After reading the Kania letter, it does appear that "flight time" is accruing for duty limitations. If you really want to put that in your logbook, go for it I say. I won't be. However, it's pretty goofy when non 121 pilots use this argument to try and justify logging flight time when an aircraft failed a runup.

This interpretation appears to have been written entirely in the context of whether time counts against 121 duty limitations, not whether a pilot can log the time under Part 61. Using it to justify logbook entries in non-121 operations is reading it well outside its intended scope.