit 60fps at 1800-1900p (GPU drops were still happening, but not common enough so I stuck with it).
Some folks in the Review topic were saying PS5 version drops to what feels like ~10 fps when the rats appear. The extra GPU grunt helps out the SX here.
DF footage shows big frame-spikes when rats spawn in on all consoles (but worse on PS5) that go away after awhile - but that's usually indicative of bottlenecks outside of the GPU.
Of course - it's not the only points where framerate drops (explosions and certain other things look more likely GPU related).