I see your point in that the amount of the fees are not part of the calculation of the penalty.
However, why would anyone mine a block for which they will not be paid?
The incentive would remain to move fees off chain, especially as the coinbase reward decreased.
Off-chain fees would not be subject to the seizure and redistribution of the rollover.
Better for the miner to guarantee positive revenue and get it on the side.
I still don't follow you.
Why does it matter wether the fee is payed on- or off-chain. The penalty is the same and the miner has to pay it either way.