I'm not going to rule it out completely until I see it tested or get around to testing it myself...the game ties a lot of stuff to the frame rate. I haven't seen anything quite like it since the DOS days of gaming.
The bigger issue is that FPS is limited by the netcode... it was particularly visible in the final battle of the Wyrd Wars, when we somehow managed to get 60+ CMDR's drop into a single instance. As the number of ppl grew the FPS gradually went all the way down to the 25 to 35 range. And I had 120 FPS (I was using the limiter) at the beginning.
BTW I'm experiencing a severely reduced FPS since the September update. I used to have stable 144 FPS (a little bit less but still above 130 in rings and near stations) with my usual settings (1080p, no supersampling, everything else maxed out, ingame frame rate limit set to 144). Without the limiter it used to be well over 200 FPS in open space (it's an i7-8700 + RTX 2080 laptop with a 144Hz GSYNC display).
I've been using it with the limiter set to 90 FPS lately (because the fans are pretty loud at max RPM and I usually play while the kids are already sleeping), but yesterday I turned off the limiter because my son said the wasn't able to get more than 90 FPS on his new RTX 2070 rig. I was surprised to see that it was the same on my laptop (90 to 110 FPS, not only in rings but also in open space).
It may sound pretty good, but it's not - considering that it used to be more than twice higher the last time I checked. And my graphics settings are the same, and neither the CPU nor the GPU is close to the thermal throttling limit (I'm constantly monitoring the frequencies and temperatures and the figures show nothing unusual).
So there's definitely something fishy going on, but I'm not yet sure what. Maybe it's an issue with the latest driver, although I don't experience similar FPS drops in other games.