Does commuting count as training?

Yes.

Remember how high the intensity is of the training required to do this. That type of intensity requires an adequate level of aerobic fitness to maintain an effective period of this training.
And as such, once intensity increases there should be a corresponding drop in volume.

RPM, you are saying once you are peaking, doing several all-out efforts a week, drop the intensity of your commutes, or reduce how many you are doing.

Makes perfect sense and marries up with what I have learnt from running schedules.