Chris
I think you are trying to split hairs. And the Marine Patrol will not be receptive to that. Skip has posted the definition that applies.
If you are securing any part of any kind of boat to the bottom of the lake in any way you will need a mooring permit.
The same kind of thing was used off the side of my dock for at least 20 years without a permit. One day the Marine Patrol showed up and said it was a mooring. After some research and a few telephone calls I discovered they were correct. Now I have a permit.
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