I don't qualify it as envelope protection, because it doesn't actually prevent you from doing something daft. This is a characteristic that seems to be common in every system I've heard of described as an envelope protection system. Though in a sense one could consider it one I suppose in the absence of a malfunctioning AoA sensor.
If it were envelope protection. It would serve the purpose of preventing you from getting into an untenable situation, regardless of your control inputs. MCAS doesn't. You can go all the way to stall with it, and it just keeps cranking down the trim to keep the control stick force curve from inverting.
It creates the piloting experience (look and feel) of 737 piloting, but introduces new and lethal failure States due to the lack of error checking, and graceful degradation of functionality.
There's other issues, but that's what sticks out to me.
To be clear, my categories of the different applications of FBW are built by the distinction between what it is trying to do. Take the F-16, or F-117 as an example of Fly-By-Wire making an unstable aircraft controllable versus Airbus control law system, which basically takes a stable airframe, and exposes a common user interface so similar control schemes can be used for physically different airframes.
The first variety has no place in Civil Transport. The second absolutely does.